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By Dalena White, secretary general, IWTO

BRUSSELS – In the heart of the European Union, the fashion industry finds itself at a crossroads amid growing concerns over climate change and environmental degradation. Against this backdrop, stakeholders are engaged in heated discussions on the elusive concept of sustainability and how to attain it. Even politicians are now getting involved, with members of parliament from the likes of France and Germany now regularly having their say on environmental issues in the fashion industry.

The burning questions: Do we need more recycled products? Better consumer education? Stricter regulations? Or perhaps a gentle nudge towards greener purchasing habits?

Enter the Product Environmental Footprint (PEF), a cornerstone of the European Union’s sustainability playbook. Developed by the European Commission, PEF offers a systematic approach to assess and communicate the environmental impact of products throughout their lifecycle. It aims to standardise measurements of crucial factors like greenhouse gas emissions, water usage, and resource depletion.

 Championed for several years by EU policymakers, PEF holds promise as a tool for identifying areas for environmental improvement and guiding decisions by businesses, consumers, and policymakers alike. With a close eye on high emissions sectors such as apparel and footwear, the EU has been pushing for wider adoption of PEF methodologies as part of its broader environmental agenda.

But is PEF the silver bullet for a more sustainable fashion industry? The International Wool Textile Organisation (IWTO) is supportive of EU efforts on green issues but has reservations about PEF in its present format. Here, I will outline some of our concerns about the methodology’s current limitations and the potential impact of these if PEF is rolled out for apparel.

The PEF rules being developed for apparel and footwear are the first time the PEF will be used to compare farmed products with mined products. In many ways, this is comparing apples with oranges and is hugely problematic.

PEF uses a lifecycle analysis (LCA) approach. Sadly, this falls short in assessing the true impact of synthetic fibres such as polyester. For instance, via its use of LCA, PEF does not account for the environmental impacts of forming oil, and only minutely accounts for the release of its carbon into the atmosphere – carbon that had been safely stored underground for millions of years. On the other hand, the impacts of forming natural fibres on a farm are fully accounted for, significantly advantaging the PEF score for synthetic clothing.

It also treats all microfibres equally. This is despite the fact that unlike microplastics released from synthetics, natural fibres such as wool offer biodegradable alternatives. Release of the nutrients from products back to the soil for use again is vital to long term sustainability, yet the PEF scoring system does not presently reward these natural fibres for such obvious attributes.

The failure to integrate microplastic impacts into the overall PEF score, but rather relegating them to ‘additional information’, has the effect of concealing crucial information from well-intended consumers and not influencing their purchasing choices.

PEF in its current form also fails to fully account for the circular attributes of natural fibres, including their renewability, reuse and recycling potential.

Without improvement, PEF threatens to undermine the EU’s broader environmental goals, including promoting a circular economy, combating plastic pollution, and putting fast fashion out of fashion. Despite the EU’s genuine commitment to green initiatives, there is a risk that PEF will push consumers towards purchasing decisions which are bad for the environment. This is in none of our interests, and this is clearly not the intention of EU policy makers.

The Commission’s public consultation on PEF is now open, and responses are more than welcome before its closure on 28 April 2024.

As this discussion continues, stakeholder help is needed to retarget PEF and ensure it aligns with the EU’s ambitions for a greener future. The clock is ticking, but with concerted efforts, a more sustainable path forward – one which better reflects the relative environmental attributes of natural fibres compared with their synthetic counterparts – is possible


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