The textile sector is still far from achieving its sustainability goals. The commitment to the Paris Agreement, the promised contributions to the Sustainable Development Goals (SDGs), and the Kunming-Montreal Global Biodiversity Framework (GBF) seem distant for the sector.
The European textile industry accounts for 1.5 million jobs spread across 160,000 companies and a total turnover of over 162 billion in 2019. However, at the same time, the sector is also one of the most polluting industries. Approximately eight to ten percent of global CO2 emissions come from the textile industry. Additionally, the immense land, water, and resource use also have a significant impact on biodiversity and the environment. If you want to know which processes in the sector are most polluting, read this article.
Although many efforts have been made over the past decade to improve sustainability and working conditions in the textile industry, many problems are still far from being solved. The root of these problems lies in the linear model in which mass production of clothing at low costs is the norm.
Consumers now have more access to cheap clothing than ever, which encourages overconsumption and creates massive garbage production. Additionally, the lack of attention to quality, reuse, and sustainability during the textile design phase plays an important role. This model of overproduction and consumption puts significant pressure on both people and the environment.
As the largest importer of clothing globally, the EU can use its power to significantly change the industry. Therefore, in May 2023, it launched the EU Strategy for Sustainable and Circular Textiles. A comprehensive plan to make the industry more sustainable and improve working conditions in the supply chain.
What is the EU Strategy for Sustainable and Circular Textiles?
You've probably heard of it, The Green Deal. This large-scale policy program of the European Union aims to address climate change and promote sustainability. It is an ambitious plan consisting of 35 actions initiating a radical transformation of the economy and society with a climate-neutral Europe by 2050 as primary goal.
One of these actions is the Circular Economy Action Plan (CEAP). This plan includes mandating sustainable product design, promoting the circular economy, and addressing waste streams.
To achieve the goals of the Green Deal and the CEAP, the EU has developed a sector-specific strategy, the EU Strategy for Sustainable and Circular Textiles. This strategy is a set of actions addressing sustainability throughout the entire production chain. The objective is to significantly change the entire lifecycle of textile products and shoes. The actions do not only focus on how textile products are made but also on how we use them and eventually dispose of them. Therefore, textiles and shoes must have a longer lifespan, become more recyclable, and contain public information about materials and environmental impacts.
Key actions in the Textiles Strategy
- Set design requirements for textiles to make them last longer, easier to repair and recycle, as well as requirements on minimum recycled content.
- Introduce clearer information and a Digital Product Passport.
- Tackle greenwashing to empower consumers and raise awareness about sustainable fashion.
- Introduce mandatory and harmonised extender Producer Responsibility schemes for textiles with eco-modulation fees.
- Address the unintentional release of microplastics from synthetic textiles.
- Restrict the export of textile waste and promote sustainable textiles globally.
- Incentivise circular business models, inlcuding reuse and repair sectors.
- Encourage companies and Member States to support the objectives of the Strategy.
- Reverse overproduction and overconsumption, and discourage the destruction of unsold or returned textiles.
How is this EU Strategy for Sustainable and Circular Textiles implemented and what can you expect working in the textile business? There are several key EU sustainability regulations and directives that form supporting pillars of the strategy. Note; many of these are general European sustainability regulations and imply for many other industries as well. These overarching regulations have multiple sector specific requirements.
In this article we discuss the four key regulations that have specific requirements and explain how they apply to the European textile industry.
1) The Corporate Sustainability Reporting Directive
2) Ecodesign for Sustainable Products Regulation (ESPR)
3) The Green Claims Directive (GCD)
4) Waste Framework Directive and Regulation on Waste Shipments
Demand for more transparency: The CSRD
First of all we look at the Corporate Sustainability Reporting Directive, abbreviated as CSRD. This directive works closely with the Sustainable Finance Directive and therefore focuses not only on evaluating the financial health of companies but also on their sustainability. The CSRD has various implications for companies in the textile and fashion industry.
The CSRD will standardize ESG reporting (environmental, social impact, and governance) of companies within the EU. This directive requires companies to disclose how they affect the environment, society, and governance (ESG). They must report on CO2 emissions, transparency in supply chains, and labor conditions. These obligations will result in fashion and textile brands coming under increasing scrutiny and accountability, forcing them to develop and implement a sustainability strategy.
What should companies report under the CSRD? Companies must comply with the obligations as set out in the 12 European Standards for Sustainability Reporting (ESRS). These include the following topics: sustainability, social performance and human rights, and governance.
Sustainability:
- Scope 1, 2, and 3 emissions
- Prevention and mitigation strategies
- Emission reduction targets (using the GHG-protocol Corporate Standard)
- Resource use and circularity throughout the supply chain
Social performance and human rights:
- These social reporting obligations apply to both employees and workers along the entire production chain and include:
- Employees
- Human rights
- Diversity policy
Governance and policy:
- Structure, process, and policy affect company decision-making.
- Companies are asked to share their business model, including a sustainability strategy.
- Identification and addressing of sustainability risks
The EU also plans to establish sector-specific obligations, which are expected to also apply to the textile sector. Recently, the EU proposed to move the adoption of these standards from the summer of 2024 to the summer of 2026.
Of course, the CSRD entails a lot of additional reporting obligations. Companies must also have implemented a well-functioning system to collect all data neatly. However, this directive also offers opportunities. For example, improving the transparency of the production chain, making sustainability goals much easier to achieve. This will then increase reliability towards customers and stakeholders.
