23 Dec 2019
Mix of Voluntary and Mandatory Legislative Proposals for Sustainable Textiles Put Forward by European Body
Earlier this month, The European Centre for Development Policy Management (ECDPM), an independent think tank, published a discussion paper titled “Sewing the pieces together: Towards an EU strategy for fair and sustainable textiles”. The paper sets out a mix of useful options and suggestions for an integrated EU strategy in support of sustainable textile value chains. It points out that the EU institutions, including the European Commission among other stakeholders, have a key role to play in actually delivering on measures that have an impact on the textile supply chain. The paper’s publication comes at the right time, given that the European Commission’s plan for a Green Deal was published only two days later.
The ECDPM paper notes that, at the European level, there is an increasing recognition of the responsibility of importers, brands, retailers and even customers to address the social and environmental issues associated with textiles. A few initiatives have arisen within Europe covering or including textiles, such as the Dutch Agreement on Sustainable Garments and Textile, and the German Partnership for Sustainable Textiles. At the EU level, so as to address both consumer-related and environmental challenges, various measures have been introduced, ranging from non-textile specific regulations, such as the directives on waste, packaging waste and landfill under the circular economy package, to voluntary measures, including the EU Ecolabel.
However, it is suggested that a coherent and ambitious EU-wide approach is still lacking. Europe remains a major destination for global textiles due to the size of its market and high per capita consumption rates. This market power can be leveraged to encourage sustainable production practices through coherent EU wide approaches and instruments. Initiatives can be made a part of the European Green Deal, announced by the new European Commission on 11 December 2019.
The paper sets forth a select number of policy options. The term “textiles” refers to all forms of textiles, including clothing, household textiles, automotive and technical textiles.
The ECDPM paper notes that the scope of the EU’s Ecodesign Directive is currently limited to energy-related products, but that this could be expanded to other product categories. The European Parliament resolution on the implementation of the Ecodesign Directive (of 2018) already recommended that the Commission should continue including other product categories to the Directive, based on their ecodesign potential, in terms of both material and energy efficiency, as well as other environmental aspects. Even more recently, Environment Ministers of EU Member States, in their Council conclusions on the circular economy (October 2019), specifically highlighted the potential for developing ecodesign criteria for textiles. This is particularly relevant in the context of the Circular Economy Package which emphasises the need to include circular aspects in future product requirements under the Ecodesign Directive. It also identifies textiles as a key priority area, given its circular economy potential, and acknowledges that no instrument currently exists for setting design and durability criteria for textiles.
A large part of the lifecycle environmental impacts of a product are determined at the design stage. In the case of textiles, this may include material efficiency requirements in terms of durability, recyclability, repairability and reusability, as well as the restriction of some chemicals. Such requirements can potentially extend the lifetime of products and indirectly offset new production, encourage the use of recycled materials in production and possibly alter the washing of such products.
EU law concerning labelling and packaging of products already exists. At present, mandatory labelling for textiles is only limited to fibre names and composition. This labelling requirement is binding on manufacturers and importers throughout the EU, by means of Regulation 1007/2011 on textile fibre names and related labelling and marking of the fibre composition of textile products. The paper suggests that there is a possibility for other labelling requirements to be included in EU legislation in order to influence consumer buying behaviour and use of products. These could be, for example, information on country of origin, chemical substances, wash/care instructions and environmental performance. Such information could possibly be provided through a QR code. The potential for product labelling to effectively influence consumer behaviour depends on the relevance of the information it provides and how such information is perceived by consumers.
Extended Producer Responsibility (EPR)
The European Commission has already adopted an ambitious Circular Economy Package, which includes revised legislative proposals, as part of the so-called waste package, to stimulate Europe's transition towards a circular economy. The revised legislative proposals adopted in 2018 set clear targets for reduction of waste, while establishing an ambitious and credible long-term path for waste management and recycling. The revised Directive on waste also requires, EU-wide, the separate collection of discarded textiles by January 2025. As one of the ways to achieve these targets Member States may need to set up Extended Producer Responsibility schemes (EPR) for textiles.
Until now, only one Member State – France – has set up an EPR scheme for end-of-use clothing, linen and shoes. In effect, all commercial entities placing textile products on the French market are liable to contribute towards the recycling and treatment of textile waste. A main objective of the EPR scheme is to raise resources for the collection, transport and treatment at the end of life of the textile products at issue.
It is also noted that the market for reused textiles is shrinking, which may soon become a cause for concern. Textiles collected through the EPR scheme are either reused as second-hand products, recycled into insulation materials and clothing rags, or end up in the incinerator or landfill. As such, recycling results in products which provide less resource benefits than reused textiles. The “reuse” stream, the most preferred option for textiles recovery, is approximately 65% of overall collected textiles.
The 9 December ECDPM paper sets out other interesting options and suggestions for the sustainability of the textiles market, which can influence the EU’s policy and law makers, especially under the European Green Deal. Hong Kong sellers of clothing and other textile products should expect that some of these will almost certainly be looked into, with a view to eventual implementation across the EU.