Luxury Supply Chain ESG: Franco-Italian Framework Sets 46 Shared Requirements

The Fédération de la Haute Couture et de la Mode and the Camera Nazionale della Moda Italiana published a shared ESG harmonisation framework on 13 May 2026, completed in April, the result of a Franco-Italian initiative launched in 2024 and around eighteen months of joint work. It is a voluntary document. It sets out 46 shared requirements across four areas of luxury supply chain ESG, governance, health and safety, human rights and labour conditions, and environmental compliance, which the framework itself terms expectations, and it is preceded by seven essential commitments that apply as a minimum. The European due diligence directive, which governs the same field, applies from 26 July 2029.

Morand and Capasa Cite Administrative Burden on Small Workshops

Pascal Morand, executive president of the FHCM, described the intention in a joint interview with Carlo Capasa.

“The idea was to harmonise the social environmental auditing to decrease the fatigue of the suppliers.”

The joint statement is more specific about who carries that fatigue. The fragmentation of differing approaches, the two institutions wrote, creates an increasing administrative burden for suppliers, in particular small workshops, the guardians of the artisanal expertise underpinning luxury excellence, placing disproportionate pressure on the sector’s most vulnerable structures.

Carlo Capasa, president of the CNMI, set out what the framework leaves untouched.

“It keeps the freedom of each of the brands to operate in its own way, but within the framework.”

The document says the same in its own language. On the basis of the shared principles, each operator is entrusted with the freedom and responsibility to independently shape its due diligence approach across its supply chain. Adoption relieves no supplier of the obligation to comply with applicable law.

The Framework Opens With Seven Essential Commitments

The seven read as follows. The business partner prohibits child labour. The business partner prohibits forced labour. It guarantees that no severe and immediate impact falls on the health and safety of workers. It ensures its practices comply with laws on pollution and the environment. It pays no less than the legal minimum wage and does not falsify records of working hours, which are transparently and reliably recorded. It tolerates no discrimination, violence or harassment, physical or psychological. It conducts its business ethically and upholds the highest transparency in its relationship with the client, including the sharing of complete, accurate, lawful and legitimate information.

A workshop meeting those expectations for a French client has met them for an Italian one.

Gucci Leads the Italian Working Group, Chanel Chairs the FHCM Committee

The composition of the bodies indicates how seriously the two industries treat the subject. On the Italian side, the CNMI sustainability working group is led by Gucci and includes Bottega Veneta, Ermenegildo Zegna, Fendi, Versace, Giorgio Armani, Loro Piana, Max Mara, Moncler, OTB, Prada, Salvatore Ferragamo, Tod’s and Valentino. The narrower sustainability commission consists of Gucci, Versace, Giorgio Armani, Prada and Valentino, with the Health and Textile Association as technical coordinator.

On the French side, the FHCM executive committee is chaired by Bruno Pavlovsky of Chanel and includes Cédric Charbit of Saint Laurent, Elsa Lanzo of Rick Owens, Myriam Serrano of Alaïa, Guillaume de Seynes of Hermès and Sidney Toledano of Givenchy and LVMH. The board of directors adds Delphine Arnault for Christian Dior Couture, Pietro Beccari for Louis Vuitton, Séverine Merle for Celine, Gianfranco Gianangeli for Balenciaga, Sarah Benady for Jacquemus and Laurent Malecaze for Chloé, among others.

These are the houses that carry the greater part of European luxury manufacturing, and their most senior executives sit at the tables where the text was agreed.

The EU Due Diligence Directive Takes Effect in July 2029

The Corporate Sustainability Due Diligence Directive requires large companies to identify and address the harm their operations cause to human rights and the environment, inside their own walls and along the length of their supply chains. It entered into force in July 2024. It was subsequently amended through the Omnibus simplification package, and the amending directive was published in the Official Journal on 26 February 2026 before entering into force on 18 March. Member states have until 26 July 2028 to transpose it into national law, and the rules apply from 26 July 2029.

The revision narrowed the scope to very large companies. Around 160,000 companies work in textiles across the European Union, and 99.5 percent of them are micro-enterprises, which places most of them outside the directive’s direct reach. They meet it through their clients, since a law requiring the largest houses to know what happens along their chains transmits itself downward as a demand for documentation.

