Textile environmental disaster demands stricter policy than what politics currently proposes

With Black Friday and Christmas shopping behind us, we have once again seen many offers pass by. Many clothing brands have also tried to convince us of ‘the best deals’ and ‘the most beautiful Christmas outfits’. However, the (European) textile industry (clothing, footwear and household textiles) has a huge negative impact. After food, housing and mobility, the textile industry is the most damaging to the climate and environment. However, the amount of clothing we consume in Europe has gone up by 40% in recent decades. At the same time, the quality of these clothes has deteriorated rapidly and their composition has changed. A growing share of our clothing consists of synthetic fabrics, such as polyester, acrylic and polyamide. Producing these fabrics requires non-renewable resources such as oil and gas. Currently, the textile industry consumes around 1.35% of global oil consumption. That may not seem like much, but this is more than the entire annual oil consumption of a country like Spain. Other fabrics are also still very damaging to the planet; for example, cotton production requires a lot of land area and water — around 2500 litres for one shirt — and there is a high use of pesticides in the cotton sector (note: this does not apply to organic cotton). Although synthetic fabrics are therefore not the only culprit within the polluting textile industry, their increase is problematic. Because synthetic fabrics are cheaper to produce and because production can be scaled up relatively easily, these fabrics are one of the drivers of fast fashion. Cheap, synthetic clothing is discarded more easily (on average after 7 to 8 wears), breaks faster, and releases large quantities of microplastics. And we are still far from a turnaround: the share of synthetic fabrics is expected to only increase in the coming years (see Figure 1). Figure 1 Global fiber production by type between 1980-2030 Source It is clear that the textile industry is still far from sustainable management of raw materials. Currently, only about 1% of collected textiles is recycled into new textile fibers (see Figure 2). This means that 99% of our textiles end up in the incinerator, on a landfill or elsewhere. In 2015, this amounted to around 500 billion dollars in wasted raw materials. At the same time, the waste pile continues to grow due to cheap fast-fashion, and fiber-to-fiber recycling for synthetic materials is even more difficult than for natural fibers. Figure 2 Global material flows for clothing in 2015 Source Regulation Our textile consumption and the use of virgin raw materials for its production must be drastically reduced, but how? Both in Europe and in the Netherlands, work is being done on a more sustainable approach to textiles. For example, the European strategy for sustainable and circular textiles contains plans to tackle fast-fashion, collect and process discarded textiles better, prevent the destruction of unsold textiles and focus on textiles that last longer, are reusable, repairable and recyclable. This is done, among other things, through the introduction of EPR for textiles, as part of the revision of the Waste Framework Directive. However, experience in other policy areas, such as packaging, shows that turning these (ambitious) ideas into concrete proposals often results in a lower level of ambition than hoped for. EPR textiles in the Netherlands In the Netherlands, too, regulations are being drafted for the textile sector: from 2023, extended producer responsibility (EPR) will apply to textile producers. Due to delayed advice from the Council of State, the implementation has been postponed from 1 January 2023 to later in the year. In this scheme, too, the level of ambition is disappointing. As we wrote last year, the combined targets set for reuse and (fiber-to-fiber) recycling give a distorted picture of the level of ambition, prevention is completely lacking (even though the Waste Framework Directive makes this mandatory) and we now know that the failing governance of EPR systems seriously harms their effectiveness. This was recently confirmed once again when the EPR organisation for packaging sabotaged the timely and proper introduction of deposits on cans. In the advisory report on EPR for textiles published in December by the Council of State (RvS), four main points are addressed: 1) the concrete implementation of the collection and processing of textiles within the EPR, 2) the relationship between the responsibility of producers and other stakeholders, 3) the necessity for the establishment of an EPR to guarantee enforceability, and 4) the measurement point of the targets. The RvS requests the Ministry of Infrastructure and Water Management to make explicit what the "total system of textile collection with the intro

