In 2024 sweeping legislation aimed at regulating fashion was passed in the European Parliament. It included the landmark Corporate Sustainability Due Diligence Directive (CSDDD), with the important requirement that brands trace their supply chains all the way back to their raw material sources. But on February 26, 2025 under pressure from some member states, the United States and businesses a new “Omnibus Proposal” was introduced that would curtail the CSDDD. If passed, brands will only need to identify their direct customers, meaning their Tier 1 cut and sew factories.

There is no better illustration, however, of why the CSDDD was passed in the first place than the current controversy over Brazilian cotton and the certification scheme known as “Better Cotton”.  It is precisely the need to know whether a fashion brand’s upstream supply chain – where almost all the environmental damage occurs – is contributing to the environmental or social destruction.

Fashion regulations are new. Until very recently, brands have never been required by law to perform due diligence when it comes to their supply chains – the factories that process their materials or the source of their raw materials. Brands have opted, in order to make sustainability claims, signed onto certification schemes that they hope will do the job for them. One such certification scheme is Better Cotton (BC). 

Founded to create a more sustainable cotton industry, Better Cotton claims to train cotton farmers in responsible practices like reducing pesticide use, reducing water use, promoting ethical labor conditions, and producing healthier yields for farmers. Unlike organic cotton, which adheres to strict guidelines and avoids synthetic chemicals, Better Cotton allows the use of genetically modified seeds and synthetic pesticides—raising questions about just how “better” it really is. The program has gained widespread industry support, with major retailers relying on its certification to market “sustainable” collections to conscious consumers.  

The BC platform works with registered companies that include ginners, yarn producers, garment manufacturers and retailers. It certifies farms and tracks large volumes of cotton from its country of origin as it moves through a supply chain. Each farm gets a code to identify their source, but hundreds of small farmers can be lumped into 1 code making it impossible to trace cotton to the farms beyond the ginners who collect it.  At the ginning stage, Better Cotton theoretically can be mixed with cotton from conventional farms and so the scheme has a verification problem.

Cotton Farming in the Cerrado

In recent years, efforts to protect the Amazon have displaced agriculture to Brazil’s Cerrado, a vital ecological region in the eastern part of the country. The Cerrado, a vast area stretching 1.2 million square miles, is a tropical area of grasslands, forests, and savannas. It is a major carbon sink and water basin. It is the world’s most biodiverse savannas – home to 5% of the world’s species, including unique wildlife like the maned wolf, jaguar, giant anteater, and giant armadillo. However, the region is under immense strain from industrial agriculture, including cotton production linked to Better Cotton’s certification program. 

Nearly half of the Cerrado’s native vegetation has already been lost, and clearing the land for agriculture risks the extinction of over one-fifth of the region’s wildlife, and generates 230 million metric tons of carbon per year—equivalent to the annual emissions of 50 million cars. 

The Cerrado is called “the underground forest because so much of the biomass is found in long thick roots that funnel water down to aquifers and store impressive amounts of carbon”, according to a Grist investigation into investments in agribusinesses that produce soy in the Cerrado. Cotton is grown half the year in rotation with soy.

According to the report, indigenous groups can lay claim to land in the Cerrado but lack deeds, and land-grabbing by large agribusiness companies is common. Businesses seeking to claim land will hire armed men to intimidate the residents or run them off. The land is cleared of trees and vegetation and seeded for crops. Eventually, they gain formal ownership through legal maneuvers. Much of the biome’s last remaining tracks of native Cerrado vegetation are in Matopiba, a region that includes the state of Bahia, the country’s last agricultural frontier.

In recent years, Brazil’s domestic cotton has expanded enormously – so much so, that the country now competes with the United States as the largest exporter of cotton in the world. Bahia State is the 2^nd largest cotton producer in Brazil.  Farmers have been spurred on due to the higher returns on cotton than other crops. In fact, in 2023/24, Brazil’s cotton exports surpassed that of the U.S. making it the largest global exporter in that year.

According to Better Cotton, in the 2023/2024 cotton season, the 440 farms that they certify produced more than three million metric tons of cotton and represent more than 83% of Brazil’s total cotton production.

But in that same year, according IBAMA, the federal agency under the Ministry of the Environment charged with oversight, monitoring and controlling natural resources in Bahia, there was a 43.7% increase in this area under alert for deforestation compared to the previous year and the infraction notices issued by IBAMA for crimes against flora in the biome increased by 45% compared to the average for the same period in the previous four years.   

Agribusinesses in Brazil

Large agribusinesses in the Cerrado have been responsible for deforestation and crimes against local populations.  SLC Agricola and the Horita Group are the two largest agribusinesses in the region of Bahia. Both SLC Agricola and the Horita Group have repeatedly faced accusations of illegal deforestation, land grabbing and corruption scandals. 

Now a new report from the NGO Earthsight, Fashion Crimes, has revealed that the cotton production grown on farms that are part of large estates owned by these agribusiness has been certified by Better Cotton.

