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 

Delivering EU Environmental Policy Through Fair Comparisons of Natural and Synthetic Fibre Textiles in PEF

Lisbeth Løvbak Berg on 25. May 2022

Make the Label Count Campaign: Simon J. Clarke, Ingun G. Klepp, Kirsi Laitala and Stephen G. Wiedemann.

Summary

Sustainability has become a priority objective for the European Union (EU). It is a key driver for policy development through the global leadership role the EU has taken in addressing climate change, decoupling economic growth from resource use, and the sustainable use of
resources. The global supply of textiles has been recognized by the EU as a major source of emissions and resource use; the sector has become increasingly reliant on fossil feedstocks to supply synthetic fibres, and the textile industry has been roundly criticised for unsustainable and non-circular consumption patterns.


The Product Environmental Footprint (PEF) system – which assesses a product’s environmental impact and provides consumers with information on that impact – has the potential to be paramount in directing the textile sector towards a sustainable system of production and consumption. However, the PEF system has not been designed to deliver the EU’s strategies and, without amendment, its application to the textiles sector risks undermining the EU’s laudable intent. The PEF system is designed to facilitate like-with-like comparisons, but assessment of textiles made from natural and synthetic fibres are not yet comparable because the impacts of forming natural fibres are fully accounted for, but omitted for fossil fuels. The single biggest sustainability issue for the textile industry is the growth in synthetic fibre production and the causally related rise in fast fashion. A PEF-derived comparison will not challenge the over-consumption of resources, and risks legitimising unsustainable consumption with an EU-backed green claim.


These limitations present a significant challenge to the delivery of both EU strategy and the PEF goal of providing fair comparisons of products based on their environmental credentials.


In combination, the characteristics of the textiles category, together with the limitations of PEF methodology, provide a strong argument for not comparing textiles made from renewable and non-renewable raw materials. However, achieving the EU Green Deal and circular economy objectives mandates a pragmatic approach; hence our analysis recommends methodological improvements to deliver EU environmental policy through fair comparisons of natural and synthetic fibre textiles in PEF. Addressing these limitations now will avoid
the same problems arising when PEF is applied to other product categories that compare renewable and non-renewable raw materials, such as furniture and fuel.

Click here to read the full report (makethelabelcount.org).

Fossil Fashion: How Green Growth is Undermining the Circular Economy

Lisbeth Løvbak Berg on 24. October 2021

Why the fashion industry, driven by the green growth notion, cannot recycle its way out of the climate crisis

By Tone Skårdal Tobiasson

Tone is co-editor of “Local, Slow and Sustainable Fashion Fibres: Wool as a Fabric For Change”, from Palgrave Macmillan, out on December 18, 2021.

As the world comes to terms with the climate crisis and the environmental devastation of our over-consumption, we are increasingly being told that switching to greener products will not only save us, but be good for the economy. This is the principle behind “green growth”, which encourages us to continue consuming as long as the products we buy are more sustainable. But could it be that someone is pulling wool over our eyes?

The fashion industry has become one of the main culprits in the blaming-and-shaming for carbon-emissions, and numbers have been thrown around at a rate that rivals fast fashion. One of the most used statistics is that textiles in 2015 emitted 1.2 billion tons of carbon dioxide, equivalent or more than maritime shipping and international flights combined, a number that has since been challenged. However, the fashion industry is far from off the hook. 

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

Durable or cheap? Parents’ acquisition of children’s clothing

ingridha on 28. May 2021

Ingun Grimstad Klepp & Vilde Haugrønning

Abstract

Parents are faced with a plurality of choices and concerns when it comes to the acquisition of clothing for their children. This paper explores how parents employ longevity in consumption of children’s clothing from a practice-oriented perspective. The material consists of 6 focus groups with 40 parents who have at least one child under the age of 18. The aim of the groups was to establish children’s clothing needs: how many they need of each garment, how long parents expect the garment to last and what they understand as quality in clothing.

The analysis shows that parents mainly opt for an ‘one or the other’ strategy; they choose what they understand as quality, often affiliated with specific brands, and accept paying more for the garment, or they mainly choose based on low prices, and expect less of the garment. Quality is evaluated based on the garments’ durability and function. More specifically, the parents measure the service lifetime of a garment based on the number of seasons it lasts, either in terms of wear and tear or the child growing out of it. The expected lifetime is defined by uncertain sources, from their own and friends’ experiences, and their desire to justify their own choices as well as routinised practices.

Our discussion section employs these findings and contextualise them within product lifetime discourses. By doing this, we provide knowledge about how quality is understood, and how brand and price are used as indicators. We show how lack of information about products, especially on garments, leads to uninformed consumption practices that have consequences for how quality and longevity are prioritised and understood.

