New briefing outlining research behind the TPR proposal

tobiasson on 17. March 2023

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.

Research briefing on clothing consumptionDownload
Download the research briefing on clothing consumptionDownload

Critical background paper on PEF for apparel and footwear

tobiasson on 7. February 2023

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.

Background-paper-on-PEFDownload
Critical review of PEFDownload

Double whammy for Clothing Research

tobiasson on 30. January 2023

Two articles from Clothing Research at Consumption Research Norway have been accepted by the journal Fibers and are accessible online. The two articles are entitled Reducing plastic: Opportunities and obstacles for coarser wool in consumer goods and Natural and sustainable? Consumers’ textile fiber preferences.

More than half of the team in the Clothing Research group have contributed to these two chapters: Kirsi Laitala, Anna Schytte Sigaard (author on both articles), Lisbeth Løvbak Berg and Ingun Grimstad Klepp – the article on reducing plastics is co-authored with three from the University of Bielsko-Biala. In the first article, findings are presented that show that on a product level, the many inherent properties of wool create opportunities for product development and sustainability improvements, and that using coarser wool represents an opportunity for replacing plastics in many applications. This was done using a SWOT (Strengths-Weaknesses-Opportunities-Threats) analysis of results from a desktop study and interviews with producers of products made from wool, as well as policy documents relating to wool, waste, textiles, and plastic.

The second article looks at synthetic vs. natural fibers, consumer preferences, their view on sustainability and more importantly, consumers’ willingness to degrow their consumption. Interestingly, not only do Norwegian consumers prefer wool, they also believe that wool is the most sustainable choice of fiber, with polyester being the least. This is the exact opposite of what today’s most common measuring tool, the Higg Material Sustainability Index, tells us.

A snap-shot from the Higg MSI ranking of fibers, the higher the number, the less sustainable.

This article also offers proof that perceptions of high sustainability regarding fibers are negatively correlated with reduced consumption: “Our study suggests that a continued focus on material substitution and other technological measures for reducing climate change will impede the move toward sustainability in the textile sector.” The article raises the very pertinent question of how the perspectives of techno- and eco-centrism impact Norwegian consumers’ fiber preferences and perceptions, and how does this, in turn, affect their clothing consumption?

Technocentric or eco-centric?

On the one hand, green growth aims to de-couple growth in the textile industry from a reliance on virgin materials by keeping already-produced materials in circulation for as long as possible. In contrast to this technocentric perspective, the eco-centric degrowth narrative holds at its core ideas such as scarcity, reduced consumption, and lifestyle sacrifices at a time of shrinking resources for the Global North. “The eco-centric approach does not disregard technology but holds that we cannot rely solely on new and better technology. Instead, it focuses primarily on behavior change and argues that a paradigm shift is necessary to transform conventional fashion production and consumption.”

The respondents showed a high preference for natural fibers, especially wool, which was preferred by 72% of them, followed by cotton (63%), alpaca (38%), organic cotton (34%), linen (30%), silk (23%), bamboo viscose (22%), viscose (10%), and, finally, synthetics at the bottom of the scale, with polyester being preferred by only two percent, followed by recycled polyester (2%) and acrylic (1%). All the natural fibers were more popular than the manmade ones, and out of the manmade fibers, the synthetics were least popular, even recycled polyester. Almost half of the respondents said that they avoided polyester (47%) and acrylic (46%), and 35% avoided even recycled polyester.

Rebound effect?

Fiber preference was positively correlated with reduced clothing consumption, so that those who preferred more natural fibers had reduced their clothing consumption more than those who preferred synthetic fibers, which is interesting. This fits with the eco-centric perspective of degrowth and reduced consumption. However, it seems that believing that a fiber is sustainable, negatively affects consumption reduction. An explanation for this could be that if the fibers used to produce clothing are considered sustainable, reducing consumption is not necessary, which gives a rebound effect that could be seen as counter-productive, from an eco-centric perspective.

Therefore, consumers’ willingness to reduce consumption is important and may be weakened if the focus continues to be on fibers and materials, instead of reduced production and consumption. Read the article here (mdpi.com).

