Feedback delivered on ESPR 2nd milestone

Consumption Research Norway (SIFO) and NICE Fashion have delivered feedback on the Preparatory study on textiles for product policy instruments: Ecodesign, EU Green Public, Procurement EU Ecolabel 2nd milestone. All in all 19 comments were prepared and submitted, after attending a two-day webinar in December 2024, where the 2nd milestone document was introduced.

The submission focuses on issues related to ‘durability’ and ‘repairability’, as these are key concepts from EU’s Joint Research Center, and according to them the main drivers for consumers to keep their apparel for longer. We do not agree with this, and have argued why in the feedback. The idea that Duration of Service can be predicted at the start of a product’s lifetime, is one of the things we argue against, and our recommendation is, as we have repeated often, to immediately start dating products, and use waste audits, or even better, SIFO’s new method to capture relationship between properties and use (more information on the method here clothingresearch.oslomet.no).

There are several other points we make, around issues such as PEFCRs, replacement, environmental impact, aggressive marketing, and volumes; and we hope this will be helpful in the work moving forward. We would wish that JRC took more of a consumer perspective, than an industry perspective in their future work on ESPR for textiles and apparel.

To read our feedback, you can download a pdf of our 19 comments here, each comment starts with where in the 2nd milestone the wording or issue we address is, as this was required in the feedback.

ECOBALYSE feedback delivered

SIFO has actively contributed with feedback to EU’s Textile Strategy, including on PEFCR, ESPR, the Waste Framework directive, etc. and also – as ECOBALYSE is based on much of the same background data – decided to deliver feedback on the French proposition.

In the feedback, we commend the French government, ADEME and ECOBALYSE is genuinely wanting to halt Fast Fashion (FF) and putting forward legislation that aims to do exactly this. However, we believe that something must be done about the fact that the tool underpinning the labelling scheme currently favors plastics. We are concerned that a labeling scheme which is intended to show what products are better for the environment, ends up supporting FF by promoting the continued plastification of apparel and footwear.

It is also commendable that ECOBALYSE includes an operationalized definition of Fast and Ultra Fast Fashion. Both the use of price and length of market presence are good indicators. For the length of time a product is on the market, we are, however, a bit confused by the longest and shortest intervals, and thereby that everything above and below 65 and 300 days, flats out.

We also have supplied some concrete suggestions, which you can read about in the feedback, which you will find here.

New consultation on PEF: Feedback delivered

We have submitted feedback for the Product Environmental Footprint Category Rules. A total of 355 responses have been submitted with a total of 5125 comments. You had to fill in an Excel form, which was a bit challenging to navigate. We have therefore extracted the answers from the Excel sheet and created a document that is easier to read, click here.

PEF is intended to be used for all products, but this consultation concerns clothing and footwear. The aim has been a label for everything put on the European market, but the plan has been scaled down to a tool that will “only” be used to document green claims. The calculation tool itself, however, is the same. Products put on the market can be compared with a “normal” product in the same category. 13 categories have been created to cover all types of clothing and shoes.

The only of these categories where fiber or material is mentioned are under sweaters, where wool is mentioned (but not alpaca) and jackets/coats, which include leather jackets. For each of these “phantom garments” what is measured and weighted is very different, and this makes it hard to understand what you are actually comparing against. For example, “land use” (how many kilograms of fiber you get per square meter) is the most important factor for sweaters and “midlayers”, not for any of the other product groups. What the logic is for this, is impossible to find out in the many and long background documents.

Stumbling blocks

The consultation process itself has been anything but democratic, with stumbling blocks on all levels. Just getting into the EU database to deliver a response has been difficult without a black belt in passwords and apps, and as mentioned, you had to read hundreds of pages of background material and refer to exactly which document, which chapter and which line was being addressed. But perhaps the worst thing is that the documents don’t really say what the result of all the various data-inputs will actually be. Before we submitted the response, everyone could participate in a webinar where we were told that, for example, complaining about microplastics not being included would fall on deaf ears because the very tool underpinning PEF (LCAs) do not allow any new parameters to be added.

So even though the EU Commission had instructed the working group working with PEF for clothing and shoes to include the problems surrounding microplastics, we were told that there was no point in pointing out the obvious weakness that this has not been done. The fact that one can voluntarily say something in the product information about microfibres (not microplasics specifically) does not solve this major problem.

