For founders and established labels working with California production companies, our Fashion Law practice assists with garment-registration questions, manufacturing relationships, commercial agreements, intellectual-property matters, and related business concerns.
The central issue is not simply, “Does my company own a factory?” California law focuses on what the business actually does and the garment-production work it contracts for.
Who Needs a California Garment Registration Certificate?
California Labor Code § 2675 requires every person engaged in the business of garment manufacturing to register with the Labor Commissioner.
California regulations also require a covered business to register as a contractor or manufacturer according to its actual business practices.
The term “person” is broad under Labor Code § 2671. It includes individuals, partnerships, associations, corporations, limited liability companies, employers, manufacturers, jobbers, wholesalers, contractors, subcontractors, and other persons or entities engaged in garment manufacturing.
A company therefore should not determine its registration status solely from descriptions such as:
- fashion brand;
- apparel company;
- wholesaler;
- retailer;
- e-commerce company;
- designer;
- manufacturer; or
- private-label company.
The company’s actual role in production is what matters.
The California Labor Commissioner’s January 2026 Garment Manufacturer Registration Exam Study Guide states that every person engaged in garment manufacturing in California must register. The guide explains that this includes performing covered manufacturing operations or contracting with a contractor for those operations.
What Counts as Garment Manufacturing in California?
California uses a broad statutory definition of garment manufacturing.
Labor Code § 2671(c) includes activities such as:
- sewing;
- cutting;
- making;
- processing;
- repairing;
- finishing;
- assembling;
- dyeing;
- altering a garment’s design;
- causing another person to alter a garment’s design;
- affixing a label; and
- otherwise preparing garments, apparel, or covered accessories for sale or resale.
The statutory definition also reaches a person who contracts to have covered operations performed.
That provision is particularly important for fashion companies.
A Los Angeles label may employ designers, sales staff, executives, and marketing employees without employing anyone who physically sews a garment. If the business contracts for covered garment-manufacturing activities in California, registration can still become relevant.
I Do Not Own a Factory. Can My Fashion Brand Still Need Registration?
Yes, depending on what the company does.
Consider a Los Angeles clothing company that develops a collection and contracts with another business to cut fabric, sew garments, perform finishing work, attach labels, and prepare the finished products for sale.
The brand itself does not perform the physical sewing.
That fact alone does not remove the company from California’s garment-registration framework because the statutory definition includes contracting to have covered operations performed.
The Labor Commissioner’s garment guidance similarly explains that a garment manufacturer can contract with a contractor to have garments made.
For this reason, outsourcing should not automatically be treated as an exemption from registration.
The parties, production locations, contracts, and actual activities should be examined together.
Does Selling Clothing in California Automatically Require Garment Registration?
Selling finished clothing in California is not, by itself, one of the garment-manufacturing operations listed in Labor Code § 2671(c).
A retailer purchasing finished inventory from an independent supplier therefore presents a different question from a brand contracting with California businesses to produce an original collection.
The analysis can become different when the company:
- commissions products using its own designs or specifications;
- contracts for cutting or sewing;
- directs production changes;
- arranges finishing or assembly;
- contracts for labels to be attached;
- contracts directly with California production businesses; or
- participates in other activities covered by the statutory definition.
The company’s business model and production relationships need to be considered as a whole.
How Does the Location of Production Affect California Garment Registration?
Location is an important part of the analysis.
The California Labor Commissioner’s January 2026 guidance states that every person engaged in garment manufacturing in California must register.
A company should not assume, however, that maintaining its headquarters outside California automatically removes registration concerns when it contracts for garment production inside the state.
A business whose relevant production operations occur entirely outside California presents a different factual situation from a company using California cutting, sewing, finishing, or manufacturing businesses.
The location of the production activity, contracting relationships, role of the company in the supply chain, and California operations should be reviewed before reaching a conclusion about registration.
