United States
Texas Announces Lululemon Chemical-Compliance Agreement
Texas’s Lululemon agreement addresses supplier chemical-compliance evidence. The state says its document review did not identify PFAS in products or materials.
Foresight
2 min readAI-drafted, expert reviewed
The Texas Attorney General announced a chemical-compliance agreement with Lululemon on 22 October 2026. The company-specific Assurance of Voluntary Compliance addresses evidence that suppliers meet Lululemon’s Restricted Substances List, or RSL. It is not a generally applicable restriction on activewear. Announcement; agreement.
Supplier Reports And Certificates
The agreement says Lululemon will continue to require vendors to provide testing reports from a nominated laboratory or valid third-party certifications accepted under its RSL. Compliance is assessed through verification of submissions and commercially reasonable corrective action, rather than perfect compliance by every supplier at all times. Paragraph 29.
If a vendor certificate expires or is not renewed, its materials must undergo laboratory compliance testing under the RSL. Vendors must notify Lululemon or its laboratory of expired certificates, and the designated laboratory must confirm certificate validity when certification substitutes for PFAS-related RSL testing. Paragraphs 30–32.
What The Investigation Established
Texas issued a civil investigative demand on 26 March 2026. The agreement records an allegation about missing signed acknowledgements from two vendors for one RSL edition, and says those acknowledgements have since been signed. Paragraphs 24–27.
It expressly states that the state’s document review did not identify PFAS in Lululemon products or materials. Lululemon makes no admission of a legal violation and denies liability. Paragraphs 17 and 28.
Duration And Enforcement Terms
The agreement takes effect when signed by the court and terminates three years after entry. The published document does not establish that court-signature date. It gives Lululemon 60 days after notice to cure alleged non-compliance or demonstrate compliance. An isolated vendor failure is not automatically a breach where the agreement’s knowledge, corrective-action and enforcement conditions are met. Paragraphs 34, 37–38 and 49.
Topics
Questions about this change
Did Texas find PFAS in Lululemon products in the investigation covered by the 2026 agreement?
The agreement states that Texas did not identify PFAS in Lululemon products or materials after reviewing the documents provided. It is not an admission of wrongdoing by Lululemon and should not be described as a finding of PFAS contamination.
What supplier evidence does the Texas–Lululemon chemical-compliance agreement require?
It requires continued vendor evidence of Restricted Substances List compliance through nominated-laboratory reports or accepted valid certifications. Expired or unrenewed certificates trigger laboratory testing under the RSL, and the agreement requires verification and commercially reasonable corrective action.
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