Earthsight’s report traced the raw cotton from SLC and Horita to eight clothing manufacturers in Asia that supply garments of finished cotton goods to numerous well known Western retailers including millions of items to H&M and Zara.

Better Cotton responded to the exposé by launching an audit of their own that showed only three farms in the area were actually certified by Better Cotton and stressed that they only assess farming practices and not how the land was acquired, or the companies that own or operate them. It admitted, however, that it “knew SLC Agrícola and Horita’s farms had been fined for environmental infractions before it certified them”.  Earthlight countered that the 3 farms audited by BC excluded those where they found wrongdoing, and that none were in the area where the major case studies in their report took place with the worst violations.

In 2023, Better Cotton’s 2030 Strategy “Better Cotton Traceability” states that BC can trace their cotton back to the “country of origin”, but has “ambitions to trace back to farms” in the future.

What is the Answer?

Legislation being passed in the E.U, the U.S. and other countries around the world is the only way to effectively address the fashion industry’s social and environmental harms.  

The most important regulations require transparency and accountability. The EU Deforestation Regulation (EUDR) passed in 2023 could be the most effective legislation to directly address the destruction of places such as the Cerrado. It covers commodities like cattle, cocoa, coffee, oil palm, rubber soy and wood and their derived products. It demands products be deforestation-free, and companies carry out due diligence in order verify the origin and production methods of the materials used in their products – an important shift in the burden of proof, particularly given the vast grey areas surrounding legality in certain places, including Bahia.

Unfortunately…the EUDR does not currently cover cotton in its scope. Adding cotton would mean brands would have to trace their cotton to farms, and without due diligence, face fines that could amount to 4% of a company’s annual EU turnover. The other shortcoming is that the EUDR covers “forests” and the Cerrado is a “savannah”, but there are calls to include “other wooded land”. 

What we can do

Consumers can educate themselves with credible, fact-based sources. The Transformers Foundation, for example, provides an insightful case study on cotton production, offering a deeper look into the complexities of the industry. By staying informed and questioning corporate narratives, consumers can push for real transparency and hold brands accountable for their promises.  

Secondly, Fashion for the Earth has published a Fashion Legislation Report. It brings together all of the recent regulations around the world aimed at the industry. Consumers can write to their lawmakers to demand that those laws that have been proposed, but not yet passed, be adopted. 

Earthsight’s report, Fashion Crimes, has highlighted the need for brands to conduct “rigorous supply chain due diligence”, for policymakers to ensure that their laws are vigorously enforced, and that we, the consumer, continue to educate ourselves and be vigilant.

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As the climate crisis accelerates, fashion continues to focus on mitigation – cutting emissions, reducing water use, and sourcing sustainable materials. But there’s another side to climate action that remains dangerously overlooked: adaptation, particularly for the garment workers who power the fashion industry. Despite growing sustainability efforts, the fashion industry continues to ignore how climate change endangers the workers and communities behind global garment production. 

While the world warms and extreme weather events escalate, the apparel workers in Bangladesh, Cambodia, Pakistan, and Vietnam, backbones of global garment production, bear the brunt. In these tropical and subtropical production zones, climate change manifests not only as rising sea levels, but in heat-stricken factory floors and flooded neighborhoods. 

Flood events in worker neighborhoods that have relatively poor infrastructure are chronic irritants for workers in South Asia. They lead to delays in getting to work and the loss of income. Face-to-face surveys conducted in Dhaka by the BRAC University Center for Entrepreneurship Development (CED), found that apparel workers miss an average of three full days of work due to flooding and heat illness.  

Flood events last for several months in South and Southeastern Asia, as water rises to the point where some Dhaka area factories must send boats to collect workers. The floods lead to illnesses like rashes and diarrhea, raising medical costs while production and income is lost. This can amount to 10% of garment workers total income during periods when living costs, such as electricity and medicine, surge due to heat-related impacts.

An example unfolds in ready-made garment (RMG) factories in Bangladesh, where a study published by BMC Public health found that more than half RMG workers surveyed from 10 randomly selected sweatshops had faced damage from natural disasters related to climate change. Workers were affected by flooding (79.9%), drought (52.2%), river erosion (49.5%), earthquakes (45.1%), storm surges (39.7%), and landslides (13%).  Nearly half of those interviewed were forced to migrate, increasing job competition within factories in urban areas, further lowering wages as a result.  

Respondents also identified climate change as a primary contributor to illnesses. About 59% mentioned no air conditioning or extra cooling protocols to resolve increased heat, and 78% were affected with illness as a result. Despite this, none of the factories gave any risk allowance for illness as a result of climate change.

The Price of Climate Change… 

Cornell’s School of Industrial and Labour Relations (ILO), projects exorbitant economic losses if adaptation is not agreed upon. Without adaptation, high heat and humidity will create a loss of 4.9% of Bangladesh’s 2030 projected GDP, with similar impacts for Cambodia (-6.5%), Pakistan (-5.1%), and Vietnam (-4.9%). Fashion’s earnings are expected to fall 22% (65.6 billion USD) by 2030 and 68.7% by 2050 (1,424 billion USD) without adaptation. 

