Letter sent to the EU Council

Tanja Gotthardsen, a Danish anti-greenwashing specialist, Continual, and member of the advisory board for textiles at the Danish Consumer Council, Forbrugerrådet Tænk, has together with Professor Ingun Grimstad Klepp and Tone S. Tobiasson, penned a letter to the EU Council ahead of their vote on Green Claims Directive.

If the EU’s Green Claims directive is truly to become a silver bullet against greenwashing, it must, first and foremost, avoid contributing to greenwashing, which it stands in danger of doing, as the recent integration of references to the Product Environmental Footprint (PEF) for apparel and footwear (A&F) in the text, makes it possible to use this faulty tool for making green claims.

For us, it’s not a question of fibers or materials, but a question of consumers being misled by a tool of the EU’s own making. And the inclusion of PEF is truly premature, as it does not account for how apparel is actually, functionally worn and used – and use is, by far, the most important indicator for a garments environmental impact.

We therefore wrote in our capacity as researchers, concerned consumers, farmers, textile companies throughout the value chain, and NGOs regarding this potential damaging inclusion of PEF.

In the letter, which you can read here, we address specifically the numerous shortcomings of PEFCRs for A&F, which have been pointed to by many and certainly in the latest open public consultation. As it is far from clear how PEFCRs for A&F will be operationalized and this will be clear at the earliest in Q4 of 2024, we challenge the validity of including PEF as a potential system or tool for making green claims. That it is not mandatory, but still remains an option, is not acceptable as long as its final design is an unknown. 

The letter builds on decades of wardrobe research conducted and policy recommendations provided by SIFO and Continual, as well as many other excellent people. A big thank you goes out to all the wonderful co-signatories from research, civil society and industry, that managed to get back to us so swiftly – this was truly a race against the clock.