Understanding the functional unit

Another problem is the weak understanding of the functional unity. This is the very foundation of LCAs, for them to provide meaningful information. This means that the thick, warm Devold sweater that you wear all winter in Norwegian wool will be a true environmental disaster (Norwegian sheep take up an incredible amount of space when they graze) compared to the thin acrylic sweater that you bought on sale and are considering throwing away having discovered that you get an electric shock every time you pull it over your head. How long and how much clothing is worn is important for the environmental impacts in an LCA, but here too PEF falls short. This is particularly where we at SIFO have contributed to bring out knowledge and methods that can be used to correct this. Read more here.

Biodiversity does not count either, which the sheep contribute to in the grazed rangelands. Nor that they contribute to carbon storage in the soil. All that counts are the negatives, even when in the case of land use, the wide space is actually a positive! In connection with the consultation, there are many small producers of wool and other natural fibers who have responded, because they are scared that their livelihood will be evaluated as “red”, not “green”. The question then is whether the EU will listen, or whether they plan to override common sense and the need to reduce actual environmental impacts, and still introduce PEF for clothing and footwear to show action and justify all the time and resources that have been spent to develop the system.

SIFO has delivered a response. Let’s hope it helps.

Feedback delivered on ESPR 1st milestone

EU’s Joint Research Center (JRC) has asked for contributions to the survey ‘Comments to the working document: Preparatory study on textiles for product policy instruments – 1st milestone‘. During March 18th – 19th, the JRC and registered stakeholders attended the online consultation about the 1st milestone of the preparatory study on textile products.

This is the second contribution related to ESPR (Ecodesign for Sustainable Products Regulation), and our first contribution can be accessed by clicking here.

The consultation process is meant to enable the JRC to improve the work under development and the exchange with registered stakeholders aims to:

–          verify the work done to date, and

–          collect additional evidence on the investigated topics.

Throughout the whole process, registered stakeholders are invited to provide evidence relevant within the framework of the preparatory study for textile products. Consumption Research Norway has therefore risen to the task, and our contribution can be accessed and downloaded here.

As part of the team working on this, Tone Tobiasson also delivered a separate comment via email to JRC directly, which can be accessed by clicking here.

New method to capture relationship between properties and use

Waste audit interviews: A method for understanding the link between intrinsic quality and apparel lifespans, is the latest publication from Consumption Research Norway SIFO at Oslo Metropolitan University, co-authored by Kirsi Laitala and Ingun Grimstad Klepp.

New proposed regulation of clothing and textiles in the EU necessitate a deeper understanding of the products, encompassing their usage patterns, duration of use, and strategies for prolonging their lifespan and enhancing utilization rates. SIFO has therefore developed a new method for this purpose, and are simultaneously asking for funding to do studies based on the method, in order to guide the regulation processes for clothing and textiles.

The method is based on the many years of research in this sector, pioneered through wardrobe studies, and lately enhanced by waste audits of different waste streams. The former method is extremely rich in data-collection, but very costly; the latter captures data by casting the net wider, but with less detail about how long the service life has been. Further, the method connects the real use of clothing with results measured in a laboratory related to physical durability. This approach shows that it is feasible to measure the use phase objectively, something policy makers, the industry and research organizations advising policy have so far deemed to be “difficult” or “impossible”.

This note gives an overview of the method and the project proposal, with a rough budget estimate.

The note can be accessed and downloaded here.

EU wants data on textile waste, and we have the answer

Text by Tone Skårdal Tobiasson

The proposal for the Waste Framework Directive, which is currently being read and analyzed by a myriad of companies, NGOs, researchers, policy-makers and interested citizens throughout Europe, handles two major consumer ‘goods’: Textiles and food. We are mainly concerned with the former, however, we have found that food offers us two good guiding principles.

The first one is to eat up what is on your plate. The second is waste audits as a means to gain meaningful knowledge on what gets “eaten up” and what doesn’t. In three separate documents, we ask the EU to heed these two guiding principles and apply them to apparel and other textiles.