With Black Friday and Christmas shopping behind us, we have once again seen many offers pass by. Many clothing brands have also tried to convince us of ‘the best deals’ and ‘the most beautiful Christmas outfits’. However, the (European) textile industry (clothing, footwear and household textiles) has a huge negative impact. After food, housing and mobility, the textile industry is the most damaging to the climate and environment. However, the amount of clothing we consume in Europe has gone up by 40% in recent decades. At the same time, the quality of these clothes has deteriorated rapidly and their composition has changed. A growing share of our clothing consists of synthetic fabrics, such as polyester, acrylic and polyamide. Producing these fabrics requires non-renewable resources such as oil and gas. Currently, the textile industry consumes around 1.35% of global oil consumption. That may not seem like much, but this is more than the entire annual oil consumption of a country like Spain. Other fabrics are also still very damaging to the planet; for example, cotton production requires a lot of land area and water — around 2500 litres for one shirt — and there is a high use of pesticides in the cotton sector (note: this does not apply to organic cotton).

Although synthetic fabrics are therefore not the only culprit within the polluting textile industry, their increase is problematic. Because synthetic fabrics are cheaper to produce and because production can be scaled up relatively easily, these fabrics are one of the drivers of fast fashion. Cheap, synthetic clothing is discarded more easily (on average after 7 to 8 wears), breaks faster, and releases large quantities of microplastics. And we are still far from a turnaround: the share of synthetic fabrics is expected to only increase in the coming years (see Figure 1).

Figure 1 Global fiber production by type between 1980-2030 Source

It is clear that the textile industry is still far from sustainable management of raw materials. Currently, only about 1% of collected textiles is recycled into new textile fibers (see Figure 2). This means that 99% of our textiles end up in the incinerator, on a landfill or elsewhere. In 2015, this amounted to around 500 billion dollars in wasted raw materials. At the same time, the waste pile continues to grow due to cheap fast-fashion, and fiber-to-fiber recycling for synthetic materials is even more difficult than for natural fibers.

Figure 2 Global material flows for clothing in 2015 Source

Regulation

Our textile consumption and the use of virgin raw materials for its production must be drastically reduced, but how? Both in Europe and in the Netherlands, work is being done on a more sustainable approach to textiles. For example, the European strategy for sustainable and circular textiles contains plans to tackle fast-fashion, collect and process discarded textiles better, prevent the destruction of unsold textiles and focus on textiles that last longer, are reusable, repairable and recyclable. This is done, among other things, through the introduction of EPR for textiles, as part of the revision of the Waste Framework Directive. However, experience in other policy areas, such as packaging, shows that turning these (ambitious) ideas into concrete proposals often results in a lower level of ambition than hoped for.

EPR textiles in the Netherlands

In the Netherlands, too, regulations are being drafted for the textile sector: from 2023, extended producer responsibility (EPR) will apply to textile producers. Due to delayed advice from the Council of State, the implementation has been postponed from 1 January 2023 to later in the year. In this scheme, too, the level of ambition is disappointing. As we wrote last year, the combined targets set for reuse and (fiber-to-fiber) recycling give a distorted picture of the level of ambition, prevention is completely lacking (even though the Waste Framework Directive makes this mandatory) and we now know that the failing governance of EPR systems seriously harms their effectiveness. This was recently confirmed once again when the EPR organisation for packaging sabotaged the timely and proper introduction of deposits on cans.

In the advisory report on EPR for textiles published in December by the Council of State (RvS), four main points are addressed: 1) the concrete implementation of the collection and processing of textiles within the EPR, 2) the relationship between the responsibility of producers and other stakeholders, 3) the necessity for the establishment of an EPR to guarantee enforceability, and 4) the measurement point of the targets.

