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BRUSSELS – The EU’s Strategy for Sustainable and Circular Textiles has been long in the making. Nobody knew quite what to expect when it finally dropped at the end of March. First impressions, however, are of pleasant surprise. This is a more radical document than one might have dared to hope for from the EU. It says all the right things on greenwashing, unsubstantiated eco claims, an over-dependence on polyester (driving fast fashion), the need to substantiate 2030 emissions targets, microplastics and the needless destruction of clothing.

Most encouragingly of all, the document tells us the EU has been listening to the debates which have been taking place these past few years. And by this, I mean listening to all actors, not just fashion marketing teams whose solution to everything seems to be to sell more and cross your fingers that one day technology will arrive that can recycle it all (newsflash: it’s not happening any time soon, if ever. And I say this having spent a decade talking to people at the sharp end of textile-textile recycling).

Setting the scene, the document points out: “As clothing comprises the largest share of EU textile consumption (81 per cent), the trends of using garments for ever shorter periods before throwing them away contribute the most to unsustainable patterns of overproduction and overconsumption. Such trends have become known as fast fashion, enticing consumers to keep on buying clothing of inferior quality and lower price, produced rapidly in response to the latest trends.”

If this opening sounded a few alarm bells for the major fast fashion brands, the meat of the EU’s document does little to ease them.

Among the more interesting proposals are a ban on greenwashing. This would come as part of proposed revisions in EU consumer law announced in the New Consumer Agenda and the Circular Economy Action Plan; as ever with the EU, there are layers upon layers of legislation.

Under proposed laws, consumers will have a right to know how long a product is designed to last for and how, if at all, it can be repaired. In addition, new rules will strengthen consumer protection against untrustworthy or false environmental claims, banning ‘greenwashing’ and practices misleading consumers about the durability of a product.

The EC is proposing to amend the Consumer Rights Directive to oblige businesses to provide consumers with information on product durability and reparability. On the issue of durability – huge in fashion – consumers must be informed about the guaranteed durability of products. We think such issues leave lots of room for interpretation but nonetheless it is pleasing durability is given a good hearing by the EU.

The Commission is also proposing several amendments to the Unfair Commercial Practices Directive (UCPD). It adds new practices that are considered misleading after a case-by-case assessment, such as making an environmental claim related to future environmental performance without clear, objective and verifiable commitments and targets, and without an independent monitoring system.

Companies would also be banned from making generic, vague environmental claims where the excellent environmental performance of the product or trader cannot be demonstrated. Examples of such generic environmental claims are ‘environmentally friendly’, ‘eco’ or ‘green’, which wrongly suggest or create the impression of excellent environmental performance.

Companies would also be banned from making an environmental claim about the entire product, when it really concerns only a certain aspect of the product; and displaying a voluntary sustainability label which was not based on a third-party verification scheme or established by public authorities.

Generic claims would only be allowed with substantiation such as the EU Eco Label – the EU references this label specifically. How many brands use this label though?

The Commission mentions the issue of synthetics and recycled polyester. Particularly, the EC says companies will be encouraged to focus on the use of recycled polyester from fibre-fibre recycling (currently around one per cent of the global market) as opposed to using recycled polyester made from plastic bottles.

It is good that the Commission has recognised the insanity of taking a product (a plastic bottle) out of a closed loop system (plastic bottles recycled into new plastic bottles), adding it to a linear system (for use in fashion where the product gets one more life) and re-branding it as sustainable.

For fast fashion brands which have been engaging in this large-scale deceit, the EU’s announcement might just signal that the party is over. But why not stop there? For years we have been asking why fashion is branding certain, accredited cottons as “more sustainable” when such claims are categorically untrue. These misleading claims harm us all and thwart progress. We hope the EU comes down on them like a tonne of bricks moving forwards.

On the issue of recycling generally, the Commission’s paper focuses heavily on design. The paper states: “While sorting and advanced recycling technologies need to be further developed, improving product design is the first step to address technical challenges. For instance, fibres are often blended with others, (e.g. polyester with cotton), which makes recycling more difficult due to low availability of technologies to separate textile waste by fibre. Moreover, elastane, often added to increase the functionalities of fabrics, can act as a contaminant in almost all textile fibres recycling technologies, impacting the economic feasibility and environmental cost of the recycling process. For thermo-mechanical recycling, blending of different types of polyester can also adversely affect the processing of textile waste and the quality of the recycling output.”

All these issues are interlinked, and this needs to be borne in mind. Fast fashion brands pushing ‘circularity’ while promoting increasingly complex fibre blends in their clothing is simply further greenwashing. This issue has come about partly because sustainability and marketing have become one and the same thing in fashion circles. This has to change.

The Commission also calls for a ban on the destruction of unsold textiles. “Destroying unsold or returned goods, including clothing, is a waste of value and resources,” it says. “As a disincentive for this practice, under the Ecodesign for Sustainable Products Regulation, the Commission proposes a transparency obligation requiring large companies to publicly disclose the number of products they discard and destroy, including textiles, and their further treatment in terms of preparing for reuse, recycling, incineration or landfilling. Subject to receiving the empowerment under the proposed Regulation and a dedicated impact assessment, the Commission will also introduce bans on the destruction of unsold products, including as appropriate, unsold or returned textiles.”

A few other areas worthy of mention include the introduction of Extended Producer Responsibility/EPR (polluter pays) regulations to encourage waste prevention.

There is also acknowledgement that synthetics are the main problem where microplastic pollution is concerned. This issue, the EC suggests, can be tackled via eco-design, pre-washing, wastewater and washing machine filters.
Finally, the waste trade of textiles will be addressed via restrictions of exporting, with the EU to distinguish second-hand clothes for resale and waste textiles.

This is a broad, all-encompassing paper. It could be years before any of the proposals become law. The EC itself told us via social media: “Our proposals will need to be discussed by the European Parliament and EU countries before becoming law.”

In the meantime, we expect some serious lobbying from industry. On that front, the Policy Hub issued its own response. For the uninitiated, the Policy Hub is made up of five organisations: Sustainable Apparel Coalition (SAC), Global Fashion Agenda (GFA), Federation of the European Sporting Goods Industry (FESI), Textiles Exchange (TE), and the ZDHC Foundation.

“The Policy Hub- Circularity for Apparel and Footwear acknowledges that as an industry we must take action to reduce our environmental impact,” it said.

But here’s the rub: the Policy Hub’s member organisations have had years to act, and none (ZDHC accepted) have come up with any ideas as far-reaching, meaningful and potentially impactful as those offered by the EU. And seriously, why would they when their paying members are the fashion industry itself?

These laggards have had their chance and been found comprehensively wanting, year in, year out. Most dangerous of all, organisations like the above – and we can add Better Cotton to this list – have enabled fast fashion retailers to brand themselves as sustainable via their various daft schemes and initiatives. Fast fashion – sustainable. It’s the ultimate oxymoron which gets more ridiculous the more you think about it.

If the EU’s proposed regulations achieve just one thing, let us hope it is that fast fashion businesses are banned from using the word ‘sustainable’ on any of their marketing until they have reformed their environmentally reckless business models.


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