The wool-related article, does, to a certain degree, focus on the raw materials, and replacing one raw material (synthetic) with a natural fiber. To investigate the use of coarse wool, mainly from Polish sheep, product groups that do not require the softness of Merino wool were examined. Many of these products are currently made of plastic, mostly in the form of synthetic fibers. In addition, many of them are single-use, such as sanitary products and plant pots, but also sound-absorbing acoustic panels. The study found that making this switch, is dependent on local infrastructure and working small-scale enterprises. A shift to small-scale and local resource utilization requires systemic change on several levels: Here the findings show that policy can incentivize material usage transitions, but that these tools are little employed currently.

Burial urns in felted wool from a Danish company.

As synthetic textiles are an important, but often forgotten part of the increasing plastic waste problem, this article contributes to lift up innovative ideas to reduce our reliance on fossil-based materials. These textiles contain environmental toxins added during the processing of fiber and fabric, and through microfiber shedding synthetic textiles contribute up to 35% of the released microplastics which have been shown to end up in our lungs, oceans, animals, and even placentas.

SWOT analysis

A common factor is a focus on wool utilization as a waste management process and in non-textile products, rather than using the material in high-value textile products. The different aspects related to the coarse wool, were first placed in the SWOT table, then grouped into themes: Properties and product performance, Price and availability, Sustainability, and Regulations and policy. As common in SWOT analysis, one aspect can be both a positive and a negative aspect, e.g., coarser wool being more labor-intensive to use means that it creates more jobs, but at the same time it makes it more costly, as will be examined in the following.

The findings were divided into internal factors, which define the strengths and weaknesses of the internal environment, in this case, the material itself and its value chain directly, and external factors, defining opportunities and threats, that are determined by the external environment operated in, i.e., the overall market and competition. Efforts to utilize and valorize surplus, coarser wool, range from creating wool powders and keratin, fertilizers, substrates for biogas production, regenerating fibers from waste keratin, slug-repelling wool pellets, insulation, water purification to bio-composites.

The lack of focus on surplus wool

As a by-product, the wool to some extent becomes invisible in that the wool is mainly disposed of on the farms directly and therefore does not enter into any formal waste management system. When the EU Strategy for Sustainable and Circular Textiles does not even mention local wool – or the possibilities that wool and other local EU fibers hold – but discusses local solutions solely as future potential recycling plants, this can be challenged through the results shown in this article.  In order to replace more plastic with wool, different types of wool need to be used where they are best suited. This also raises the question of how much under-utilized or surplus wool is actually out there?

In addition, using the coarse wool represents an opportunity to replace particularly problematic plastic products. The study found that several of the examined products are today mainly made of plastic, including the products where plastic cannot be recycled and therefore represent a waste problem. It is unlikely that all such plastic can be replaced by wool, but it is nevertheless important to develop alternatives and at the same time exploit available natural materials: “It is important to remember that the extensive use of plastic is relatively new in human history and that a range of solutions existed before these products invaded the market.”

To read this article, click here (mdpi.com).

Natural and Sustainable? Consumers’ Textile Fiber Preferences

Lisbeth Løvbak Berg on 26. January 2023

by Anna Schytte Sigaard  and Kirsi Laitala

Abstract

Textile fibers have become a major issue in the debate on sustainable fashion and clothing consumption. While consumers are encouraged to choose more sustainable and circular textile materials, studies have indicated that a reduction in production and consumption has the greatest potential to reduce the total environmental impact. This can be considered an ecocentric perspective with a focus on degrowth as opposed to a technocentric view where new technologies are expected to solve environmental problems while economic growth continues. Based on a survey in Norway (N = 1284), we investigate how the techno- and ecocentric perspectives impact Norwegian consumers’ fiber preferences and perceptions and the corresponding effects on their clothing consumption. We found that the majority of consumers preferred natural fibers compared to synthetic materials. This contradicts current market practices and the recommendations by material sustainability comparison tools such as the Higg Material Sustainability Index (MSI), where many synthetics receive better ratings than natural fibers. We also found that perceptions of high sustainability regarding fibers were negatively correlated with reduced consumption. Our study suggests that a continued focus on material substitution and other technological measures for reducing climate change will impede the move toward sustainability in the textile sector.

Click here to read the full article (mdpi.com).

Presentation of preliminary findings from the Wasted Textiles PhD project

tobiasson on 19. January 2023

March 14th, 2023, 10 am to 12 noon. Athene 1 (auditorium), Pilestredet 46, OsloMet.

