Eighty-two percent. That is the share of large clothing brands publishing some form of supplier list in 2025, according to the Fashion Transparency Index produced by Fashion Revolution. A decade ago, the figure was below 20 percent. The number is also misleading, because most published lists end at the cut-and-sew factory and conceal everything that happens upstream: dyeing, weaving, spinning, ginning and the cotton field itself. Transparency, in fashion, has become a coverage map with most of the territory still in white.
This piece walks through how the modern transparency report is structured, what its standard categories actually measure, where the gaps live, and how to read a brand’s disclosure document with the same scepticism you would apply to a corporate sustainability press release. Most of the examples below are drawn from publicly available 2024 and 2025 reports, which I read in full for this piece.
The four tiers most brands disclose (and the ones they do not)
Industry standard divides the supply chain into tiers, but most non-specialist readers do not realise where their favourite brand actually stops disclosing. Tier 1 is the cut-and-make factory where finished garments are sewn. Tier 2 is the mill that produces the fabric. Tier 3 is the spinner, dyer or yarn maker. Tier 4 is raw material — cotton, flax, wool or oil for synthetics — at the farm or extraction site.
According to the 2024 Fashion Transparency Index, while 52 percent of major brands published Tier 1 supplier lists, only 17 percent disclosed Tier 4. Tier 4 is also where most environmental and human-rights risk concentrates. The forced-labour reports linked to cotton in the Xinjiang region of China, for example, all sit at Tier 4. By the time the cotton reaches a Tier 1 sewing factory in Vietnam or Bangladesh, no documentary trail typically remains.
What a good transparency report actually contains
The benchmark documents in the field are produced by a small group of brands that have invested in genuine traceability infrastructure. Patagonia publishes its full supplier list with addresses, worker counts, products made and union status. Nudie Jeans publishes Tier 1 and Tier 2 mills with cotton sourcing percentages by country. Eileen Fisher traces wool back to specific Argentine and Patagonian ranches. The most ambitious example to date is the Spanish brand Ecoalf, which publishes documentation back to specific Mediterranean fishing fleets that recover plastic for its recycled-PET fabric.
A useful report contains, at minimum:
- A facility list with name, full address and a measurable identifier (often a building number or coordinates)
- Worker headcount and gender breakdown per facility
- Whether trade-union activity is recognised or banned
- Audit findings (not just audit dates) and corrective action progress
- Average wages versus regional living wage benchmarks
- Percentage of materials by fibre, including recycled and organic shares
- Greenhouse gas, water and energy data, ideally by Scope 1, 2 and 3
Why audit data is often unreliable
Most brand audits are carried out by third-party social compliance firms — Bureau Veritas, SGS, Intertek — typically once a year, with announced visits. A 2019 academic study published in the Journal of Business Ethics reviewed more than 40,000 such audits across South and Southeast Asia and found systematic underreporting of overtime hours, child labour and wage violations. The 2013 Rana Plaza collapse in Bangladesh, which killed more than 1,100 garment workers, occurred in a building that had passed multiple audits in the previous two years.
The most credible alternatives are worker-driven monitoring agreements such as the International Accord for Health and Safety in the Textile and Garment Industry, which evolved out of post-Rana Plaza accords and now covers more than two million workers across Bangladesh and Pakistan. Brands that have signed and publish their compliance status (H&M, Inditex, Bestseller, among others) have measurably better workplace safety outcomes than those that have not.
Reading a real example: how to dissect a brand’s report
Take a hypothetical mid-size brand publishing its annual sustainability document. Open the supplier list and check four things in order:
- Does the list include addresses, or just country names? Country-only listings are functionally meaningless.
- How many tiers are covered? Tier 1 only is a starting point, not a destination.
- Is wage data included or only “wages comply with local minimum”? Local minimums in much of South Asia are roughly 30 to 50 percent of a living wage, as calculated by the Anker Methodology.
- Does the report distinguish targets from achievements? “We aim to source 100 percent recycled polyester by 2030” is a target. “We sourced 47 percent recycled polyester in 2024” is an achievement.
The role of digital traceability
Several technical infrastructures now compete to map textile flows at scale. TextileGenesis, used by Lenzing, H&M and Zalando, issues digital tokens at the fibre stage that follow the material through every transaction until it reaches a finished garment. FibreTrace embeds physical luminescent particles into raw fibre that can be scanned at any subsequent point in the chain. The EU Digital Product Passport, which becomes mandatory for many textile categories starting in 2027 under the Ecodesign for Sustainable Products Regulation, will require a QR code on every garment linking to its full material and impact data.
None of these tools solve the human-rights gap by themselves; a forced-labour cotton ginning mill can still issue a clean digital token if the brand or auditor does not catch it. They do, however, raise the cost of falsification, which is meaningful.