One of the documents is our feedback on the textile part of the Waste Framework Directive (read the document here), where the authors have concrete recommendations for ensuring that the policy measures in the WFD can actually contribute to the EU’s ambition of putting fast fashion out of fashion. Currently, the Duration of Service is what is lacking in the available data (how long apparel has been in use and to what level the apparel and textile waste is ‘used up’ ), but even if the background document (#4) states “There is currently no sound method of estimating textile waste (collected and discarded in mixed municipal waste)”, this is just not true. And the two other papers elaborate on exactly this point. Waste audits/waste composition studies – which are very much used when gaining data on food waste – and wardrobe studies – are well-developed methods.

The document Status for developing methods for using waste as a resource for knowledge about the use phase of clothing (read the document here), offers an overview of exactly the current status for these methods, while the document USED, BUT NOT USED UP: Using textile waste to inform textile rating schemes (read the document here) explores how the data-collection methodology using waste audits can underpin several policy measures, such as the Product Environmental Footprint Category Rules, Ecodesign for Sustainable Products Regulation (ESPR), Labelling and Digital Product Passport (DPP), the Green claims directive, as well as EPR and the WFD. We have called the ongoing waste audit method for Targeted Producer Responsibility (TPR), as we originally saw it as a more effective means for levelling a EPR fee, using the Duration of Service as the measuring stick. However, we also now have realized that taking the waste as the point of departure, has many other ramifications that can be leveraged.

The cut-off point for feedback to the WFD keeps being postponed, but we encourage everyone to respond, as a functioning EPR scheme which actually takes the waste hierarchy seriously, can be reality, if we use waste audits as the basis for eco-modulating the fee. What we urgently need is for companies to add the date of production or when the product goes to market to the brand label. Then we can look both upstream, and downstream, from the time apparel and other textiles enter the different waste streams.

Ecodesign position paper: Textiles and footwear

In a position paper from the Change and Wasted Textile projects, authors Kate Fletcher, Irene Maldini, Ingun Grimstad Klepp, Kirsi Laitala, Jens Måge and Tone Skårdal Tobiasson have addressed the background document from EU’s Joint Research Centre on Ecodesign for Sustainable Products Regulation (ESPR).

The main theme in the position paper, is that the JRC document Preliminary study on new product priorities lays the basis to increase environmental burdens rather than reduce these. Therefore, in the paper, the authors ask that the work with the ESPR incorporates more empirical understanding about ecodesign, clothing consumption, and textile and fashion design. This in order that the directive will have the effect of reduced environmental burdens (including on climate) and will minimize inappropriate or unintended side effects.

The aim in writing the paper is to support the ESPR process for textiles and footwear in fostering deep and lasting environmental change.

The authors applaud the efforts of the EU in regulating the textile and footwear sector and agree in the priority that has been assigned to clothing and footwear on the bases of high consumption volumes in the EU, potential environmental improvements, and lack of previous regulation. However, it is the view of the authors that the current work with the Ecodesign Directive is based on some assumptions that are not in line with the knowledge that is there, nor is it targeted towards the main and interconnected challenges in clothing and textiles: overproduction and the increasing plasticization of the material content of products.

These two factors are interconnected due to the fact that an increase in production is not possible without the cheap, easily available fossil fuel-based raw material for fibres, materials, dyes and other processing chemicals.

It is therefore questionable whether textiles and footwear should actually be the initial priority for ESPR. Perhaps starting with cement would be better.

Questions related to the TPR proposal

The Wasted Textiles team have had many meetings with policy-makers, politicians, NGOs, textile industry representatives and other interested parties regarding our Targeted Producer Responsibility proposal. We have collected questions we have been asked and here you will find the answers to these questions. If you have other questions, feel free to send them to us, and we will answer them as best we can, and make them publicly available.  

Q: How to obtain knowledge about the lifespan of textiles?

A:   Lifetime can be measured in number of years, or the number of times something is used. The proposal is to use the length of the use phase as the most important criterion. We propose that the brand and date of production/import will be made mandatory in the future legislation. In the long term, it will then be possible to measure how long the usage phase is on average per brand. We will also be able to say something about the number of uses. The clothes that have not been used will usually be recognizable, and likewise, clothes that have been used until they are worn out. The main method of TPR will be waste analyses and it is possible to do the analyses of the life span in different ways, also related to the type of textile.

