Critical gaps in environmental permitting systems are leaving textile factories across ten major producing nations inadequately regulated—a finding central to a new report published by the United Nations Environment Programme (UNEP). The industry is estimated to account for between 2 and 8% of global greenhouse gas emissions and consumes 215 trillion litres of water annually, yet many operations can obtain permits without undergoing comprehensive environmental impact assessment.
- No consistent approach exists for classifying textile activities as posing significant environmental risk, creating loopholes that allow operations to proceed without full impact review.
- Bleaching, dyeing and tanning facilities operating above defined capacity thresholds are most commonly recognised as high-risk in national legislation, yet many smaller operations remain exempt from comprehensive environmental assessment.
- Most national environmental legislation is silent on gendered impacts, despite women comprising the majority of the global textile workforce and facing disproportionate exposure to hazardous chemicals.
- Litigation from the Asia and Pacific region shows communities have successfully challenged permit breaches on environmental and human rights grounds, with water contamination identified as a primary concern.
- The findings are drawn from Supporting the Transition to a Sustainable Textile Value Chain: The Role of Environmental Permitting Systems, recently published by the United Nations Environment Programme.
SCOPE AND METHOD: Researched and drafted by Rowena Maguire, Bree Hurst, Alice Payne, Paige Street and Alexandra Clark of Queensland University of Technology, the report was developed in partnership with UNEP and subjected to expert consultation and independent peer review. It analysed national environmental legislation across Bangladesh, Brazil, China, Egypt, Germany, India, Indonesia, Jordan, Türkiye and the United States of America, focusing on Tiers 1 to 3 of the textile value chain.
- The research was developed to inform the UNEP Textile Initiative, which coordinates sector-wide action towards a sustainable and circular textile value chain, drawing on the FAOLEX database for national legislation.
- A four-phase analytical framework was developed to examine permitting systems: application submission, permit decision, operations including monitoring and enforcement, and renewal or closure and rehabilitation.
- The research was peer reviewed by specialists from India, Kenya, the Netherlands, Bangladesh and the European Commission Joint Research Centre, strengthening the integrity of its findings.
- The study represents the first global desk-based review of national environmental permitting legislation as it applies specifically to garment and textile production activities across multiple regions.
- Scope was limited to national-level legislation; subnational regulation, Tier 4 raw material extraction, and the retail and end-of-life phases of the value chain were excluded from analysis.
WHAT THE LAWS REVEAL: Most countries examined are progressing towards integrated environmental permitting, with the United States of America the sole exception, retaining a single-media approach. Bangladesh, China, Indonesia and Brazil have adopted integrated systems to varying degrees, while Jordan's status could not be confirmed and Egypt's system is likely integrated based on available legislation. Permit validity periods vary substantially across the ten countries—from one year for high-risk operations in Bangladesh and five years in China and Türkiye, to unlimited duration in Germany and Indonesia.
- How legislation defines "significant" environmental impact determines whether a comprehensive impact assessment is required—and, where integrated permitting applies, whether best available techniques must be adopted as permit conditions.
- Activities most commonly classified as high-risk include tanneries and operations involving hazardous chemical use or high water discharge, predominantly at Tiers 2 and 3 of the value chain.
- Small and medium enterprises frequently fall below thresholds that trigger environmental impact assessment, leaving their cumulative pollution output largely unregulated under current national legislation.
- Penalties including daily escalating fines, permit revocation and criminal liability exist across all ten countries, though how frequently these powers are applied to textile operations requires further research.
- In every jurisdiction examined, legislation was silent on both permit renewal and strategic environmental assessment, leaving the cumulative pollution impact of multiple textile operations in any given region unmanaged.
WHO PAYS THE PRICE: Regulatory gaps in national environmental permitting carry measurable consequences for communities, ecosystems and workers across the textile value chain. Where permits are issued without comprehensive impact assessment, operations may discharge chemical pollutants into waterways and soil without binding conditions attached, exposing surrounding populations to contamination that national legislation has repeatedly failed to anticipate or adequately prevent.
- Public participation rights during permitting vary widely—from no legal requirement in some jurisdictions to mandatory consultation in others—with enforcement failures in India and Indonesia prompting communities to seek redress through the courts.
- The European Union requires 300 large textile plants to hold permits based on best available techniques, yet no equivalent enforceable international framework governs textile permitting beyond Europe.
- Women of colour represent approximately 80 per cent of textile workers worldwide, yet permitting laws across all countries examined make no provision for intersectional vulnerability or the gendered dimensions of chemical exposure.
- Voluntary schemes including ZDHC, GOTS and bluesign have attracted significant brand participation but proven insufficient to drive structural change, as compliance relies on reputational risk rather than enforceable obligations.
- Site rehabilitation upon closure of textile operations is addressed in only a limited number of jurisdictions—one of 18 recommendations the report makes to policymakers on strengthening environmental permitting frameworks.
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- HIDDEN COST: When environmental permits are weak or absent, the true price of textile production is paid not by industry but by the communities living closest to it.
- RULES GAP: Across ten nations, the law that should protect people from industrial pollution is either inconsistently applied, poorly enforced, or missing entirely for textile operations.
- PAPER TRAIL: A permit on the wall does not guarantee clean water in the river—the gap between legal compliance and environmental protection defines the crisis this report addresses.
- SILENT LAW: Environmental legislation that ignores the gendered dimensions of industrial pollution is not neutral—it is a policy choice with consequences for millions of women workers.
- VOLUNTARY LIMITS: When industry self-regulation substitutes for binding law, compliance becomes optional—and the communities bearing the environmental burden of textile production have no legal recourse.
- WATER JUSTICE: Contaminated rivers and poisoned farmland have driven communities across Asia and the Pacific to the courts, where human rights arguments are filling the gaps left by environmental law.
- PERMIT REFORM: The path toward a sustainable textile value chain runs through national legislatures—where stronger, gender-responsive, integrated permitting laws must replace the fragmented frameworks currently in place.
- UNEVEN GROUND: Nine of ten countries examined are moving toward integrated environmental permitting—but the pace, depth and enforcement of that transition vary enormously, leaving vast regulatory blind spots across the global industry.