A business also should not treat sales to California customers as legally identical to conducting garment-manufacturing activities in California.
What Is a Garment Manufacturer Under California Law?
Labor Code § 2671 defines a garment manufacturer as a person engaged in garment manufacturing who is not a contractor.
This can differ from the everyday use of the word “manufacturer.”
A fashion label may think of itself as a brand because it does not own production machinery or employ sewing workers. California law looks instead at the activities and contractual relationships falling within the statutory framework.
A business can therefore operate primarily as a fashion brand while still facing manufacturer-registration questions based on its production structure.
What Is a Garment Contractor?
A garment contractor generally performs garment-manufacturing operations for another person using employees or others.
Covered operations can include:
- sewing;
- cutting;
- processing;
- finishing;
- assembly;
- dyeing;
- garment design alterations;
- label attachment; and
- other covered preparation work.
Subcontractors performing such operations can also fall within California’s garment-law framework.
California regulations require covered businesses to register according to their bona fide business practices rather than relying solely on the description chosen by the business.
What Is a Brand Guarantor Under California Garment Law?
The concept of a brand guarantor is particularly important under California’s Garment Worker Protection Act.
Labor Code § 2671 defines a brand guarantor as a person contracting for garment manufacturing regardless of the number of contractors or subcontractors separating the brand guarantor from the workers performing the manufacturing operations.
The statute also addresses agreements involving licensing a brand or name for garment manufacturing.
This means the legal structure can reach beyond the factory directly employing garment workers.
A Los Angeles label may contract with one production company, which may then use cutting companies, sewing contractors, finishing businesses, or other subcontractors. California law can examine the wider contracting chain.
Does Every Brand Guarantor Need a Garment Registration Certificate?
No.
Brand-guarantor status and garment-registration status are related but separate legal questions.
The California Labor Commissioner addresses this distinction directly. Its Garment Worker Protection Act guidance states that brand guarantors must register if they are engaged in garment manufacturing.
A company should therefore avoid both of these assumptions:
“We are a brand rather than a factory, so California registration cannot apply.”
and
“We qualify as a brand guarantor, so registration automatically applies for that reason alone.”
The correct analysis starts with the statutory definitions and the company’s actual production activities.
Which Fashion Products Can Fall Under California’s Garment Rules?
California garment law is not limited to shirts, dresses, jackets, or pants.
Labor Code § 2671 identifies apparel and accessories that include:
- clothing;
- hats;
- gloves;
- handbags;
- hosiery;
- ties;
- scarves; and
- belts.
The statutory list is not framed as an exhaustive list of every possible product.
This can be important for Los Angeles companies operating across several fashion categories.
An accessories company should not assume that garment law has no application simply because its core products are handbags or belts rather than traditional clothing.
Are There Exceptions to California Garment Registration?
California Labor Code § 2671 contains limited exclusions.
For example, the statutory definition excludes a person manufacturing garments alone without assistance from a contractor, employee, or other person.
The law also contains exclusions involving certain cleaning or alteration businesses and employees performing regulated activities for wages.
The Labor Commissioner’s January 2026 study guide also explains that a tailor or individual sewing or altering a garment for the person who will wear it, rather than for a company reselling that garment, does not fall within the registration requirement described by the agency.
These provisions should not be interpreted as broad exemptions for small fashion companies.
A founder working alone can occupy a different legal position after hiring employees, contracting with production businesses, or commissioning garments for resale.
How Does a Fashion Company Apply for California Garment Registration?
The California Division of Labor Standards Enforcement currently allows garment-registration applications online or by mail.
Applicants must provide business information and supporting documents.
Depending on the entity and circumstances, current DLSE requirements can include:
- fictitious business-name documents;
- State Employer Identification Number information;
- Federal Employer Identification Number information;
- articles of incorporation;
- LLC articles of organization;
- limited-partnership documents;
- Secretary of State Statements of Information; and
- workers’ compensation documentation when applicable.