A research study by Harvard shows that damage by climate change impacts hot, low-income countries most, as a one-degree Celsius rise in temperature reduces economic growth by 1.3 percentage points, a notable decrease and an effect that will not be seen in developed nations.  

Globally, some workers can earn extremely low wages. In one documented case a supplier paid as little as $1.58 per hour. In Bangladesh workers are paid an average of $113 per month for full-time work, making every hour of work vital. In 2022, it was estimated that potentially 490 billion hours of labour were lost due to heat.   

These losses in GDP and available working hours will be almost completely felt by those in developing countries.  

Sink or Swim 

Adaptation is crucial to protecting garment workers ᠆᠆ so how do we?  

One solution is encouraging social dialogue between leadership and workers. When factories operate with unsafe equipment or when extreme heat makes labour dangerous, the demands for change must come from those affected: the workers themselves. However, supply chain factories must prioritize social dialogue to encourage safe and healthy workplaces. During the COVID-19 pandemic, social dialogue was the only mechanism workers had to protect themselves, proving its effectiveness in crisis. But the protections provided during emergencies should not be exceptional, rather set a standard. Importantly, both governments and fashion companies must institutionalize these practices as part of their daily operations.  

Investment in green energy can transform factories into sustainable and climate resistant workplaces. Beyond reducing Greenhouse Gas emissions, renewable energy can efficiently power cooling systems, lowering indoor air temperatures by 3-4 degrees Celsius.  

But the primary, and most effective and immediate form of climate adaptation in developing nations is raising wages. Without adequate income, workers cannot meet basic standards for health and safety. When wages are among the lowest globally, people are extra susceptible to malnutrition, poor healthcare, and a diminished living standard. A study published by the National Library of Medicine found that among female garment workers in Bangladesh, 43.33% were underweight, and 96% of those had health issues. Over half the participants reported multiple health complications, even before factoring climate stressors. This situation will only worsen as temperatures rise.  

In Dhaka, workers have told the Executive Director of the Global Labor Institute at Cornell,  Jason Judd, that they often resort to selling or pawning household goods to pay electricity bills. During climate-intensive periods, medicine prices reportedly rise as much as 10 times, putting healthcare further out of reach. Paying a living wage means compensating workers adequate for a standard workweek so they can afford a decent standard of living ᠆᠆  essentials like food, water, housing, and education. Yet despite this, only 2% of garment workers make a living wage.  

Raising wages is often argued to threaten industry competitiveness, but in Cambodia a decade ago, wage increases were implemented which grew orders, revenue, and jobs.  

Raising wages would reshape the fashion industry with positive benefits. Heightened wages slows production by disrupting the low-wage system that enables fast fashion. This pressure leads to more sustainable practices across supply chains. According to The Business of Less, increasing workers’ pay by just $100 could reduce global CO2 emissions by 65.3 million metric tons ᠆᠆ because higher wages raise production costs, in turn moderating consumption.  

A living wage would enable climate adaptation among workers by allowing them to afford and invest in essential resources, such as sanitation, food, clean water, and basic needs ᠆᠆ foundational elements that build resilience to climate change.  

No Relief on the Factory Floor   

Cornell’s School of Industrial and Labour Relations (ILO) also monitors legislation. Currently, international regulations on heat stress for workers are limited to two non-binding recommendations – The Hygiene Recommendation (No. 120, 1964) and Protection of Workers Health Recommendation (No. 97, 1952). These recommendations urge governments to set standards and enact laws protecting workers from extreme heat, inadequate ventilation, and lack of water access. However, implementation has been minimal, with only Vietnam as the notable exception.  

A survey of national legal frameworks in Bangladesh, Cambodia, Pakistan, and Vietnam reveals the disparities within each country. While Vietnam has stringent laws on climate adaptation for labour, such as paid sick leave, heat thresholds, and pay during force majeure work stoppages, the other countries have few or no legal provisions addressing climate-labour disruptions.  

Cambodia, in particular, remains virtually silent on climate-related labour protections. There are no requirements for paid breaks, pay during work stoppages, or rights to stop working in dangerous conditions.  Furthermore, none of the countries, besides Vietnam, have indoor heat standards and extreme heat protocols. Even basic protections, such as access to drinking water, fall below acceptable thresholds across all four national legal frameworks.  

S.O.S   

For these workers, climate change isn’t conceptual or invisible, rather a daily struggle for health, stability, and survival. As heat rises ᠆᠆ long-term health risks and a loss of income do too.

It is already apparent that several major apparel production hubs that are responsible for a significant share of current output are unlikely to escape the accelerating impacts of the climate crisis. While about one million jobs and $65 billion in export earnings are expected to be lost by 2030, only 3% of big brands disclose efforts to support workers affected by climate change. 

Adaptation among all nations is critical to global development, determining industries where every human has a decent standard of living. As climate change threatens the lives of millions ᠆᠆ collective, equitable action is not just necessary, it’s urgent. 

Photo credit: Liuser

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