Global supply chain laws are multiplying (for example, the EU Corporate Sustainability Due Diligence Directive and similar regulations worldwide), placing new due diligence requirements on textile brands and retailers. The Global Organic Textile Standard (GOTS) – a voluntary sustainability standard with 20+ years of experience – proactively supports companies in meeting these legal obligations. GOTS notes that it “has always served in helping companies demonstrate legal compliance”. In fact, GOTS 7.0 already includes expanded due‑diligence criteria to align with modern supply‑chain laws.
In line with this proactive approach, a new GOTS provision (effective 4 Sept 2023) now helps retailers document organic goods even when those goods aren’t GOTS‑labelled. Specifically, starting 4 September 2023 GOTS allows brands and retailers to obtain Transaction Certificates (TCs) for finished GOTS goods, even if the items do not bear GOTS labelling. Certification Bodies are the exclusive issuers of these retail TCs. This means that if a retailer sells finished organic textile products made under GOTS standards, it can request an official GOTS Transaction Certificate for them – provided no GOTS claims are made in marketing or sales. In other words, an unlabeled product may still be documented as GOTS‑compliant via a TC, but it cannot be advertised or sold as “GOTS certified” without the label.
GOTS 7.0 Labelling Rules Still Apply
Importantly, GOTS’s core labelling requirements (Section 2.7.8) remain unchanged. Any textile product marketed or sold as GOTS-certified must bear the official GOTS label. The new TC provision does not override this rule. If a product has no GOTS logo, it simply cannot carry GOTS claims – even though a Transaction Certificate can still be issued for it. In practice, this means: retailers gain traceability documentation via TCs, but the branding rules of GOTS 7.0 stay intact. As the GOTS guidance explains, if no GOTS label is present “there shall be no claims to GOTS”.
What’s Changed vs. What Remains the Same
Changed: Retailers can now request GOTS Transaction Certificates for finished goods produced according to GOTS ecological and social criteria even if those goods are not GOTS-labelledglobal-standard.org. This is a new option for retail sales, created to help document organic sourcing at the point of sale.
Unchanged: Per Section 2.7.8 of GOTS 7.0, any retail product that is advertised or sold as GOTS-certified must still carry the GOTS label. In other words, no GOTS logo means no GOTS claims in promotions or packaging. The new provision only affects documentation (TCs), not marketing claims.
Retroactive Coverage: GOTS also allows these Transaction Certificates for applicable products shipped up to 3 months before the announcement (i.e. dispatched and received prior to 4 Sept 2023). This grace period ensures that qualifying goods already in transit or on shelves can be certified retroactively under the updated rules.
Supporting Traceability and Compliance
Transaction Certificates are a cornerstone of GOTS traceability. By their nature, TCs “provide a record of all the transactions… including information about the type and quantity of the product, the name and address of the buyer and seller and the date of the transaction”. In short, each TC creates a transparent trail of the product’s journey through the value chain, verifying its organic status at every handoff. This traceability is exactly what regulators demand: GOTS notes that traceability is often required by regulatory bodies, especially under new supply‑chain laws. For example, the EU’s Corporate Sustainability Due Diligence Directive will oblige companies to fully trace and disclose sustainable sourcing throughout their supply chain.
By leveraging the new TC provision, retailers strengthen their organic textile compliance and responsible sourcing. Even when products lack visible GOTS labels, obtaining TCs ensures there is verifiable proof that they meet GOTS ecological and social standards. This formal documentation helps demonstrate supply chain law compliance for retailers (by tying finished goods back to certified inputs) and upholds accountability. In essence, the update empowers retailers and brands with an additional due-diligence tool: they can align with legal requirements and consumer expectations for transparency, while avoiding any unauthorised GOTS claims on unlabeled products.
Take Action for Proactive Compliance
Organic textile producers, brands, and retailers should take immediate note of this update. Review your procurement and marketing processes to see where the new TC option can apply. Work with your GOTS Certification Body to request Transaction Certificates for any finished goods that meet GOTS criteria but are sold without a GOTS label. Doing so will bolster your traceability records and help ensure you’re prepared for evolving sustainability regulations.