Fashion for the Earth

Certifying Cotton from the Cerrado

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 2nd 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.