PhD Candidate Anna Schytte Sigaard will present preliminary findings based on data collection from 28 Norwegian households in three areas of Norway: Oslo, Vestfold and Salten. This is part of her PhD Want Not, Waste Not: A wardrobe study approach to minimizing textile waste from Norwegian households.

Each household collected textile items that they would have otherwise discarded during a period of 6 months. They participated in a start-up interview at the beginning of the collection period and two interviews about the collected textiles after 3 and 6 months. All textiles (more than 3000 pieces) were brought to SIFO for analysis where they have been registered according to different physical properties and the story for each textile, from acquisition to disposal, has been recorded.

The findings will grant insights into consumption of clothing and other textiles from households in Norway.

  • A more detailed agenda will be shared closer to the event date.
  • Snacks and coffee/tea will be provided.
  • Location: Athene 1 (auditorium), Pilestredet 46, 0170 Oslo

If you are interested in joining in person, please contact Anna Schytte Sigaard. email: annasiga@oslomet.no

It is also possible to join via Zoom, using this following link:
https://oslomet.zoom.us/j/68769021034?pwd=eEVxb1lQSW4vNkdmbDZFamNvb2x1dz09

A functioning ‘functional unit’

tobiasson on 13. January 2023

For LCA-based tools and category rules, there is a central idea of a “functional unit”. How this will function in the ongoing work with EU’s PEFCR (Product Environmental Footprint Category Rules), is based on the number of days of “usability”.

A “functional unit” is most often described for paint. It is not the liter of paint that has an environmental impact to be reconned with, it is, however, a painted wall one year that is the “functional unit”. With a “good” paint as opposed to a “less good” paint you can paint less often and therefore you need less. The functional unit, is what the paint is supposed to do, keep the walls protected and good looking for a certain period of time. This is at the very core of a life cycle assessment. It defines what the environmental footprint is. So far so good. Let’s then move on to apparel.

Or rather, we would like to share a link to the op-ed that Ingun Grimstad Klepp and I co-authored for EcoTextile News, which you can read here.

A functioning ‘functional unit’?

Lisbeth Løvbak Berg on 12. January 2023

Ingun Grimstad Klepp and Tone Skårdal Tobiasson

What is the ‘functional unit’ of a winter coat, or a pair of boots? The ‘functional unit’ is a central concept for lifecyle assessment (LCA) based tools. In the ongoing work on the European Union’s (EU) PEFCR (Product Environmental Footprint Category Rules), this is based on the number of days of ‘usability’.

Let’s explore what this means. A ‘functional unit’ is perhaps most easily explained in terms of paint, in terms of how long a certain paint will keep the walls protected and good looking, but how does that translate to apparel?

The EU has decided that the functional unit for a winter coat – or a pair of boots – is 100 days of use. This is the expected usability (functional unit) you can expect to gain from a product before it needs replacing or repairing. So far, so good.

Click here to read the full article (ecotextile.com)

Click here to read an opinion piece on the same theme (sciencenorway.no)

We throw away clothes with the price tags on them

tobiasson on 6. January 2023

Textile waste piled high

We throw away enormous amounts of clothing, and most of it contains polyester and other plastics. We need more knowledge to be able to meet the new EU requirement for separate textile collection by 2025, say researchers.

Text Kjersti Lassen/Consumption Research Norway (SIFO)

After cleaning out your wardrobe, you might be left with a pair of trousers with a huge hole in the knee, a sweater you stopped wearing a long time ago or a dress you never really ended up wearing. Where should you dispose of the clothes you want to get rid of?

In Norway you may put whole garments that are clean and functional for a new user in a container for clothing collection, but what about the damaged clothes?

– There are few other options than throwing them in the residual waste, says PhD candidate holder Anna Schytte Sigaard, part of Consumption Research Norway’s Clothing Research team.

Clothing disposal after 2025

But this will not be an option quite soon. Textiles are prioritized in the EU’s circular economy strategy, and by 2025, separate textile collection will be mandatory, also in Norway.

– In order to find out how this is to be organized, we need to know what types of textiles are actually thrown into the municipal waste or end up in other waste or collection streams, says Sigaard.