Living wages: where transparency reports get vague
Living wage data is the most consistent omission across the industry. The Global Living Wage Coalition publishes country and region-specific living wage benchmarks. A factory paying the legal minimum in Dhaka in 2025 was paying approximately 45 percent of the Anker living wage benchmark for the city. Brands that disclose this gap directly — Nudie Jeans, Stanley/Stella, Veja — are still rare. Most reports use phrases such as “all suppliers comply with applicable minimum wage laws”, which says everything and nothing.
Government regulation finally catching up
Until 2023, transparency was almost entirely voluntary. The picture is now changing.
- EU Corporate Sustainability Due Diligence Directive: phased in from 2024, requires large companies to identify and address human-rights and environmental risks across their full supply chains.
- German Supply Chain Due Diligence Act (Lieferkettengesetz): in force since 2023, with fines up to 2 percent of global turnover.
- French Loi de Vigilance: in force since 2017, requires multinationals to publish vigilance plans.
- US Uyghur Forced Labor Prevention Act: in force since 2022, presumes any goods linked to Xinjiang were produced with forced labour unless proven otherwise.
These laws are starting to pull data into the public sphere that voluntary reporting alone never produced. Early enforcement actions against German retailers in 2024 and French food multinationals have already resulted in published remediation plans.
Frequently asked questions
Is a long supplier list automatically a sign of an ethical brand?
No. A long Tier 1 list with no Tier 2-4 disclosure, no audit findings and no wage data is publicity. Pair the supplier list with the wage and worker-rights sections before judging.
Are small brands more transparent than large ones?
Often, but not always. Smaller brands frequently know their factories personally and can disclose more, but they may also lack the resources to produce a formal report. Large brands have the budget for proper reporting but more incentive to hide complexity.
Does a B Corp certification guarantee supply-chain transparency?
It does not. B Corp certification covers governance, environmental management and worker welfare at the corporate level, but its supply-chain criteria are softer than Fair Wear Foundation membership or full Fashion Transparency Index disclosure.
Comparative analysis: how three brand reports stack up
To understand the difference between robust and weak transparency reports, it is worth comparing three real documents from the 2024 to 2025 cycle. Patagonia’s 2024 Environmental and Social Initiatives report runs 116 pages and includes specific factory addresses for every Tier 1 and Tier 2 facility, plus a separate Footprint Chronicles dataset that lists individual mills and farms. H&M Group’s 2024 Sustainability Disclosure runs 95 pages and lists Tier 1 facilities by name and country but only summarises Tier 2 by region; its scope-3 emissions figures are presented as ranges rather than verified totals. A typical fast-fashion competitor in the same year published a 24-page report listing five “core values” and one supplier-country pie chart with no addresses or audit findings.
The numbers behind these documents matter. Patagonia’s report identifies 27 Tier 1 factories across 12 countries with worker counts ranging from 88 to 4,400. H&M Group lists more than 600 Tier 1 facilities, mostly clustered in China, Bangladesh, Turkey and Vietnam, and acknowledges 39 social-compliance non-conformities resolved during the year. The fast-fashion comparator publishes none of this, which means external observers have no factual basis to compare it to either competitor.
Implementation steps for sceptical readers
For a reader who wants to apply the framework above to their own purchasing, the practical workflow is simpler than it sounds. The total time investment per brand is roughly 15 to 25 minutes, which compares favourably to most other research a household does before a meaningful purchase.
- Step one: locate the report. Search “[brand name] sustainability report” or “[brand name] supplier list.” If neither returns a current PDF or web page, that is itself the answer.
- Step two: count the tiers. Open the supplier list. Tier 1 only is a baseline. Tier 1 plus Tier 2 is meaningful. Tier 1 through Tier 4 is genuinely rare.
- Step three: scan for wage data. Search the document for “living wage” or “wage gap.” Note whether the brand discloses the gap or only references “minimum wage compliance.”
- Step four: cross-check the Fashion Transparency Index. The Index publishes its raw scoring spreadsheet alongside the headline report, which lets you verify how independent assessors rated the brand on the same criteria.
- Step five: check enforcement records. Search the German BAFA enforcement database (which publishes Lieferkettengesetz cases) and the EU’s emerging Corporate Sustainability Reporting registry for any active cases against the brand.
Misconceptions worth flagging
Three persistent misconceptions distort how transparency reports are read. The first is that “made in Italy” or “made in Portugal” labels imply ethical production. They do not. EU labour protections cover formal employment, but textile production across Italy and Portugal also relies on extensive subcontracting networks, including documented cases of Chinese-owned factories in Prato that have prompted regular Italian labour inspections since the early 2010s.