Q: Is it only the quantity and age of the textiles in the waste stream that determine the size of the fee?

A: Our proposal is that the quantity and age of discarded textiles shall determine the fee together with the cost of capturing the End of Life (EoL) value for the products. This means that textiles with a high price on the second-hand market, or based on their material composition are a resource for recycling, will have a lower price or even not generate a fee at all, in accordance with the “polluter pays” principle.

Q: How to guarantee that the product carries information about the garment and the brand?

A: The rules today safeguard this to a certain extent, as the labels or the printed information need to withstand a certain number of laundry cycles. It is often also possible to determine the brand by visible logos or because the clothes are recognizable for other reasons. In practice, some will be unidentifiable, but as the sample pick analysis will give representative numbers, this is not the biggest hurdle. There will be enough waste to make statistical and significant compilations.

Q: With the Digital Product Passport (DPP) work underway to update the rules on what information is mandatory on textiles, is it premature to require that the date of manufacture (or date of placing on the market) must already appear on the label?

A: No. There can be interim solutions on the way to a product passport, and as picking analysis is a known method to gather data from waste streams, this is vital in order to quickly assess how long products have been in use before they are discarded. It is possible to analyse the age of clothes in the waste streams without dating the clothes, but dating will give better accuracy and make the analyses easier. In addition, the dating of clothes will have a number of positive effects for consumers, such as giving consumers a greater opportunity to compare the technical quality of the clothes and determine how long they have been in use. This will strengthen the right to complain which is linked directly to the number of years, thus empowering EU citizens.  It will also be an important link to transparency about production conditions. We, therefore, suggest that product date labelling should be included in the coming revision of the EU Textile Labelling Regulation, independently of EPR/TPR.

Q: Who will do the waste picking analysis?

A: We envision the work being carried out by third-party analysis agencies/research institutions with expertise in picking analyses and apparel, overseen by a public authority to oversee the implementation and ensure transparency.

In the Wasted Textiles project, the analyses are based on a collaboration between an analysis agency, MEPEX, with experience from sorting agents for other waste streams, researchers with experience with textiles, and the largest charity in Norway, along with Consumption Research Norway (SIFO)’s experience with different versions of wardrobe methods. Collectively, a method has been developed to look at the composition of the textile waste. Based on this work, it will be possible to further develop a method that meets the specific requirements of an EPR/TPR system.

Q: How to estimate how old a garment is by looking at waste streams or reuse collection streams?

A: Unused clothes are generally recognized by the fact that they have price tags on them, or that they are found in large quantities of similar clothes (unsold). Age can otherwise be assessed based on style, technical details and wear-and-tear. We are not talking about detailed information, but about broad assessments. Textile waste today consists of textiles produced over many decades and there have been technological and aesthetic changes in apparel over the past 50 years, although apparel has not changed as quickly as e.g., electronics. Accuracy will of course be easier when the date becomes a mandatory part of labelling textiles. Accuracy will also be better if the staff who carry out the analysis have the appropriate textile expertise.

Q: What are the criteria for a TPR fee?      

A: TPR can be used and combined with different varieties of EPR and other political instruments. If it is to have the effect of reducing overproduction and making fast fashion out of fashion, then it depends on the fee being high enough to affect the producers, their business models and downstream decisions. However, it is not the size of the fee that distinguishes TPR from other EPR systems, but the way it is calculated.

Producers would pay different levels of EPR fees depending on:

  • How old the clothing is when going out of use (very old clothing generates no fee, while very new would generate a high fee)
  • How reusable/recyclable the clothing is (clothing types with profitable pathways have a low fee)

TPR will ensure a level playing field for a European-based textile industry, global brands and online producers, so-called ultra-fast-fashion brands.  TPR will catch all textile waste, regardless of where the garment was made or imported from, thus addressing the challenge of online trade/e-commerce and “free-riders”. Further work is needed on the details of how the fees are calculated for each individual producer, for specific product groups or for the industry as a whole.   

Q: Can picking analysis actually underpin the legal validity of fees?

