BRUSSELS – Pending new laws on making fashion green claims in the European Union could provide a license for greenwashing, 12 NGOs have warned. The civil society groups have written to the European Commission expressing serious concerns about the Product Environmental Footprint (PEF) and its potential role in eco-labels for fashion. They claim the Product Environmental Footprint Category Rules (PEF-CR) for apparel and footwear “will give a limited and unholistic picture of product impact.”
“As such, it is our view that the PEF-CR for apparel and footwear should not be used as a standalone method for underpinning labelling, green claims made in marketing, or any other EU policy measures announced as part of the EU Strategy for Sustainable and Circular Textiles,” the letter adds.
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The European Commission will outline the role it sees for product comparison rules based on the PEF method in a legislative proposal on substantiating green claims, planned for release on 30 November.
PEF is set to be primary tool expected to be used as the basis for product sustainability claims. However, in the letter the 12 groups claim the development of the PEF-CR for apparel and footwear is mainly driven by representatives from industry groups; is under minded by poor quality data; does not consider the full lifecycle of textiles; does not consider social impacts; and fails to address fast fashion.
The letter also says these limitations are all the more significant in light of the Norwegian Consumer Authority (NCA) ruling in June that the global average data behind the Higg Materials Sustainability Index (MSI) does not constitute sufficient evidence for product
specific claims and that any claims made by companies building on this tool are seen by the NCA as misleading. The letter states: “In light of this ruling, we would welcome a clarification from the Commission as to whether there is any overlap between the secondary datasets and/or the methodology used by the Higg MSI and by the database which the Commission will provide for use with the PEF-CR (the EF 3.1 database). In order to be verifiable and easily accessible, data used must be open access. The Commission could also consider commissioning the LCAs necessary for true comparisons.”
The letter calls for an expert committee made up of stakeholders which include civil society groups – and not just industry – should get the chance to scrutinise and vote on the final outcome of the PEF-CR for apparel and footwear.
Emily Macintosh, senior policy officer for Textiles at the European Environmental Bureau (EEB), said: “It would be problematic if rules that don’t measure the impact of overproduction form the backbone of EU efforts to curb fast fashion. More democratic oversight is needed in the process of drafting product comparison rules.”
Make The Label Count (MTLC) coalition has also sent an open letter to the European Commission calling for them to ensure that upcoming EU textile legislation does not facilitate greenwashing. The letter is signed by 23 organisations, including Australian Wool Innovation, the Campaign for Wool and Plastic Soup Foundation.
The letter calls on the Commission to amend the PEF methodology to make it fit for purpose. To do this, the letter states, it needs to include microplastic release, plastic waste, and circularity.
The letter says the omission of these indicators could risk measuring synthetic clothing as more sustainable than it actually is, “guiding well-intentioned consumers to buying more of the fossil fuel-derived fashion, rather than less.”
The PEF method was developed by the European Commission to create a common approach to conducting assessments of a product’s environmental impacts over a defined lifetime, typically measured from the extraction and cultivation of raw materials to their end-of-life. A group of brands are in the process of developing rules for how to apply the method to apparel and footwear products.
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