She is involved in the research project Wasted Textiles, which studies the fate of all the textiles that go out of use. Why do we throw away clothes, what do we throw away, and what do we choose to keep? What is the condition of the clothing that is thrown away, and how much is made of synthetic materials, i.e. plastic?

Because what will happen to the textiles that are collected? Can they be recycled in some way, so that the materials can be used further?

– Then we first have to find out what the clothes are made of. Material recycling is difficult, and with mixed materials it is almost impossible. The next product is almost always of poorer quality, she says.

Method: Deep dive into our waste

To find answers, the researchers have gone through our textile waste: from municipal waste, from recycling facilities where people themselves deliver clothes as waste and from apparel and textile receiving bins where interior textiles, clothes and shoes are delivered to UFF (Humana People to People) or Fretex (Salvation Army).

SIFO-researchers Lisbeth Løvbak Berg, Anna Schytte Sigaard og Kirsi Laitala are here sifting through the textile waste in a recovery station in order to analyze several things. Photo: Kristiane Rabben, Mepex

– We had to start by developing the picking analysis method, says Sigaard, which they did together with Mepex, a consulting company for waste and recycling. Dressed in protective suits and masks, they went through a total of 3,500 kilos of waste, some of it soiled, smelly and ruined, while other things were as good as new. They have looked at different types of textiles, fiber content and the condition of the garments.

– We found a surprising number of garments with the price label still on them, also at the waste recovery stations. People have thrown away completely new garments.

– Everything from the municipal waste, however, was ruined, as the textiles were mixed with food waste and everything else, and impossible to assess. Clothes in the municipal waste have no use value, she says.

SIFO-professor Ingun Grimstad Klepp heads the Wasted Textiles project, and participated in the sorting and analysis of textile waste. Photo: Lea Gleisberg/Wasted Textiles

Surprised by the amount of plastics

Two-thirds of the textiles examined contained some or mainly synthetic fibers, i.e. non-renewable materials or plastics, depending on how one likes to categorize synthetics. Polyester is the largest category, but acrylic, elastane and nylon were also prevalent.

The rest, a third of the textiles, were natural materials or what we call renewable materials, such as cotton, wool and silk. Or viscose, which is also plant-based and degradable, but has undergone intensive chemical processing.

– We were surprised by the large proportion of plastic, as we included all textiles, and found a lot of bed linen and towels, which are most often made of cotton. Still, there is an inordinate amount synthetic altogether, says Sigaard.

If we had only included clothing, there would have been an even greater proportion of plastic. Over two-thirds of all materials in textiles produced today are synthetic.

There is also reason to believe that the proportion of plastic clothing binned will increase in a few years. There is a constant growth in the production of synthetic textiles, and the clothing bought today will be thrown away in a few years. The clothes we find in the trash today have of course been bought back in time.

Analyzing over 3000 discarded clothing-items

All clothing has a label showing the fiber content. This is required by law. But how precise is this label? Investigations in other countries show that many clothes are mis-labelled and contain a greater proportion of synthetic materials than what is stated on the labels. Does this also apply in Norway?

To test this, the Wasted Textile researchers have borrowed a FabriTell fiber scanner – a small, hand-held machine that uses near-infrared analysis technology to identify the fiber composition in textiles. The researchers scanned a selection of the textiles that had been collected from the 28 households. They chose everything that was labelled as mixed fibers or not marked at all.

The FabriTell fiber scanner. Photo: Tone S. Tobiasson

– We found a lot that was mislabeled. For example, t-shirts or hoodies may be labeled as 100 percent cotton, while the scanner shows that the ribbed edges are mixed with synthetic materials. This is within the law, but gives incorrect information, says Sigaard.

We need to reduce production

All knowledge that emerges in Wasted Textiles can be used in the work to fulfill both policy issues and other incumbent requirements the new textile strategy for circular economy in the EU will spearhead. Denmark will start a separate textile collection system as early as June 2023, and hopefully Norway will follow suit in 2025.

Overproduction of clothing is made possible due to the large amount of polyester and other cheap plastic materials used by the apparel industry. This creates enormous amounts of textile waste that leach microplastics and chemicals. The waste often ends up as waste mountains in the Global South, as we have seen in the media from Chile and Ghana.