PLATE-2021_Klepp-and-HaugronningDownload
PLATE-2021_Klepp-and-HaugronningDownload

Consumer practices for extending the social lifetimes of sofas and clothing

ingridha on 27. May 2021

Vilde Haugrønning, Kirsi Laitala & Ingun Grimstad Klepp

Abstract

Consumers play an essential role in efforts to extend product lifetimes (PL) and consumers’ practices can determine how long and active lives products get. Applying the framework of Social Practice Theory, this paper argues that in order to suggest changes to how consumers can contribute to longer product lifespans, research needs to focus on consumer practices. The data material consists of 4 focus group interviews with 38 participants about household goods and 29 semi-structured interviews about clothing.

Previous research shows that consumers’ expectations of product lifetime has decreased, while satisfaction with products is relatively high, which may indicate that product break down and/or replacement is more accepted. Therefore, we argue, it is necessary to focus on social lifespans. Our findings show that products such as clothing and sofas often go out of use or are disposed of before their physical lifespan ends, and it is more common to donate or sell old clothing and sofas than buying the products second hand. There are a number of routinised practices, such as disposal of functional items, that are considered normal, which leads to less reflexivity of seemingly unsustainable practices.

The material in products, or the expectation to the material, is highly influential for practices that can extend the social lifespan, such as maintenance. We conclude that by understanding practices as integrated and influenced by elements of the material, social and cultural, policy interventions may have a greater impact on the social lifespan of products.

PLATE-2021_Haugronning-et-alDownload
PLATE-2021_Haugronning-et-alDownload

Reducing environmental impacts from garments through best practice garment use and care, using the example of a Merino wool sweater

Lisbeth Løvbak Berg on 19. April 2021

Stephen G. Weidemann, Leo Briggs, Quan V. Nguyen, Simon J. Clarke, Kirsi Laitala and Ingun G. Klepp

Abstract

Purpose

Garment production and use generate substantial environmental impacts, and the care and use are key determinants of cradle-to-grave impacts. The present study investigated the potential to reduce environmental impacts by applying best practices for garment care combined with increased garment use. A wool sweater is used as an example because wool garments have particular attributes that favour reduced environmental impacts in the use phase.

Methods

A cradle-to-grave life cycle assessment (LCA) was used to compare six plausible best and worst-case practice scenarios for use and care of a wool sweater, relative to current practices. These focussed on options available to consumers to reduce impacts, including reduced washing frequency, use of more efficient washing machines, reduced use of machine clothing dryers, garment reuse by multiple users, and increasing number of garment wears before disposal. A sixth scenario combined all options. Worst practices took the worst plausible alternative for each option investigated. Impacts were reported per wear in Western Europe for climate change, fossil energy demand, water stress and freshwater consumption.

Results and discussion

Washing less frequently reduced impacts by between 4 and 20%, while using more efficient washing machines at capacity reduced impacts by 1 to 6%, depending on the impact category. Reduced use of machine dryer reduced impacts by < 5% across all indicators. Reusing garments by multiple users increased life span and reduced impacts by 25–28% across all indicators. Increasing wears from 109 to 400 per garment lifespan had the largest effect, decreasing impacts by 60% to 68% depending on the impact category. Best practice care, where garment use was maximised and care practices focussed on the minimum practical requirements, resulted in a ~ 75% reduction in impacts across all indicators. Unsurprisingly, worst-case scenarios increased impacts dramatically: using the garment once before disposal increased GHG impacts over 100 times.

Conclusions

Wool sweaters have potential for long life and low environmental impact in use, but there are substantial differences between the best, current and worst-case scenarios. Detailed information about garment care and lifespans is needed to understand and reduce environmental impacts. Opportunities exist for consumers to rapidly and dramatically reduce these impacts. The fashion industry can facilitate this through garment design and marketing that promotes and enables long wear life and minimal care.

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

What Affects Garment Lifespans? International Clothing Practices Based on a Wardrobe Survey in China, Germany, Japan, the UK, and the USA

ingridha on 3. November 2020

Kirsi Laitala and Ingun Grimstad Klepp

Abstract

Increasing the length of clothing lifespans is crucial for reducing the total environmental impacts. This article discusses which factors contribute to the length of garment lifespans by studying how long garments are used, how many times they are worn, and by how many users. The analysis is based on quantitative wardrobe survey data from China, Germany, Japan, the UK, and the USA. Variables were divided into four blocks related respectively to the garment, user, garment use, and clothing practices, and used in two hierarchical multiple regressions and two binary logistic regressions.

The models explain between 11% and 43% of the variation in clothing lifespans. The garment use block was most indicative for the number of wears, while garment related properties contribute most to variation in the number of users. For lifespans measured in years, all four aspects were almost equally important. Some aspects that affect the lifespans of clothing cannot be easily changed (e.g., the consumer’s income, nationality, and age) but they can be used to identify where different measures can have the largest benefits. Several of the other conditions that affect lifespans can be changed (e.g., garment price and attitudes towards fashion) through quality management, marketing strategies, information, and improved consumer policies.

