The production and consumption of textile products continues to grow and so does their impact on climate, on water and energy consumption and on the environment. About 5.8 million tonnes of textiles are discarded in the EU every year, approximately 11kg per person, and every second somewhere in the world a truckload of textiles is landfilled or incinerated. As clothing comprises the largest share of EU textile consumption, the trends of using garments for ever shorter periods before throwing them away contribute the most to unsustainable patterns of overproduction and overconsumption.
These challenges call for systemic solutions in line with the European Green Deal’s ambition to make growth sustainable, energy- and resource efficient, and centred around a circular economy. In response to this the EU Commission has built on the 2020 Circular Economy Action Plan and released the EU Strategy for Sustainable and Circular Textiles (the Strategy) in March 2022. This strategy aims to create a coherent framework and a vision for the transition of the textiles sector whereby, by 2030 textile products placed on the EU market are long-lived, recyclable, mainly made of recycled fibres, free of hazardous substances, and produced in respect of social rights and the environment
The main elements of the Strategy will:
- Establish ecodesign criteria to maximise durability and recyclability
- Put an end to wasteful incineration of unsold products
- Introduce key sustainability information requirements and a Digital Product Passport
- Tackle false green claims
- Propose harmonised EU Extended Producer Responsibility rules
5 Key actions for businesses under the Strategy
- Mandatory Ecodesign requirements
Product design plays a key role in extending the life of textile products. This is one of the most effective ways businesses can significantly reduce the environmental and climate impacts of textiles.
The Commission has proposed the Ecodesign for Sustainable Products Regulation (ESPR) that will include binding product-specific ecodesign requirements for textile products in order to:
- Increase textiles durability, reusability, reparability, fibre-to-fibre recyclability
- Establish mandatory recycled fibre content
- Minimise and track the presence of substances of concern and to reduce the adverse impacts on climate and the environment.
Under this regulation specific attention will be paid to the cost-effectiveness and affordability of textiles. The Commission also aims to introduce mandatory criteria for businesses on green public procurement, the scope of which will be defined following an impact assessment, as well as incentives concerning textile products.
As the ESPR is currently subject to approval by the co-legislators and an impact assessment, existing voluntary ecodesign schemes could serve as a reference for the textiles sector until the final requirements are specified. For example, the EU Ecolabel criteria for Textile Products and the EU GPP criteria for textiles products and services, already include environmental requirements such as criteria for sustainable sourcing of fibres, durability, hazardous chemicals restrictions.
- Stopping the destruction of unsold textiles
Businesses that destroy unsold or returned textile products waste value and resources. Under the ESPR the Commission has proposed 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. This will open businesses up to consumer and NGO scrutiny, which will pose significant reputational risks and opportunities. Additionally, The Commission will also introduce bans on the destruction of unsold products.
- Introducing information requirements and a Digital Product Passport
Clear, structured and accessible information on the environmental sustainability characteristics of products empowers businesses and consumers to make better choices and improves communication between actors along value chains. This level of transparency boosts the credibility of sustainable companies and products.
As part of the measures under the ESPR, the Commission will introduce a Digital Product Passport for textiles based on mandatory information requirements on circularity and other key environmental aspects. To ensure consistency with this new piece of legislation, the Commission will also review the Textile Labelling Regulation, which requires textiles sold on the EU market to carry a label clearly identifying the fibre composition and indicating any non-textile parts of animal origin to include sustainability and circularity parameters.
- Green claims for truly sustainable textiles
Consumers willing to purchase more sustainable products are often discouraged from buying them due to the unreliability of claims. Brands including Nike, H&M and Zara have been called out by NGOs and consumers for greenwashing and making false claims about their products.
The Commission proposes to amend the Unfair Commercial Practices Directive and the Consumer Rights Directive to ensure consumers are given information confirming a commercial guarantee of durability as well as information relevant to repair, including a reparability score.
Additionally general environmental claims (e.g., “green”, “good for the environment”) will only be allowed if underpinned by recognised excellence in environmental performance, based on the EU Ecolabel, Type I eco-labels, or specific EU legislation on claims. Alongside this the Commission is continuing to work on minimum criteria for all types of environmental claims in the context of the Green Claims Initiative, which will be presented in the second half of 2022.
- Extended producer responsibility
Making producers responsible for the waste that their products create is essential to decouple textile waste generation from the growth of the sector. Extended producer responsibility (EPR) requirements have proven to be effective in improving separate waste collection and its management in line with the waste hierarchy. EPR can incentivise product design that promotes circularity throughout the material lifecycle and takes account of the end of products’ life. If you would like to read more about how EPR operates and existing schemes, please read my piece on Future of textiles regulation.
The Commission will propose harmonised EU EPR rules for textiles with eco-modulation of fees, as part of the forthcoming revision of the Waste Framework Directive in 2023. The key objective will be to create an economy for collection, sorting, reuse, preparation for reuse and recycling, as well as incentives for producers and brands to ensure that their products are designed in respect of circularity principles.
Upcoming key dates
Next steps for your business
Businesses need to consider a variety of approaches as there is no silver bullet solution. Consumers, investors, and the Commission will continue to push the transition to a circular economy. Although this may appear daunting, taking time now to understand how the Strategy will affect your business allows time to prepare and develop a proactive approach. For all textile producers this is an opportunity to develop your business by improving durability and design, establishing take-back schemes and repair services, and exploring innovations in fibre-to-fibre recycling.
At Sancroft, our services are tailored to our clients’ needs. We support businesses in navigating incoming regulatory changes. This can be through helping create a textile waste strategy or developing a take-back schemes to ensure you are poised to minimise costs.
If you would like to find out how we provide bespoke expert sustainability guidance to your business, please contact Erika.Furbert@sancroft.com or Felix.Gummer@Sancroft.com.
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