Feedback on the Sustainable Products Initiative (EU)

Kirsi Laitala and Ingun Grimstad Klepp have submitted feedback on the Ecodesign for Sustainable Products Regulation proposal on behalf of Consumption Research Norway. In the following, you can read the introduction. Click this link to read the whole feedback document ( The clothing research group also sent feedback on the Sustainable textiles strategy to Miljødirektoratet (under the Ministry of Climate and Environment), click here to read the feedback.

Feedback from Consumption Research Norway (SIFO)

Consumption Research Norway (SIFO) would like to thank the European Commission for the opportunity to give feedback on the Ecodesign for Sustainable Products Regulation proposal.
Our feedback concerns textiles that are very complex products, socially, aesthetically, functionally, and technically. The main problem lies in overproduction, and therefore setting requirements for eco-design can have unintended effects. For example, when setting criteria for more physically durable clothing, longer-lasting products will first and foremost contribute to greater accumulations and when they are discarded, they still retain the potential useful lifespan. Only about 37% of garments are disposed of because they are worn out or broken. Therefore, it is important that the directive also takes into consideration the other design aspects that impact length of product lifespans, such as changes in fashion, and poor fit of garments.

EU policy places great responsibility on consumers to bring about the reductions in environmental impact by choosing the least polluting products. However, within clothing, the difference in environmental impact between products is not large enough, and secondly, there is a lack of reliable information available about these differences. There are no «sustainable clothes» – rather there is rampant overproduction. The main problem is related to the quantity and not to the individual items.
In connection with product passports for textiles, access to information about production year will ensure a greater opportunity for consumers, authorities, and the waste industry to map how long things are used and last. The fiber labeling should also be updated to include information about the content of environmentally harmful chemicals.

Most clothes can be mended, and the majority of repairs are quite easy. When they are not repaired, it is usually because they are so cheap that this does not “pay off”, either in terms of using time or money for the repair. Therefore, determining repairability should be connected to the value of garments. Examples of non-repairable clothing include those with non-replaceable batteries or fabrics with Elastane. Elastane in fabrics can make them more durable, but when the Elastane has lost its elasticity, the clothes can no longer be repaired.

We recognize the urgency of building a larger second-hand market and a textile recycling industry in Europe. This will prevent landfill and the export of waste to countries without proper waste management. However, this entails the danger of continued spread of chemicals and materials including plastics. The requirement of using recycled fibers can in some cases lead to products with poorer use properties.
Due to the global overproduction of clothing, there are many products that are not needed or wanted, and that must go away somehow. What are the alternatives if the destruction of unsold consumer products is prohibited? We believe that this problem should be tackled earlier in the value chain, for example by using financial penalties against overproduction/import, measured for example by the number of unsold products, or that are returned, go on sale, or otherwise clearly are not desired.

We wish you all the best with this important work and hope to contribute to that the knowledge of consumption will be used actively in the design of the directive to avoid unintended adverse effects of good intentions.