A: The legal foundation, implications and further development of TPR are in the current EU Waste Framework Directive, and in the coming revisions. The current WFD (article 8a) defines minimum requirements for member states and their EPR-systems, f. ex. stating that eco-modulation shall be used when it is possible. But until now we have not seen eco-modulation being used in accordance with the waste hierarchy, nor the polluter pays-principle, when it comes to irresponsible production and consumption, and its waste export, and there are limitations in the current directive when it comes to setting fees that go beyond the waste phase. The EU textile strategy from March 2022 announced that there will be a harmonised producer responsibility in the EU set forth in the coming revisions.

We will rely on legal experts and funding for further work with the legal aspects of TPR. It is likely that the retroactive aspect will be contended. If producers are held responsible for the waste they have produced long before the scheme comes into effect, they will balk. It will, however, only be a temporary problem. It is also possible to use TPR combined with sales/import statistics, so that TPR is used to modulate the fee, but that it is based on the imports/production taking place at the same time. We consider it unlikely that the analysis of the waste itself would not be reliable enough. Picking analyses are used on other waste streams and is a recognized method.

Q: Will TPR be costly to operate?

A: The costs of operating the scheme will be covered by the fee, as is normal for other control schemes for industries. TPR is based on national samples taken annually or every two years, and is assumed to be administered at low cost.

For TPR to work (reduce quantities and thus environmental burdens) it is important that the fees are high enough. This will provide money that can be used for, among other things, the operation of the system. In existing EPR-schemes the fees are often set very low so that there is little room for covering other than minimum administrative costs.

In general, there is too little waste regulation supervision and with many new EU regulations to be followed up, it is necessary to strengthen supervision on national and municipal levels. The knowledge that the picking analysis will provide is important data for monitoring the effect of the EU’s textile strategy and for making the best possible use of textile waste. It is difficult to imagine effective policy and product development without knowledge of the waste.

Q: How can we trust those who will be doing the picking analysis, that the data they collect is good enough to eco-modulate fees based on the findings?

A: In contrast to much environmental work, TPR is not based on information provided by the actors themselves, but by an independent third party with no financial interests in the matter. Why should a research or analysis agency not be trusted? It is, after all, common to use a third party to obtain information precisely to ensure independence. A major problem in the textile industry is that concepts, perspectives and what is perceived as knowledge are often produced by the industry itself and its organisations. Selective analyses, on the other hand, can be carried out by independent analysis agencies/researchers.

Q: Will TPR affect companies that want to invest in circular business models and charities that are dependent on revenues from second-hand trade?

A: Circular BMs, such as repair, rental, etc. are struggling financially today due to the competition with cheap new clothes. By making it more expensive to sell what hardly gets used, the over-production will be impacted and eventually reduced (provided the fee is high enough). This will strengthen the possibility for such BMs. The companies that work with further processing of textile waste (repair, redesign, recycling and all intermediate forms) will be able to receive financial help for product development and support from the EPR system and this subsidy will improve their financial sustainability.

Q: In the EU, 99,9% of the actors in the textile sector are SMEs. How will TPR capture meaningful data about them, and ensure that they are not treated unfairly?

A: For once, we are lucky that the fashion and sports apparel sector are dominated by big, global companies with large volumes. This means that they will dominate in the picking analysis.

Q: How will the collected fees be allocated and used?

A: The allocation of the fee has not been elaborated in the proposal for a TPR system. However, we believe that it is important that the TPR funds will be allocated to support as a minimum (non-exhaustive list):

  • operation of the system (incl. picking analysis and calculations, the logistics)
  • support proper use of collected textiles according to the waste hierarchy, incl. charities, markets for reuse and repair
  • support the work with reducing synthetic textiles, preventing the spread of microplastics and cleaning up the textile waste in developing countries
  • support municipalities that need to build up collection, sorting and treatment facilities
  • support countries, regions, businesses and NGOs in the global south in cleaning clean up landfills and rivers and establish functioning waste management systems
  • stimulate technology innovation, research, development and investments

Q: Can TPR be useful for other policy measures than EPR? 

A: TPR is a way of “capturing” the use phase, which otherwise remains a “black hole” in LCAs. In other words, a very important factor for calculating environmental impact in the whole lifecycle of a product, is not taken into account. TPR will make a valuable contribution to gathering meaningful data – and thus can have an impact on many policy measures, especially the ones based on LCA data.