Businesses should use the current DLSE application instructions rather than relying on older forms or unofficial summaries.
Is There an Exam for California Garment Registration?
Yes.
The Labor Commissioner’s January 2026 study guide states that initial registrants must pass the garment examination.
The current passing score is 70 percent.
The examination covers California labor requirements and relevant health and safety subjects applicable to the garment industry.
California regulations also place requirements on the individual taking an examination for a business entity. Depending on the applicant structure, the qualified individual may need a specified ownership interest or qualifying labor-relations role within the business.
For renewal registrations, another examination is not automatically required every year. The Labor Commissioner may require a renewal applicant to take the examination again following a registration violation during the preceding year.
How Much Does a California Garment Registration Certificate Cost?
California registration fees depend partly on the type of registration and the business’s reported gross sales.
DLSE currently lists annual contractor fees as:
- $250 for gross sales of $100,000 or less;
- $350 for gross sales from $100,001 through $500,000;
- $500 for gross sales from $500,001 through $1 million; and
- $1,000 for gross sales above $1 million.
The current standard manufacturer fee schedule lists:
- $750 for gross sales of $500,000 or less;
- $1,000 for gross sales from $500,001 through $3 million;
- $1,500 for gross sales from $3,000,001 through $7 million; and
- $2,500 for gross sales above $7 million.
Different fee rules can apply following specified prior registration denials, suspensions, or revocations.
Businesses should check the current DLSE fee schedule immediately before filing because administrative fees can change.
Does Every Applicant Need a $5,000 Bond?
No.
A $5,000 bond is not a universal requirement for every garment-registration applicant.
DLSE’s current application instructions state that a $5,000 bond is required for applicants that have received specified citations or assessments from the U.S. Department of Labor or California Department of Industrial Relations for violations identified by the agency.
California Labor Code § 2675 also contains a bonding provision connected to specified prior garment-law citations and penalties.
A company should therefore review its enforcement history and current DLSE instructions rather than assuming that every new registration requires a bond.
Can a New Fashion Brand Start Manufacturing While Its Application Is Pending?
A first-time applicant should not treat filing an application as authorization to begin covered garment operations.
DLSE states that operating a garment business without first obtaining the required registration is illegal and can expose the business to civil or criminal penalties.
This makes registration timing important when planning a collection launch or moving production to California.
Companies preparing to begin covered California manufacturing activities should address registration before those operations commence.
Renewal Applications Can Be Different
California Labor Code § 2675.2 provides a limited registration-extension procedure for qualifying renewal applications.
An existing registration may be extended for up to 90 days when the statutory conditions are satisfied, including timely submission of a complete renewal application and satisfaction of other applicable requirements.
The extension is not automatic.
The Labor Commissioner may also grant an extension for a renewal application received less than 30 days before expiration following a showing of extenuating circumstances.
A company waiting for its first registration certificate is therefore in a different legal position from an existing registrant qualifying for a statutory renewal extension.
What Can Happen If a Business Operates Without Required Registration?
California law provides several enforcement mechanisms.
Labor Code § 2676 provides that a person engaged in garment manufacturing without registration can be guilty of a misdemeanor, subject to a statutory exception involving businesses without workers.
Labor Code § 2678 provides civil penalties for registration violations.
For a person employing workers, the statute provides:
- $100 per affected employee for an initial violation; and
- $200 per affected employee for a second or later violation.
For a covered person that does not employ one or more workers, § 2678 provides a $500 civil penalty and states that the person does not face the misdemeanor consequence specified in § 2676 for that violation.
California law also permits confiscation of garments or apparel assembled or partially assembled by or for a person that has not complied with the registration provisions.
These consequences make registration status a business issue that should be addressed before a regulatory inquiry develops.
Why Should a Fashion Brand Check Its Contractors’ Registrations?
A fashion company should examine the registration status of the businesses participating in its production chain.
