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PARIS – “Legislation is coming, and there’s going to have to be transparency.” This was the stark conclusion drawn from a panel session on apparel sustainability I participated in at COP27 in Egypt in November. The subject was ‘Minimising Climate Impacts across the Value Chain’ and I was joined by model and activist, Arizona Muse, and Simone Cipriani of the UN Alliance for Sustainable Fashion for the session. We agreed that collating a verified source of truth and linking it to a garment is going to be a game-changer in the apparel industry – whether brands like it or not.

While transparency has long been advocated as the key to driving circularity in fashion production and consumption, the French Decree 2022-748 AGEC (Anti-Waste for a Circular Economy Law) will make verified environmental labelling an absolute necessity for large clothing brands selling in France from January 2023, and smaller ones soon after. So, what can be done to prepare for this revolutionary step?

French regulators move first

It’s commendable that the French government has committed to a strong legal strategy enforcing transparency about environmental impacts of clothing sold in France. Rather confusingly for the industry though, it has done so ahead of planned wider EU laws that will make climate-impact labels mandatory across the entire bloc. So, the first thing brands must do is commit to a digital solution for labelling that will give them supply chain visibility, and the scope to adapt their data management to a fast-evolving legal framework.

Then of course, there must be full understanding of the incoming compliance requirements. The French Decree 2022-748 will eventually apply to all fashion brands that sell garments, footwear, and home textiles in the French market. It will be implemented for companies with a turnover above €50m in January 2023, and phased in for smaller companies during 2024 and 2025.

At a basic level, the legislation requires fashion brands to provide consumers with detailed information about the environmental qualities and characteristics of the products they purchase. This will include information on reparability, recyclability, sustainability, re-use possibilities, recycled material content, use of renewable resources, traceability and the presence of plastic microfibres.

Product information must be made available to consumers at the point of sale – so either online or in a shop – and available after sales. In practical terms, this means a dedicated web page per product must be built to inform consumers about the specifications and environmental characteristics of the product.

The objective is to empower consumers to make conscious decisions about their purchases and to manage textile and packaging waste more effectively. It should certainly stamp out fashion brands’ penchant for greenwashing, instead forcing retailers to source genuinely sustainable fabrics, and to think about the longevity of the garments they design.

It’s worth noting that smaller apparel companies with a turnover of €10m and above, or that put more than 10,000 waste-generating units into the French market annually, will not need to be compliant until January 2025.

What about countries outside of France, selling into the country? The decree states that these brands will have to translate all the product information they collate and make available to shoppers into French. In other words, every product you’re selling will need a digital product page for the French market.

Are apparel brands ready?

From my conversations with apparel manufacturers and retailers in recent weeks, a big concern is that many Spring/Summer 2023 garments are already manufactured and in the supply chain heading for sale in France – without anything like the correct labelling. There is a scramble for the larger brands to make changes to comply with the new laws. Also, as mentioned earlier, with the EU bringing in similar laws for Digital Product Passports (DPPs) on garments by 2025, as part of the Green Deal, concerns are being raised about how different compliance requirements can possibly work together, and which to focus on first.

The French Decree seemingly came from nowhere, taking fashion brands very much by surprise. Conversely, the EU legal changes set out in the Green Deal have been on the horizon for years, giving lobbying groups, businesses and industry stakeholders ample time to debate key issues, and research the benefits of DPPs. There has also been time to plan the best ways to introduce new systems.

As yet, the French and EU rules are not aligned, so the global apparel industry is watching with interest to see how this is addressed. Avery Dennison sits on the EU’s CIRPASS panel and we can confirm that a great deal of brilliant work is going into piloting and preparing the ground for the deployment of standardised, verified and technologically feasible Digital Product Passports, for all product categories.

The good news is that the technology for DPPs is market-ready and already being used by leading apparel brands keen to adopt circular models as quickly as possible. Avery Dennison’s clients are making headway with digital care labels in garments and other triggers that link to DPPs on web pages and apps. Simply by scanning QR codes on labels or NFC tags with a smartphone, consumers, regulators, and other stakeholders, can open up a wealth of information.

As so many commentators at COP27 pointed out, we have every reason to be hopeful that new laws like the French Decree will trigger a greener future for fashion and textiles. There’s also real conviction in the industry that DPPs – acting as a data gateway – will not only support compliance, but will allow recyclers and resellers to identify the material later on in the garment life cycle. DPPs bring a host of other benefits to apparel companies too – from tighter supply chain management, to brand authentication and story-telling.

Fashion now acknowledges the role supply chain transparency will play in reducing the mountains of textile waste produced, and tackling the industry’s heavy carbon footprint. Thanks to the latest digital innovations, we can engage with customers, and drive behaviour change right now. Quite simply, if we can extend the life of garments – reselling or upcycling worn items and recycling fabrics – we can make real progress towards vital sustainability goals.

Many on the CIRPASS panel, including myself, are hopeful that the new French regulations won’t conflict too directly with the EU’s DPP plans. We really need to harmonize and make these changes as easy as possible for the fashion industry to adopt.

Debbie Shakespeare is senior director of sustainability, compliance, and core product line management, Avery Dennison RBIS

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