Q: The EU Textile strategy aims for durable, repairable, recyclable apparel and footwear, that also contains recycled content – does TPR contribute to this, or is it counter to these aims?

A: TPR will contribute by bringing forward knowledge and data on how effective these aims are in delivering on the issues around durability. Through the picking analysis it is possible to collect various information on discarded or donated products, i.e., if the discarded or donated items have been repaired, or other relevant information related to the Textile Strategy aims.

Q: Does the TPR have the potential to address just transition, more local value-chains, eco-design and other issues that the EU are addressing through other strategies and programs?

A: The results from the picking analysis will feed into eco-modulation, and be the opposite of traditional eco-design, which only projects assumptions on lifespan. The data collected will be ‘proof of the pudding’ on what actually has a long lifespan, and cancel part of the eco-design directive, through providing actual data and incentives for making lasting products. TPR will use the market forces, and let the companies themselves decide how they tackle this, but make it costly to make products nobody wants.  This will be valuable for the New European Bauhaus. We also see synergies for Farm to Fork, the EU’s new Soil Mission, and other programs and strategies, for example, the Plastic strategy. We know the EU aims for a more holistic, non-siloed way forward, and TPR offers an opportunity for this, based on how to award apparel that stays in use for a long time (indigenous, traditional, local, etc.) up against low-quality products that have a very short lifespan.

Q: How will TPR help to phase out fast fashion?

A: If the fees are high enough to deter the increased plastification of our wardrobes and for clothing that we keep, use and love for a long time, to be awarded amnesty, then TPR will help phase out fast fashion.

Q: How will this affect the developing countries, who rely on second-hand clothes from the EU and the trade of these clothes?

A: TPR has the potential to affect developing countries in two ways. Firstly, the TPR fee should address the issue of waste colonialism, i.e., quantities of textile waste exported (as mentioned earlier in the paper but needs further study for concrete proposals).

Secondly, in line with the EU’s strategic goal to handle its own textile waste rather than exporting it to the Global South, TRP will indirectly affect this export in the long run, through the expected reduction of fast fashion and the volumes being exported.

TPR is also an opportunity for EPR to reduce quantities imported into the EU and thus if the fee is set high enough, it will affect the quantities that go out of use and thus what is exported to developing countries. This is very important, as it is the Global North that creates the major waste problems, which has been recently documented by EEA, Changing Markets Foundation and The OR Foundation. TPR’s goal is to affect the quantities being produced (fast fashion) and exported as waste and thus reduce negative environmental impacts and the related problems in production, use and disposal. These are environmental problems that particularly affect developing countries in that both the production takes place there and that the waste ends up there.

Q: Can TPR be used in other product areas?

A: Yes. That is a good idea to explore. As far as we know, there are no similar systems for other product groups; however, many products are sold with dates and also information on expected lifespan, which is a good basis for developing a TPR system. It would be possible to install a counter in f. ex. a laundry machine or coffee maker, so that the fee is not only based on years of use, but also laundry cycles or coffee-pots made. Using both years of service life and other available information in the modulation of the fee will contribute to more durable products for many product categories.

See the full briefing paper that was sent to the EU representatives below.

New briefing outlining research behind the TPR proposal

During a meeting earlier this year with a team from the European Commission Executive Vice-President for the European Green Deal, Frans Timmermans’ office, the authors of this new paper were asked to supply more background on the Targeted Producer Responsibility they presented.

As the first step in supplying more research-based data and knowledge, the paper entitled “Critical review of Product Environmental Footprint (PEF): Why PEF currently favors synthetic textiles (plastics)” and therefore also fast fashion was sent to the meeting-participants and published online. This was, however, only the first of three papers promised. The second, “Research input for policy development based on understanding of clothing consumption“, a research briefing, goes into the research behind the proposal. It is now sent to the meeting participants and is therefore also made publicly available.

For this research briefing, additional researchers who are not part of the Wasted Textiles project were engaged, and who have also recently been recruited to roles at SIFO: Kate Fletcher and Irene Maldini. Authors from Wasted Textiles are Lisbeth Løvbak Berg (SIFO, OsloMet), Tone Skårdal Tobiasson (NICE Fashion/UCRF), Jens Måge (Norwegian Waste Management and Recycling Association). Kerli Kant Hvass (Revaluate/Aalborg University); and of course, the main author Ingun Grimstad Klepp.