That is the situation the framework addresses. It arrives three years before the directive applies, written by the industry rather than for it, and it gives the workshops one form to prepare rather than several.

France Bargains With Five Unions, Italy Signed a Milan Protocol in 2025

France and Italy regulate work in fashion through different traditions, which makes the shared document more notable than a single national initiative would be.

France operates through collective bargaining. The convention for Couture parisienne et autres métiers de la mode and the convention for the clothing industry, the latter signed in 1958, set wages and conditions through annual negotiation between employer organisations, the FHCM among them, and the five representative unions, CFDT, CFE-CGC, CFTC, CGT and FO. Those agreements bind once extended by ministerial order. The process is a genuine negotiation. In 2025 all five unions declined to sign the proposed wage scale and asked the federation to revise it.

Italy has built newer instruments alongside its own collective agreements. In 2025 the Milan Prefecture, the CNMI, Confindustria Moda and the unions signed a non-binding memorandum with an action plan against exploitation, undeclared work and tax evasion, proposing a digital supply chain platform that companies may join voluntarily with mandatory updates every six months, cascading compliance clauses down to subcontractors, and both scheduled and unannounced audits. Negotiations took close to a year.

The shared ESG framework sits above both. It is the point at which two systems with different mechanics describe the same expectations in the same words.

The Milan Tribunal Cited Negligent Facilitation in Five Manufacturing Cases

The Milan public prosecutor’s office, under chief prosecutor Marcello Viola and prosecutor Paolo Storari, has since 2023 investigated conditions in the Italian workshops that supply luxury houses. The Milan tribunal placed several manufacturing subsidiaries under judicial administration, among them Manufactures Dior, Giorgio Armani Operations, Alviero Martini, Valentino Bags and Loro Piana.

The legal finding in these cases concerned oversight rather than direct exploitation. The tribunal described negligent facilitation, colposa agevolazione, meaning the companies had failed to verify the conditions along their subcontracting chains. In the Loro Piana case the court referred to a generalised absence of organisational models and a faulty internal audit system. Production of cashmere jackets had been placed with a company that held seven workers and almost no machinery for the task, which subcontracted onward to a further firm, which in turn used two Chinese-owned workshops. Inspections recorded workers without papers, working hours reaching ninety per week, unsafe premises and unpaid social contributions.

The administrations were lifted as the companies cleaned their supplier bases under court-appointed commissioners, Armani in February 2025, Dior shortly after, Loro Piana in April 2026 following roughly 2,400 audits and the removal of more than a hundred suppliers. In December the police requested governance documents from thirteen further companies, among them Dolce & Gabbana, Versace, Prada, Missoni, Ferragamo, Givenchy Italia, Alexander McQueen Italia, Gucci and Yves Saint Laurent Manifatture. On 16 July 2026 similar orders went to eleven more, including Chanel, Brunello Cucinelli, Bulgari, Etro, Moncler and Stefano Ricci. None of those companies is under investigation and none has been placed under administration. Cucinelli said it had been surprised and saddened to learn that packaging material had been found in an unsuitable workplace, despite its supplier controls and pricing policy, and pledged full cooperation.

Read alongside the framework, several of the requirements correspond directly to what those cases turned on.

• Expectation 06 requires a business partner to demonstrate that its production capacity is sufficient to fulfil accepted orders.
• Expectation 04 makes the business partner responsible for guaranteeing that its own supply chain meets legal, ethical, social and environmental standards.
• Expectation 35 requires that working hours be monitored and documented accurately.

Capasa Puts Italian Losses at Ten Billion Euros Since 2023

Capasa opened the Milan menswear season in May by naming what the sector had lost.

“Italian fashion has lost ten billion in turnover since 2023 and almost seven in active balance since 2024. These are significant numbers.”

He has said repeatedly that something in the industry has to change. A luxury object carries a claim about how it was made, and that claim has rested largely on reputation. The framework sets out where the two chambers now expect that claim to be documented, in one form, across two countries, along the length of the chain.

The two institutions have also announced a consortium of universities and schools to develop ESG skills throughout the value chain, with the stated aim of building the expertise the framework requires at every level of the supply chain.