Do you want to know more about the CSRD? Read our article: The CSRD, everything you need to know.
The Ecodesign for Sustainable Products Regulation (ESPR)
Then there is the Ecodesign for Sustainable Products Regulation, as the name suggests, this directive focuses on product design. The environmental impact of a product is determined to 80% in the design phase, making rules and guidelines about this crucial. The current legislation, called the Ecodesign Directive, previously concerned only electronic products but will now also apply to textiles.
Textile brands operating in the European market will have to consider product design in their production from start to finish. This strongly emphasizes reliability, reusability, improvable-ness, repairability, ease of maintenance, recycling, energy efficiency, and resource efficiency during the textile design process. The establishment of requirements for the ecodesign of textiles will be completed by mid-2025.
An important part of the regulation is the Digital Product Passport (DPP). The DPP must provide consumers and producers with comprehensive product information, making it easier to repair or recycle products, but also to track potentially hazardous substances throughout the entire supply chain. This will have significant consequences for the textile industry.
For all textile products placed on the European market, a DPP will be mandatory. This is a digital report, for example, a QR code, containing all information on how the product came about linked to a unique product ID.
This passport contains information about the circularity of the product, the percentage of recycled materials, and the CO2 footprint. The circularity of a product refers to the extent to which a product is designed and produced with reuse, recycling, and waste minimization in mind. It takes into account the full lifecycle of the product, including the raw materials used, the production processes, the use of the product, and the end of its lifespan.
Two components of the Digital Product Passport are important for fashion and textile brands:
1) The DPP must contain a physical label (such as a QR code) linking to a unique identification. This must be physically present on the product at the time of sale.
The digital dossier of a product must have data from the entire value chain of the product, from manufacturers and importers to repairers and recyclers. This digital dossier is intended for customers and all parties within the value chain.
2) The specifications to be included in the DPP will be published in 2024. When the DPP for textile products will actually become mandatory is not yet clear, but 2025 would be the target date.
The Green Claims Directive (GCD)
In today's market, consumers are bombarded with a plethora of environmental labels all vying to convince them that products are more sustainable and eco-friendly. It's no surprise then that navigating through this abundance of information can feel like trying to find a tree in a forest.
In the EU alone, there are more than 230 ecolabels on the market. Of these, a staggering 53% provide vague, misleading, or unsubstantiated information, and 40% of claims are found to have no supporting evidence. Greenwashing allows misleading information to be presented to consumers. This creates an uneven playing field in the EU market and puts truly sustainable companies at a disadvantage. The Green Claims Directive (GCD) is designed to counteract this.
Promises such as "the ecological footprint of this product has been reduced" must be supported by scientific evidence. Stricter rules also apply to communication about "green claims." For example, total scores of environmental impact may no longer be allowed.
The directive will primarily improve information provision for the textile sector regarding the sustainability and repairability of a product. Claims must be verified by a third party through a standard methodology for a life cycle analysis (LCA).
Waste Framework Directive and Regulation on Waste Shipments
The new EU directive on waste shipments from the Waste Framework Directive was adopted in 2021. The original aim of this directive was to promote a circular economy and ensure that the EU no longer ships its textile waste to developing countries. This also made it easier to transport and recycle waste within the EU, while improved measures were introduced to trace illegal waste shipments.
The Extended Producer Responsibility (EPR) is a policy instrument that has introduced new rules making producers responsible for the entire lifecycle of textile products, from product design to textile waste and recycling. For the textile industry, this means that producers must contribute to the financing of the collection and processing of textile waste, as well as to the promotion of sustainable production and consumption. Each country within the European Union, including the Netherlands, has its own national laws and regulations regarding EPR, which may vary in the details of implementation and enforcement.
In the Netherlands, the Extended Producer Responsibility for Textiles (UPV-Textiel) has been in force as a legal obligation since July 1, 2023. This makes producers and importers of both clothing and household textiles responsible for managing waste streams from their products sold on the Dutch market.
This means that they must ensure an appropriate system for separate collection and its financing. Additionally, they are required to ensure a system of recycling and reuse of collected textiles. The government has set objectives for this: by 2025, 50% of textiles sold on the Dutch market must be recycled/reused, and this percentage must gradually increase to 75% by 2030. Currently, about 35% of textiles are reused and recycled.
With the Regulation on Waste Shipments, the European Commission has proposed an amendment regarding the textile industry. Currently, EPRs are active in various member states. The aim of the new regulation is to bring these together.
This regulation is intended to facilitate sustainable management of textile waste throughout Europe and hold textile producers responsible for the costs of waste disposal. The idea is that if producers bear the costs of waste disposal, they have an incentive to reduce waste and make their products circular. Costs will be determined based on environmental performance through "eco-modulation."
How to comply with EU regulations for textiles?
Be prepared for what is to come! This is the most important advice we can give. What is certain is that clothing and textile brands must have a clear understanding of the environmental impacts of their products throughout their lifecycle to comply with the rules. Measurement leads to knowledge but it also requires a lot of time and effort.
Starting early to set up systems to collect data and meet reporting obligations is therefore of great importance. Then you can face the Strategy for Sustainable and Circular Textiles with confidence!
Hedgehog Company has a team of climate experts and data specialists who are eager to roll up their sleeves to help your company comply with the guidelines. If you have any questions or need tailor-made advice, please contact us via this email address.