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

Environmental impacts associated with the production, use, and end-of-life of a woollen garment

ingridha on 25. May 2020

S.G. Wiedemann, L. Biggs, B. Nebel, K. Bauch, K. Laitala, I.G. Klepp, P.G. Swan and K. Watson.

Abstract

Purpose

The textiles industry is a substantial contributor to environmental impacts through the production, processing, use, and end-of-life of garments. Wool is a high value, natural, and renewable fibre that is used to produce a wide range of garments, from active leisure wear to formal wear, and represents a small segment of the global fashion industry. Woollen garments are produced by long, global value chains extending from the production of ‘greasy’ wool on sheep farms, through processing to garment make-up, retail, consumer use, and end-of-life. To date, there have been limited life cycle assessment (LCA) studies on the environmental impacts of the full supply chain or use phase of garments, with the majority of wool LCA studies focusing on a segment of the supply chain. This study aimed to address this knowledge gap via a cradle-to-grave LCA of a woollen garment.

Methods

This study investigated greenhouse gas (GHG) emissions, fossil fuel energy, and water stress associated with the production, use, and end-of-life of a lightweight woollen sweater (300-g wool), together with inventory results for freshwater consumption and land occupation. Primary datasets were used for the wool production and wool processing stages, while primary datasets relating to consumer garment use were supplemented with literature data. Impacts were calculated and reported per garment wear event.

Results and discussion

Impacts per wear were 0.17 (± 0.02) kg CO2-e GHG, 0.88 (± 0.18) MJ fossil energy, and 0.96 (± 0.42) H2O-e water stress. Fossil fuel energy was dominated by wool processing, with substantial contributions of energy also arising from retail and garment care. Greenhouse gas emissions from wool production (farming) contributed the highest proportion of impacts, followed by lower contributions from processing and garment care. Contributions to water stress varied less across the supply chain, with major contributions arising from production, processing, and garment use.

Conclusions

Opportunities to improve the efficiency of production, processing, and garment care exist, which could also reduce resource use and impacts from wool. However, the number of garment wear events and length of garment lifetime was found to be the most influential factor in determining garment impacts. This indicated that consumers have the largest capacity to influence the sustainability of their woollen garments by maximising the active garment lifespan which will reduce overall impacts.

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

Wardrobe sizes and clothing lifespans

Lisbeth Løvbak Berg on 19. September 2019

Ingun Grimstad Klepp, Kirsi Laitala and Vilde Haugrønning

Abstract

It is easy to assume that a large wardrobe is characterized by excessive clothing and high acquisition, with little use of each garment and thus a big environmental impact. However, it is also possible to think the opposite; that the large wardrobe is a result of clothes remaining in use for a long time, that disposal happens rarely, while acquisition can be normal or even low. Whatever the reason, in a large wardrobe it is more likely that clothes become old before the technical life expires. This is because many of the garments are seldom used. Small wardrobes are often presented as favourable for both people and the environment, and as part of an ecological-friendly lifestyle, but we know little about the interaction between wardrobe sizes, longevity and the environmental impact.

In this paper, we investigate this relationship based on survey material from five countries; China, Germany, Japan, UK and the USA. We find that consumers with large wardrobes use their clothes longer, but consumers with small wardrobes use their clothes more often before they are disposed. We conclude that a good utilization of resources is possible with both large and small wardrobes, but in different ways. As we work towards more sustainable clothing consumption, we need to approach consumers differently, in order to give constructive advice to all.

This is a conference article from the 3rdPLATE 2019 Conference. Click here to find the full conference proceedings including this article (depositonce.tu-berlin.de).

Does Use Matter? Comparison of Environmental Impacts of Clothing Based on Fiber Type

ingridha on 19. July 2018

Kirsi Laitala, Ingun Grimstad Klepp & Beverley Henry

Abstract

Several tools have been developed to compare the environmental impact of textiles. The most widely used are Higg Materials Sustainability Index (MSI) and MADE-BY Fiber Benchmark. They use data from production to evaluate the environmental impacts of textiles differentiated by fiber type. The use phase is excluded from both tools. This article discusses whether there is evidence that the use of textiles differs systematically between different fiber types and examines the consequences of comparing the environmental impacts of clothing based on differences in production of fibers alone without including differences in their use.

The empirical material in this paper is based on analysis of rating tools and a literature review on clothing use. It shows that fiber content contributes to the way consumers take care of and use their clothing. When use is omitted, major environmental problems associated with this stage, such as spread of microplastics, are also excluded. This one-sided focus on material production impacts also excludes the importance of product lifespans, quality, and functionality. The consequence is that short-lived disposable products are equated with durable products. Comparing dissimilar garments will not help consumers to make choices that will reduce the environmental burden of clothing. We need an informed discussion on how to use all materials in the most environmentally sustainable way possible.

Click here to read the full article (oda.oslomet.no)