Texas Attorney General Ken Paxton secured an Assurance of Voluntary Compliance with Lululemon USA Inc. after investigating potential PFAS and consumer representations about product safety. The agreement requires the company to maintain supply-chain chemical standards, verify vendor compliance through testing or certifications, and take corrective action for three years; no monetary penalty is stated.
For three years, Lululemon must maintain and enforce chemical safety requirements across its supply chain, require vendors to demonstrate compliance with its Restricted Substances List through independent testing or valid third-party certifications, verify certifications, require additional testing when certifications expire, and take commercially reasonable corrective action for vendor noncompliance.
This is a chemical-safety enforcement action, not a privacy enforcement action, so it does not directly indicate changes to data-processing, privacy-notice, consent, or breach-notification clauses. In vendor and manufacturing agreements, review provisions requiring compliance with the company’s Restricted Substances List, independent laboratory testing or valid third-party certifications, verification and renewal of certifications, retesting when certifications expire, supply-chain oversight, and commercially reasonable corrective action for noncompliance. Customer-facing product terms and supplier flow-down clauses should also clearly allocate responsibility for substantiating product-safety claims and maintaining compliance records.
Entity
Lululemon USA Inc.
Industry
RetailOfficial Press Release
https://www.texasattorneygeneral.gov/news/releases/attorney-general-paxton-secures-settlement-lululemon-enforce-chemical-safety-standards-and-protect
Lulu AVC
https://www.texasattorneygeneral.gov/sites/default/files/images/press/Lulu%20AVC.pdf
Texas Attorney General Enforcement Page
https://www.texasattorneygeneral.gov/consumer-protection/privacy
"Lululemon USA Inc. (“Lululemon”)"
"October 22, 2026 | Press Release"
"potential presence of per- and polyfluoroalkyl substances (“PFAS”), commonly known as “forever chemicals.”"
"The company must continue requiring its vendors to demonstrate compliance with its Restricted Substances List (“RSL”) through independent laboratory testing or valid third-party certifications."
"These obligations will remain in effect under the AVC for three years."
"Attorney General Ken Paxton secured an Assurance of Voluntary Compliance (“AVC”) with Lululemon USA Inc. (“Lululemon”)"
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$3.0M
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$773.0M
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$1.5M
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