– The most important thing is to reduce the amount of waste. For this to happen, all actors in the value-chain must agree, or be forced to do so. As of now, the industry is only concerned with recycling opportunity, not reducing production, says Sigaard. In other words: Business as usual.

Recycled polyester seems to be the industry-favored answer to the current conundrum, the willingness to degrow the sector is not easy to advocate. Photo: Tone S. Tobiasson

Mapping of the industry’s design tools

Lisbeth Løvbak Berg on 3. January 2023

Lisbeth Løvbak Berg, Tone Skårdal Tobiasson, Ingun Grimstad Klepp

One of NF&TA’s tasks in Wasted Textiles is to map what tools are being used by businesses, academia and organisations in the design and product development processes to ensure more environmentally friendly and circular production, and how these relate to the central questions in the project.

The mapping was done by Kjersti Kviseth. Ten different design tools were examined and the analysis shows that they have clear common trais. They all emphasise duarablity (‘Social’, ‘Emotional’, ‘Technical’, ‘Longer use’) and minimising waste in production.

The most important questions for Wasted Textiles is whether they will contribute to reducing the volumes of clothing produced and the share of these that are made from synthetic fibres. On these topics the tools are simultaneously very different and very vague. Only two of them include minimising the use of synthetic materials. Overall, the tools will therefore not halt the e ‘plastification’.

The same can be said for volumes. Admittedly, four tools say something about volumes, but the measured proposed are weak. The remaining six do not address this decisive aspect at all.

Kjersti Kviseth ends the report with a personal reflection where she emphasises that the tools reflect the understanding of the environmental issues that existed at the time of their making, and that they will be amended as the understanding matures and the knowledge about plastics and volumes increases. We can hope that she is right, but at the same time the road ahead is long and the current situation is that non of the most common design tools address the most central problematic of the industry: the increase in production volumes and the galloping plastification of clothing and other textiles.

Read the document here (docdroid.net).

How to make sure Extended Producer Responsibility becomes a silver bullet

Lisbeth Løvbak Berg on 24. October 2022

This is a letter sent to commissioners and members of the European Commission in October 2022, from 4 participants in the Wasted Textiles project that explains their suggestions for a way of developing an EPR scheme that addresses volumes. They suggest an Eco-modulation based on volumes in the waste and therefore include the growing online trade.

How to make sure Extended Producer Responsibility becomes a silver bullet

We would firstly like to recognize the immense effort made by the EU Commission in launching the EU Strategy for Sustainable and Circular Textiles in the spring of 2022 and welcome the long-awaited focus on this sector. We would also like to express our appreciation of the strategy’s systemic approach to tackling the various challenges in the textile sector. We especially welcome that the strategy addresses fast fashion, the problem of synthetics and the need for EPR.

We are an applied research consortium under the umbrella of the project Wasted Textiles, which represents strong expertise on textiles, i.e., consumption and wardrobe studies (use, reuse, laundry, repair, disposal), end-of-life practices and waste analysis, fibres and measurement tools, greenwashing, marketing claims and consumer communication and, business models. We wish to offer our interdisciplinary expertise and in-depth knowledge of consumer research, waste and recycling management and policies from 30 years of research and recycling industry development. Wasted Textiles is led by Consumption Research Norway (SIFO), a non-profit, transdisciplinary research institute at the Oslo Metropolitan University.  SIFO has a history going back to the 1930s and the birth of home economics and has worked with clothing consumption from the start. Today the institute has extensive research on clothing, especially the use phase.

With this letter, we would like to express our support for the EU Commission’s work within textiles and at the same time highlight key areas of concern that need to be addressed for a much-needed systemic change within the industry. Specifically, this letter concerns the development of harmonised      EU Extended producer responsibility (EPR) rules for textiles with eco-modulation fees as part of the forthcoming revision of the Waste Framework Directive in 2023.

Norway was one of the first countries in Europe to implement Extended Producer Responsibility for packaging waste and electric electronic equipment (EE goods) and batteries during the early 1990s. The law from 2017 replaced the voluntary industry agreements from 1994. The National Waste Association of Norway (Avfall Norge, part of the Wasted Textiles consortium) has a history dating back to 1986. Norway also got its first Pollution Act in 1981.

