Though Levi Strauss & Co. has long asserted itself as a leader in sustainable fashion, Stand.earth — an advocacy organization that holds corporations and governments accountable for environmental destruction — is calling out the denim retailer as a top polluter in an extensive report released today.

In the study, titled “Too Deadly To Wear,” researchers stated that though Levi’s has made progress in reducing water waste, it has neglected to clean up deadly air and pollution emissions. According to the report, Levi’s can be traced to more than 2,200 deaths or disabilities in 2016, a number calculated by using its pollution-volume percentage across the industry and then calculating its tie to illness traced to toxic pollution from retail factories and coal plants. It also claims Levi’s contributes to an estimated 30 additional deaths related to climate change annually because it releases the same amount of pollution as 1.1 million cars.

“Levi’s has talked itself into believing that leadership is just changing the lightbulbs in their headquarters; that’s the problem,” said Todd Paglia, executive director of Stand.earth. “Real leadership is substantively addressing all of the impacts across their supply chain. They have to grapple with the fact that it’s not as easy as changing your lightbulbs.”

The report comes after Levi’s made a public commitment to improving its supply chain in November 2016, urging suppliers to avoid harmful petroleum-based materials in favor of natural resources. Previously, Levi’s shared that it maintains a restricted-substances list that it first launched in 2000 and has continued to update over the years.

“Levi Strauss & Co. has a long-standing commitment to taking action on climate change,” a Levi’s spokesperson wrote in a statement. “In line with our history of advocacy, we’ve been vocal in our support for the Paris Climate Agreement and in urging world leaders to protect our environment. We’re committed to reducing our emissions by 25 percent and using 20 percent renewable energy by 2020 – and we are on track to exceeding this goal.”

Despite these efforts, the Stand.earth report found that 99 percent of Levi’s pollution comes from its supply chain, including everything from facilities that handle fiber, yarn and fabric procurement to factories that deal with assembly, dyeing, finishing and distribution. The researchers attributed the problem to a lack of enforcement and clear policies monitoring production protocols across the supply chain.

Paglia said the report took several months to compile and was inspired by several unanswered attempts to connect with Levi’s CEO Chip Bergh to discuss early findings and suggest methods for improvement. For Stand.earth, urgency began to mount in response to the recent barrage of natural disasters that experts say have been caused by climate change, including wildfires and mudslides on the West Coast and an influx of hurricanes ravaging the East Coast.

Paglia said, rather than antagonize, the study is designed to heighten Levi’s attention to the issue and encourage the brand to enact sustainable policies that will tangibly move the dial, in turn influencing peers and competitors. Levi’s executives have previously spoken about the company’s responsibility to leading industry members around sustainability and have held forums and symposiums on the topic in the past.

“We have the power to steer some really big boats in this industry, as well as small startups, and innovative smaller companies that have a vision for a sustainable future,” Paul Dillinger, vp and head of global product innovation at Levi’s, told Glossy in October 2016.

Denim is a notoriously destructive product to make due to the volume of water needed for production and the tendency to cause harmful chemical run-off to contaminate natural water sources. While the report does give Levi’s credit for efforts on reducing water through its “Water<Less” program and for supporting U.S. participation in the Paris Climate Agreement, it calls on the brand to use its influence to make meaningful change. The researchers delineate ways Levi’s can make a bigger impact by setting attainable goals for the company, including transitioning its entire supply chain to renewable energy and reducing carbon emissions by 66 percent by 2050.

“It’s all talk and no action,” Paglia said. “Levi’s keeps telling us that they’re a leader. OK, if you’re a leader, where’s the leadership? If you look at cumulative impacts, it’s a 160-year-old company that’s had enormous impacts on people and the climate, and a legacy of pollution that they need to deal with. This all led us to say to Levi’s, ‘You keep saying you’re a leader, now lead.’”

This article was updated to include official comment from Levi’s.