The second is that synthetic fibres are inherently more traceable than natural fibres because they are produced industrially. The opposite is closer to the truth. Polyester production is concentrated in a small number of petrochemical plants in China, India and Taiwan, and most of the recycled-PET stream comes from bottle waste with limited chain-of-custody documentation. Cotton at least has Better Cotton Initiative, organic certification and several digital traceability programmes; polyester has the Recycled Claim Standard but not yet a robust farm-to-garment equivalent.
The third is that “small brand” automatically means “ethical.” Many small brands buy white-label garments from the same factories as larger brands and add a screen-printed logo. The relevant question is not the size of the brand but whether the brand can describe its supply chain in specific, falsifiable terms.
The brands that have moved fastest
Several brands deserve specific attention for the speed and depth of their transparency improvements over the past decade. Patagonia’s Footprint Chronicles, launched in 2007 and substantially expanded since, remains the reference standard for brand-level transparency. The platform tracks individual products through their full supply chain with photographs and worker interviews, supplemented by annual environmental and social initiatives reports running over 100 pages.
The Swedish brand Nudie Jeans has made transparency a core part of its brand identity, with publicly available supplier information including individual factory addresses, worker counts, audit findings and ongoing improvement programmes. The 2024 Nudie Jeans transparency report includes specific information about every Tier 1 and Tier 2 supplier, with most Tier 3 suppliers also disclosed.
The American brand Eileen Fisher’s Renew programme combines supply chain transparency with end-of-life garment recovery, creating a closed-loop system that addresses both production and disposal. The brand has resold or repurposed more than two million garments since the programme’s 2009 founding, with detailed reporting on the materials and labour involved.
The Dutch brand Asket publishes per-garment cost and impact breakdowns including CO2e emissions, water use, energy consumption and labour content, providing some of the most granular consumer-facing transparency in the industry. The brand’s 2024 disclosure included individual supplier identification for 100 percent of its products, with audit findings and improvement plans for any non-conformities.
The role of investigative journalism
Outside the corporate transparency reporting infrastructure, investigative journalism has produced some of the most consequential disclosures of supply chain conditions in recent years. The 2013 Rana Plaza coverage by Bangladeshi journalists at the Daily Star and Prothom Alo, supplemented by international reporting from outlets including the New York Times and the Guardian, produced the political pressure that eventually resulted in the International Accord. The 2017 reporting on Xinjiang cotton by Vicky Xiuzhong Xu at the Australian Strategic Policy Institute and subsequent BBC reporting transformed how the cotton supply chain was understood and regulated.
More recent investigations have continued to surface conditions that voluntary corporate reporting did not disclose. The 2022 Reuters investigation into Italian leather supply chains documented working conditions in the Indian tanneries that supply European luxury brands. The 2023 Wall Street Journal investigation into the Pakistani cotton supply chain documented child labour conditions that several major brands had previously claimed to have addressed.
For consumers wanting to follow supply chain reporting, several specific journalism outlets have developed sustained expertise. Sourcing Journal covers textile supply chains specifically; Business of Fashion’s sustainability section publishes regular investigative work; the BBC, Reuters and the Wall Street Journal maintain dedicated supply chain reporting capacity. Following these outlets across multiple years builds a more accurate picture of supply chain conditions than corporate reporting alone provides.
The future of supply chain transparency
The trajectory of supply chain transparency over the next decade depends substantially on regulatory implementation and consumer pressure. The EU Corporate Sustainability Due Diligence Directive, phased in from 2024 through 2028, will require detailed reporting from large companies that goes substantially beyond current voluntary practice. The German Lieferkettengesetz has already produced enforcement actions, with several million-euro fines issued to non-compliant retailers in 2024.
Technology developments are expanding what is verifiable. Blockchain-based traceability systems including TextileGenesis and Provenance now provide cryptographically verifiable chain-of-custody records that earlier systems could not match. The Digital Product Passport infrastructure being developed for the EU textile market will provide consumer-facing access to supply chain data through QR codes on garments. The 2025 Estonian government pilot of full Digital Product Passport implementation provides one of the first working examples of how the system functions in practice.
For consumers, the practical implication is that supply chain transparency is genuinely improving but remains incomplete. The brands at the forefront of disclosure (Patagonia, Asket, Eileen Fisher, Nudie Jeans, several others) are setting standards that will gradually become more widespread through regulatory and competitive pressure. The brands that have not engaged with disclosure are increasingly visible as outliers, which creates its own market pressure for change.
Where to dig further
Read the most recent Fashion Revolution Transparency Index in full, then read your favourite brand’s annual report alongside it. Cross-check supplier lists against the International Labour Organization country profiles. The OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector is the reference document used by most regulators drafting national legislation. Our archive of brand-level reviews lives at brand etici, our deeper notes on textile traceability are filed under tessuti & innovazione, and we maintain a parallel thread on workers’ rights in textiles.
This article is for informational purposes and summarises publicly available reports; brand disclosures change frequently, so verify current data on each company’s site before drawing conclusions.