California Labor Code § 2677 addresses situations in which a person engaged in garment manufacturing contracts with another garment business that lacks required registration or a required valid bond.
Under the conditions stated in the statute, the contracting business can face employer status and joint liability for specified violations committed by the unregistered business.
DLSE maintains a public Garment Manufacturers and Contractors Registration Database that includes information such as registration numbers, business names, classifications, addresses, and expiration dates.
Fashion companies can use that database as part of contractor review.
DLSE also cautions that an entry appearing as expired can still be undergoing renewal because database updates may lag the registration process. An apparent expiration should therefore be investigated rather than treated as conclusive proof that the contractor lacks current registration.
Before entering a California production relationship, a brand should consider reviewing:
- the contractor’s legal entity name;
- registration number;
- registration classification;
- listed expiration date;
- production location;
- involvement of subcontractors; and
- the businesses performing each stage of production.
Companies entering or revising these relationships may also benefit from reviewing their manufacturing agreements through our Business Transactions Law practice.
What Records Must Brand Guarantors Keep?
California garment law imposes specific recordkeeping requirements.
Labor Code § 2673 requires brand guarantors to maintain specified records for four years.
Those records include items such as:
- contract worksheets showing agreed pricing;
- contracts;
- invoices;
- purchase orders;
- work or job orders;
- style or cut sheets;
- identifying information for contracting parties; and
- copies of garment registrations for covered persons with whom the brand guarantor contracts.
These documents can become important during Labor Commissioner proceedings, wage claims, production disputes, or reviews of a manufacturing relationship.
Fashion companies should develop organized production records as their contractor networks grow rather than trying to reconstruct the manufacturing chain after a dispute has started.
What Should a California Garment Manufacturing Contract Include?
For contracts between persons engaged in garment manufacturing covering the production or preparation of garments for sale or resale, California regulations impose specific written-contract and record-retention requirements.
Covered agreements may need information concerning:
- legal and fictitious business names;
- addresses;
- garment-registration numbers;
- registration expiration dates;
- workers’ compensation information;
- contract dates;
- completion dates;
- unit prices;
- quantities;
- garment type, style, and color;
- style, cut, or lot numbers;
- total contract price;
- payment information; and
- later changes to the agreement.
Covered written contracts must generally be retained for at least four years.
Apart from regulatory requirements, a fashion manufacturing agreement can also address commercial issues such as:
- design ownership;
- intellectual-property rights;
- confidentiality;
- approved subcontractors;
- quality specifications;
- delivery dates;
- inspection procedures;
- defective merchandise;
- payment terms;
- indemnification; and
- dispute procedures.
Clear manufacturing agreements can become especially valuable when a missed delivery, unauthorized subcontractor, quality problem, intellectual-property issue, or wage-related allegation affects a collection launch.
How Does California’s Garment Worker Protection Act Affect Fashion Brands?
California’s Garment Worker Protection Act took effect on January 1, 2022.
Among other provisions, Labor Code § 2673.1 creates joint and several liability in specified garment-manufacturing relationships.
Depending on the facts, manufacturers, contractors, and brand guarantors can face liability for categories including:
- unpaid minimum wages;
- regular wages;
- overtime wages;
- premium wages;
- certain expense reimbursements;
- other compensation;
- interest;
- specified attorney fees and costs; and
- certain civil penalties connected to workers’ compensation coverage.
The statutory framework is designed to address garment-production structures containing multiple contracting layers.
A garment registration certificate therefore does not resolve every California labor-law issue facing a fashion company.
A broader review can include:
- the brand’s registration status;
- contractor registrations;
- subcontracting;
- production agreements;
- required records;
- wage-related exposure; and
- brand-guarantor status.
Is Garment Registration the Same as California Textile Recovery Compliance?
No.
California garment registration and California’s Responsible Textile Recovery Act create separate legal frameworks.
Garment registration concerns businesses engaged in covered garment-manufacturing activities.