We believe that harmonised EU EPR rules for textiles can be an important instrument to bring the needed systemic changes in the textile sector. In line with a recent report by Eunomia “Driving a Circular Economy for Textiles through EPR”, we believe the aim of the EPR scheme must be the reduction of environmental impacts from the textile sector. This is in line with the original definition of EPR from the Swedish researcher Thomas Lindhqvist from 1992:

“Extended producer responsibility is an environmental protection strategy to achieve an environmental goal of reduced total environmental impact from a product, by making the manufacturer of the product responsible for the entire life cycle of the product and especially for the return, recycling and final disposal of the product. The extended producer responsibility is implemented through administrative, financial and informative instruments. The composition of these instruments determines the exact form of the extended producer responsibility.”

Our point of departure is that the biggest challenge in the textile sector is overproduction. The amount of clothes produced and sold has increased drastically in the past 20 years. This means that each individual garment is used less and less. In order to reduce environmental burdens, measures are therefore needed that not only address the product’s design but above all the quantity of products. It is those who produce the clothes that are used the least – or never even used at all – who emit the most. At the same time, it is the clothes that are worn the longest that burden the environment and waste systems the least. In other words, we want to take the waste hierarchy seriously by showing how EPR can prevent waste and not just stimulate increased reuse and recycling.

As a starting point, and in line with the beforementioned Eunomia report, we believe the aim of the scheme must be the reduction of environmental impacts. This is achieved most quickly and efficiently by reducing the EU’s production and import of new apparel and other textile products. But, for EPR to move towards a circular economy for textiles and not simply be an exercise in transferring costs, as the report formulates it, EPR must be designed smartly. One of the challenges with EPR, that the report points to, is precisely taking the waste hierarchy seriously, e.g., by not favouring recycling over reuse, ensuring that the environmental fee is high enough to have an effect on production volumes, and that the scheme includes the growing online shopping with direct imports.

The biggest challenge is overproduction: EPR must be designed accordingly

We are concerned that the measures proposed in the EU’s textile strategy (PEF, the Eco-design Directive and EPR) focus primarily on the product and its design together with end-of-life strategies (recycling), and thus not on the possible systemic changes that are pressing. In order to reduce the environmental impact of large volumes of textiles (fast fashion), measures are therefore needed that not only address the product’s design and strategies for prolonged- and end-of-life textiles, but also the number of products produced. If the EU is to achieve its goal of making fast fashion out of fashion, the means must be directed at factors that make fast fashion unprofitable. In extreme cases, we are talking about disposable products, in addition to the destruction of products that have never been used at all. It is not the design of each individual product that distinguishes fast fashion, which means that eco-design criteria will therefore not have the desired effect standing alone. A weakness of most of the EPR systems that have been implemented so far is that they do not take the issue of quantity seriously.

If the EU is to achieve its goal of making fast fashion out of fashion, the means must be directed at what makes fast fashion profitable: large volumes and rapid changes. The commission has been discussing a ban on greenwashing and planned obsolescence. In fact, fast fashion is planned obsolescence by definition. The clothes are not meant to last. Not because of bad quality or bad design, but because there is a new trend coming ever more often and faster.

The work on the development of PEF (Product Environmental Footprint) for clothing has also shown that it is extremely difficult to develop eco-design criteria for clothing, as the criteria for what constitutes good clothing are so varied and person-specific. Focusing on the product’s design does not capture the most important: whether there is an actual use for the product.

We believe that EPR can be designed so that quantity and speed are taken into account. This must be done by studying the use and disposal phases, and possibly also the quantity and speed of production. Those clothes that are used little and cost a lot to reuse/recycle will be the most expensive to put on the market.

If this is done and combined with sufficiently high fees, we ensure that one of the instruments in the textile strategy actually works, i.e., brings systemic change and is thus a true silver bullet.    

The importance of the use phase

By the use phase we mean the time the product is in use. The longer this is, the less waste is created. Currently, textile use is an area with limited knowledge and data, however, in order for the EPR rules to have an impact on fast fashion and the related overconsumption, it is highly important, that we make sure that an EPR scheme considers use-related aspects. The use phase for clothing can be measured in the number of times something is used, or how long it is used. The latter is far easier than the former to measure. Instead of trying to guess which products will be used for a long time and modulating the fee on design parameters, it is possible to measure how long products from different (larger) retailers remain in use. Using “picking analysis” (a type of waste audit, an established method for analysing waste streams), sample analyses of textile waste and textiles donated for reuse, an average usage phase can be estimated.