This briefing paper builds on research and evidence from SIFO’s 75 years of consumer research on clothing and the ongoing projects CHANGE, Lasting as well as the mentioned Wasted Textiles, addressing the problem of overproduction of textiles. It draws attention to the importance of incorporating the latest consumer research in the design of Extended Producer Responsibility (EPR) – or rather our suggestion TPR – and other textile policies currently being developed in the EU. It is written by a diverse group of academics and practitioners who are seeking to support change in the sector.

The briefing puts forward that the authors see a trend in various policy discussions and documents based on the belief that making garments more durable, will reduce the quantity of clothing produced. Scientific research does not provide evidence for this, which is exactly what this briefing aims to show. The briefing is, however, not only a criticism of the lack of research-based policy tools. The authors also offer suggestions on how to make these tools effective in the challenge that lies ahead of us: Making fast fashion out of fashion.

Read the full briefing below.

Critical background paper on PEF for apparel and footwear

This week saw the publication of a critical background paper on concerns surrounding the Product Environmental Footprint Category Rules for Apparel and Footwear from a consortium representing the collaborative international research project Wasted Textiles at Consumption Research Norway SIFO at Oslo Metropolitan University.

The consortium were asked to supply more background information to the EU Commission after a knowledge sharing meeting January 25 hosted by Vice President Timmermans cabinet members and other EU officials from both DG Grow and DG Environment involved in the execution of the EU Textiles strategy, the revision of the Waste Framework Directive, and other Green Deal related policies.

As the first step in supplying more research-based data and knowledge, the paper entitled CRITICAL REVIEW OF PRODUCT ENVIRONMENTAL FOOTPRINT (PEF): WHY PEF CURRENTLY FAVORS SYNTHETIC TEXTILES (PLASTICS) AND THEREFORE ALSO FAST FASHION was sent to the meeting-participants this week, and the authors have decided to make the paper publicly available through the Clothing Research website, and can be accessed at the bottom of this page.

During the meeting, which was mainly about Extended Producer Responsibility, Professor in Clothing and Sustainability at Consumption Research Norway SIFO at Oslo Metropolitan University, Ingun Grimstad Klepp, brought up concerns surrounding PEF and PEFCR that could be addressed with the right policy measures to ensure better data collection for the use- and end-of-use phase. These concerns are based on research from three longitudinal research projects at SIFO (Wasted Textiles, CHANGE and Lasting), under the auspices of the Clothing Research umbrella. This research was what led to the meeting with several EU officials, who were all genuinely interested in how academic research can contribute to better policy measures.

Four of the authors, from left to right: Jens Måge, Ingun Grimstad Klepp, Tone Skårdal Tobiasson and Kerli Kant Hvass.

This paper is the first in a series of three that will be delivered to the participants of the meeting and will be made available on this website, related to EU’s textile strategy. The research consortium behind the critical papers, welcome EU’s ambitious strategy for apparel and footwear; however, the same research consortium sees that unless one takes a holistic view which includes the use and disposal of products, with a view from what actually ends up in the waste and how quickly – true sustainability-measures are in danger of supplying misleading information. By capturing this research and making it available, it is possible to spur policy measures that address the issue of over-production head on.

In conclusion, the paper states: “In essence, one can therefore say that PEFCR for clothing favors plastic due to a lack of political decisiveness on how to measure natural versus synthetic materials, together with giving the FF (fast fashion) industry power in the development of PEFCR and choice of underlying data. Fast fashion will remain in fashion if those who have the most to gain from it are making the rules.” The first critical paper is authored by Ingun Grimstad Klepp, Kirsi Laitala, Lisbeth Løvbak Berg (all SIFO, OsloMet), Tone Skårdal Tobiasson (NICE Fashion/UCRF), Jens Måge (Norwegian Waste Management and Recycling Association) and Kerli Kant Hvass (Revaluate/Aalborg University).

The SIFO Clothing Research team who are all co-authors: Kirsi Laitala, Lisbeth Løvbak Berg and Ingun Grimstad Klepp.