The Responsible Textile Recovery Act creates a separate extended-producer-responsibility system involving covered apparel and textile products.
Fashion companies selling into California can therefore encounter obligations under both legal regimes depending on their products and business structure.
Our article on California’s textile recovery law for fashion brands discusses that separate program, including producer identification, current PRO membership requirements, covered products, and implementation dates.
California Garment Registration Checklist for Fashion Brands
Before beginning or expanding production in California, a fashion business should identify:
- What products does the company sell?
- Which production activities take place in California?
- Does the business perform covered manufacturing operations itself?
- Does it contract for covered operations?
- Who cuts the products?
- Who sews them?
- Who performs assembly or finishing?
- Who attaches labels?
- Who may change designs during production?
- Does the primary contractor use subcontractors?
- Does each covered production business hold current registration?
- What registration classification does each contractor hold?
- Are required production records being retained?
- Do covered written agreements contain required information?
- Has the company’s manufacturing structure changed since its last registration review?
This last question can be particularly important.
A Los Angeles fashion company may begin by purchasing finished wholesale inventory and later move into original design, private-label manufacturing, local production, or direct contractor relationships.
A change in the production model can also change the garment-registration analysis.
Frequently Asked Questions About California Garment Registration
Does every California fashion brand need a garment registration certificate?
No. Registration applies to persons engaged in garment manufacturing under California law. Because the statutory definition includes contracting to have covered manufacturing activities performed, some brands can fall within the registration framework without owning factories.
Do I need garment registration if another company sews all of our products?
Outsourcing sewing does not automatically remove a company from California’s registration rules. The law includes contracting to have covered garment-manufacturing operations performed.
Does an online fashion brand need California garment registration?
Operating online does not decide the registration question. The company’s production activities, contracting relationships, and location of covered manufacturing operations are more important.
Can handbags and accessories fall under California garment law?
Yes. Labor Code § 2671 expressly identifies several accessories, including handbags, hats, gloves, hosiery, ties, scarves, and belts.
Is brand-guarantor status the same as garment-registration status?
No. The California Labor Commissioner states that brand guarantors register if they are engaged in garment manufacturing. The two legal concepts should therefore be analyzed separately.
How often does a California garment registration certificate need renewal?
DLSE’s January 2026 study guide states that garment registration must be renewed annually.
Can I manufacture while waiting for my first registration certificate?
A first-time applicant should not rely on a pending application as authorization to begin covered operations. DLSE states that a garment business requiring registration must obtain registration before operating.
How can I check a garment contractor’s registration?
DLSE provides a public registration database that allows users to review registration numbers, business names, classifications, addresses, and expiration information.
Is garment registration the same as a local business license?
No. Garment registration is a state Labor Commissioner requirement. Local licenses and permits are separate. California law also connects local licensing of garment-manufacturing businesses with proof of state garment registration.
How long should covered garment records be retained?
California law requires specified garment and brand-guarantor records to be retained for four years.
Speak With a Los Angeles Fashion Lawyer About Garment Registration
California’s garment-registration laws can reach fashion businesses that do not fit the traditional image of a manufacturer. A brand that contracts for covered manufacturing activities in California can face registration questions even when outside companies perform the physical production.
The analysis may also change as a fashion business adds contractors, moves production into Los Angeles, expands private-label manufacturing, licenses its brand, introduces new products, or changes its supply chain.
We work with fashion companies, designers, manufacturers, founders, wholesalers, retailers, and other businesses on garment-registration questions, production agreements, commercial relationships, intellectual-property issues, and related disputes.
Our Corporate Law and Business Ventures practice can also assist Los Angeles companies reviewing entity structures, regulatory obligations, licensing matters, and business relationships as operations develop.
If your company is beginning California production, changing manufacturers, expanding its product line, or questioning its current garment-registration status, use the Schedule Consultation button or contact form to arrange a confidential strategy call with our firm.
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