"Made In" Doesn't Really Tell You Where Your Clothes Were Made

Pick up a garment — any garment — and look at the label. You'll find a country of origin. Bangladesh, Portugal, India, Turkey. It feels like information. It's meant to feel like information.

But in both EU and UK law, "Made In" refers to where the last substantial transformation of the product took place [1]. For garments, that means the country where the fabric was cut and sewn — not where the yarn was spun, the fabric woven, or the fibre grown. The label tells you where the needle went in. Nothing about where the fabric came from, who spun the yarn, or what happened at every stage before that.

A t-shirt labelled "Made In Portugal" could contain cotton grown in India, ginned in Pakistan, spun in China, woven and dyed in different regions of India, and assembled in Portugal. The label would still say Portugal. Every step before the sewing machine is legally invisible.

Only 8% of major fashion brands can disclose their raw material suppliers [2]. The brand knows the garment factory. Rarely anything before it.

Let's follow a cotton t-shirt back to the beginning — stage by stage, and the human and environmental risks that come with each one.


Stage 1: The Cotton Field

Most conventional cotton is grown in India, China, Pakistan, the United States, or Uzbekistan — often by smallholder families selling their harvest to local traders or cooperatives.

Human & health risks

  • Cotton accounts for just 2.4% of cultivated land but uses an estimated 6% of global pesticides and 16% of global insecticides

  • Farmers apply these chemicals often without adequate protective equipment, in high heat — documented risks include skin conditions, respiratory damage, and neurological effects

  • Many smallholders operate in debt cycles with little negotiating power over the price they receive

  • Cotton is listed as produced with child or forced labour in 17 countries, including India, Pakistan, Uzbekistan, and Tajikistan [3]

Environmental risks

  • The water footprint of cotton fabric is approximately 10,000 litres per kilogram — around 2,500 litres for a single 250g t-shirt

  • In water-stressed regions, cotton cultivation has had severe consequences for local ecosystems and communities depending on the same water sources


Stage 2: The Ginning Facility

After harvest, raw cotton goes to a ginning facility to separate the fibre from the seeds and remove plant debris. This step is invisible to virtually everyone outside the raw materials trade.

Human & health risks

  • Ginning is dusty work — cotton dust causes byssinosis, a chronic lung disease known as brown lung disease, particularly prevalent in India, Pakistan, Bangladesh, Nepal, and Sri Lanka where ventilation standards are inconsistently enforced

  • A study across 38 mills found 56% of 2,031 workers had at least one chronic respiratory symptom [4]

  • Ginning workers are among the lowest-paid in the chain, many working seasonally with no employment security between harvests

Environmental risks

  • Ginning generates cotton dust and plant waste

  • Without adequate waste management, this contributes to local air and soil contamination — a largely unmonitored problem in informal and semi-formal operations


Stage 3: The Spinning Mill

Cotton fibre is carded, drawn, and twisted into yarn at a spinning mill — a loud, continuous, physically demanding process.

Human & health risks

  • Noise-induced hearing loss is one of the most underreported issues in textile manufacturing — a study of 264 workers found 79% had measurable hearing impairment

  • Sound levels in textile facilities reach 102–114 dBA — well above the 85 dBA safety threshold — with a pooled hearing loss prevalence of 49% across the industrial sector [5]

  • Research across mills in Tamil Nadu documented 12-hour shifts, forced overtime, and indicators of bonded labour linked to international brands [6]

Environmental risks

  • Spinning mills are energy-intensive

  • Yarn preparation involves chemical treatments, some of which are hazardous

  • Wastewater management is not universally in place


Stage 4: The Fabric Mill

Yarn is woven or knitted into fabric — what the trade calls grey fabric, or greige. This is the raw, undyed textile a brand will eventually specify in a tech pack. It is the step most brands know least about, and the point where the supply chain becomes most opaque. Fabric is commodity-traded, passing through agents and intermediaries before reaching a garment factory. Each handoff loses traceability.

Human & health risks

  • Workers face ergonomic strain from repetitive motions

  • Significant noise exposure from mechanical looms

  • Chemical exposure from agents applied during yarn processing — some of which are hazardous and not uniformly managed

Environmental risks

  • Weaving and knitting are energy-intensive

  • Chemical agents used during processing require proper wastewater treatment before discharge

  • Where that infrastructure is not in place, these compounds enter local waterways


Stage 5: The Dyeing and Finishing House

Grey fabric is dyed, softened, and treated here. It is one of the most environmentally damaging stages in the chain.