The RvS requests the Ministry of Infrastructure and Water Management to make explicit what the "total system of textile collection with the introduction of the EPR will look like". Specific attention must be paid to the description of all responsibilities and how they relate to each other. The RvS considers it insufficient to assume that setting legal obligations automatically leads to an effective EPR system. The RvS refers in this regard to Article 8a of the Waste Framework Directive. Although this is an important point, we consider it a missed opportunity that the RvS did not also refer here to Article 8a, paragraph 6 of the Directive, which obliges Member States to provide for a regular dialogue between a wide group of actors involved in an EPR system, including producers, local authorities and civil society organisations. Given the lack of this within current EPR systems, the EPR textiles should include a provision in which this is properly anchored. The lack of that broad dialogue means that EPR organisations primarily represent the interests of producers and, with a lack of transparency, also offer little accountability.

The RvS also proposes to include in the explanatory notes that a producer responsibility organisation (PRO) has been established in a timely manner (at the start of the EPR) because enforceability and feasibility are compromised without a producer organisation. While there is certainly something to be said for a producer organisation simplifying compliance, this ignores the fact that a lack of good governance allows producer organisations to turn into powerful lobby clubs, precisely thanks to legislation. For this reason too, the EPR textiles should set the right framework for the operation of a producer organisation.

Finally, the advisory report addresses the measurement point of the targets. The research report by Rebel Group advises measuring the targets against the number of kilograms of discarded textiles. Yet the Ministry has chosen to ask businesses to report on the kilograms of textiles placed on the market. The RvS points out that the Human Environment and Transport Inspectorate (ILT) indicates in its enforceability assessment that these figures are susceptible to fraud, because producers can potentially manipulate the figures. We have previously indicated that within EPR systems, the government places itself in a position where they are dependent on data supplied by businesses. However, this applies not only to reporting by individual companies, but just as much to producer organisations reporting on behalf of companies.

Initiative proposal D66

Finally, it is worth mentioning the Initiative proposal Clothing - A new design for the clothing industry: from a throwaway society to a circular economy by Kiki Hagen (D66). In this paper, various proposals are made which, according to D66, are necessary for a more sustainable clothing industry. We highlight a few proposals here.

Radical transparency

The proposal states that sustainability claims are often unfounded, making it difficult for consumers to know where they stand. Kiki Hagen's proposal is to set standardised requirements for clothing products, determining what is sustainable and what is not. In addition, information should be made available not only on the sustainability of a specific line (such as H&M's Conscious products), but on the sustainability of the company as a whole. Finally, D66 also proposes an eco-score (similar to the nutri-score), higher fines for greenwashing, and an information obligation for return policies.

RNB believes these proposals would be a big step in the right direction. A lack of transparency in terms of claims, but also in terms of production numbers and material use combined with the pursuit of maximum profit, hinders the transition to a sustainable textile industry.

Broader producer responsibility

To tackle fast fashion, D66 wants producers to be incentivised through EPR systems to redesign their production process. This can be done by increasing the fees that producers pay to EPR organisations for non-sustainable products, by integrating a right to repair, but also by creating a more active role for the central government as a facilitator when it comes to spending funds, and by giving other stakeholders (such as municipalities) more influence and say. The Ecodesign Regulation on which Europe is working also plays an important role. This should look, among other things, at the origin of materials, renewability, the use of pesticides and chemicals, and the phasing out of (non-recycled) fossil materials.

In addition to the above points, the initiative proposal also addresses preventing microplastic pollution and promoting circular chains by providing better support to sustainable frontrunners.

What else is needed?

As an environmental organisation, we are very pleased with the initiative proposal from D66. In addition to the points mentioned above, we believe there is still a lack of a clear plan for product prevention and thus also prevention of virgin raw material use. This applies to both national and international policy and must also be included in the definition of a 'sustainable' item or production process. Sustainability must be measured, among other things, by the extent to which virgin raw materials are avoided. A garment that is not produced, and therefore not bought by the consumer, is ultimately the most sustainable solution. To tackle the failing governance of EPR systems at national and international level, we are committed to:

tackling producer organisations that lobby against environmental policies;

adjusting the governance structure, making various stakeholders (governments, waste processors, environmental organisations) less dependent on PROs;

encouraging national governments to take more control within EPR systems and ensuring they involve a broader group of stakeholders in designing new EPR systems.