The system will be far more accurate when the year of production is included in the mandatory labelling of clothing, a long overdue requirement. The time-lapse from when the product is put on the market until it goes out of use will give the manufacturers a score which is then multiplied by the volumes of the various brands or collections that suppliers put on the market. The modulation of the fee should take into account the producers’/brands’ average usage phase.

The brands that are not found in the waste streams will be exempt from paying a fee. This may be because the products are perceived as so valuable by consumers that they remain in their possession. Differentiations based on clothing categories should, however, be included as some garment types are expected to have longer use phases than others, e.g, a coat versus a T-shirt.

Reuse and disposal phase

When more textiles are to be collected for reuse and recycling, and more is to be done in Europe rather than in the Global South, the costs of these processes will increase. If more is to be utilised at a higher level in the waste hierarchy, it will also cost more. Much of what is not reused today could be reused if the clothes were renewed, i.e. repaired, washed or stains were removed, which in turn captures the reuse value of these products but at the same time carries a cost. These activities and related business models are currently underfinanced, and they lack profitability due to the associated high costs of manual labour and the overload of big volumes of low-priced and low-quality fast fashion items with no or limited reuse value.  At the same time, certain textiles have a high value and can ensure a profit for collectors (e.g., resell business models where ca 5-10% of high-quality garments are sold on online platforms). It is important that all reusable textiles are given the opportunity to have longer lifespans, so if the EU is to aim to increase the reuse of textiles, preparation for reuse and repair activities must be financially supported by the EPR.

The same will apply to various forms of recycling: different products have different recycling costs. Some can be easily recycled; other textiles will not be recyclable at all or only if cost-intensive measures are first taken. As for the use phase, we, therefore, propose an average per brand based on how much the waste management costs. Those with a high reuse value and low cost of recycling will receive a lower fee, possibly an exemption in the end.

The modulation of the fee will thus consist of a combination of how long clothing from the brand is used on average and how costly better waste treatment is. Both evaluations can be made based on picking analyses that are repeated at regular intervals so that new brands, or improvements by already existing brands, can be captured. These analyses will also ensure increased knowledge about textile consumption and textile waste and will be important for statistics, research and regulation in the textile area. We have called this way of modulating the fee in an EPR system Targeted Producer Responsibility (TPR), which is described in ScienceNorway.no.

Production and marketing

The way EPR is usually conceived, the total tonnage of products placed on the market by an individual producer forms the starting point for the fee. But the quantities can also be used in the modulation of the environmental fee. It is possible to let those manufacturers who have many collections, a short timespan in-store for each individual product and also sell large volumes, incur a higher fee, which is then multiplied by the weight of what they place on the market. Proposals for such a fee modulation have been made by several Norwegian environmental organisations and can easily be combined with a TPR. It is also possible to use other parameters in the modulation, such as the proportion sold with reduced prices (the percentage that goes on sale), the proportion of returned goods, unsold goods, etc.

To summarise our proposal:

  • The EU has a golden opportunity to ensure a systemic change for the better of its citizens and the environment.
  • If we are to achieve the goal of reducing environmental impacts from textile production the quantities must be reduced. Less clothing is the prerequisite for each garment to be used longer, in line with the principles of the waste hierarchy and circular economy.
  • The measures proposed in the EU’s textile strategy (PEF; the Eco-design Directive and EPR) all focus on the product and its design, and thus not on the systemic changes. EPR on textiles can, if desired, be designed so that it changes the business models of fast fashion by making it less profitable, and those clothes that are used little and cost a lot to be reused and recycled also become unprofitable to put on the market.

The above concerns and suggestions were a selection of many, and we are aware that a successful EPR agenda in the EU will include many more elements and key areas for coherent consideration.

Thank you for your time and attention.

Sincerely,

Ingun Grimstad Klepp

Professor of Clothing and Sustainability, SIFO, OsloMet

Jens Måge

Technical Advisor, National Waste Association of Norway

Kerli Kant Hvass

Assistant Professor in Circular Economy, Aalborg University

Tone Skårdal Tobiasson

Author, journalist, founder NICE Fashion and Board member Union of Concerned Researchers in Fashion