Dyeing uses synthetic dyes, fixatives, softeners, optical brighteners, flame retardants, anti-crease finishes. Regulation in consumer markets covers residue levels in the finished product — not what happens at source.

Human & health risks

  • Workers face direct chemical exposure daily: skin contact with dyes and fixatives, inhalation of fumes, and heat stress

  • Some chemical residues also remain in finished garments, with potential health implications for the end consumer

  • Communities near dyeing clusters have reported elevated rates of skin conditions, gastrointestinal illness, and respiratory problems

Environmental risks

  • Textile dyeing generates large volumes of chemically contaminated wastewater

  • Where treatment infrastructure is inadequate, heavy metals and other compounds accumulate in local waterways and agricultural land, with documented health consequences for communities living downstream


Final Stage: The Garment Factory

On 24 April 2013, the Rana Plaza building in Dhaka collapsed. 1,134 workers were killed — most of them young women, making clothes for brands sold in Europe and North America. Structural cracks had been reported the day before. Workers were ordered back inside.

It was the event that forced garment worker conditions into mainstream conversation — and triggered a wave of investigations, supplier codes of conduct, third-party audits, and transparency commitments across the industry.

More than a decade on, safety violations persist [7]. The most scrutinised stage in the supply chain still has unresolved problems.

And it is one stop in a chain of at least five. Every stage before the garment factory — the spinning mill, the fabric mill, the dyeing house — has far less scrutiny, far fewer protections, and workers whose conditions are shaped in part by decisions made by brands who will never know their names.


Why this matters now

When something goes wrong — a factory fire, a contaminated river, a child labour investigation — brands tend to respond the same way: the work was subcontracted, they only deal with approved suppliers, they can't be responsible for what contractors do upstream.

This is often structurally true. Brands contract to a garment factory. That factory sources fabric from a mill or a trader. The mill buys yarn from a spinner. Contractual relationships run one tier up. The brand's reach ends at the factory gate.

But brands are not passive actors in this chain. The prices they pay, the lead times they demand, the volumes they place — all of this flows upstream and shapes the conditions under which people work and materials are produced. Reputational risk, as several brands have discovered, does not stop at the factory gate either.

That is starting to change on the legal side. The EU's Ecodesign for Sustainable Products Regulation, adopted in 2024, will make Digital Product Passports mandatory for textiles, with requirements phasing in from approximately 2028 [8]. Brands will need to know not just their Tier 1 supplier, but where their fabric came from, who processed it, and under what conditions. Most aren't ready — not because they don't care, but because the infrastructure to answer those questions doesn't yet exist in their supply chains.

That is the gap t.issu & co exists to help close: connecting mid-size UK and European fashion brands with pre-qualified mills, cooperatives, and producers in India — with traceability and compliance documentation built in from the start.


What you can do

    • Ask brands where their fabric comes from — not just the factory, but the mill, the yarn, the fibre. If they can't answer, that's worth knowing.

    • Check the Fashion Revolution Transparency Index [2] — it ranks major brands on supply chain disclosure. Takes a few seconds.

    • GOTS, OCS, and RWS certifications are a useful starting point for identifying traceable natural fibres, though they don't cover every risk in the chain.

    • Supply chain visibility is fast becoming a legal requirement. Digital Product Passports will require Tier 2+ traceability by approximately 2028 — the garment factory is no longer where the audit trail ends.

    • Most brands know their garment factory. Fewer know where the fabric was woven, dyed, or spun. That's the gap to close.

    • Traceability documentation and export readiness are increasingly what mid-size European brands need from supply chain partners.

    • Being able to demonstrate fibre origin, processing conditions, and certification status is increasingly what European buyers are asking for.

Behind every fabric, there are people. And keeping them visible is key.



t.issu & co works with mid-size European and UK fashion brands to connect them with pre-qualified natural fibre suppliers in India, with sourcing support, traceability documentation, and compliance readiness built in from the start. If you're navigating sourcing complexity or preparing for incoming EU requirements, get in touch.

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EU Green Claims Rules: What Fashion Brands Actually Need to Know Before September 2026