Thematic session at PLATE 2025

Join us for a thematic session at PLATE conference in Denmark (July 2025).

2025 is the last year for the CHANGE project and one of the closing activities is a thematic session at the Product Lifetimes and the Environment (PLATE) conference. The thematic session on “Rebound effects and critical views on product durability”, co-chaired by Irene Maldini, Ingun Klepp, Kirsi Laitala, Eléonore Maitre-Ekern, Harald Wieser welcomes contributions until November 29th, 2024. The conference will be held at Aalborg University in Denmark from the 2nd to the 4th of July, 2025, and you can read more here.

With this session we would like the PLATE community to press pause for a couple of days and reconsider: Are we moving in the right direction? What are the assumptions that underlie the claimed benefits of durability? Are our efforts really helping to reduce material depletion at a significant rate? What are the material and behavioural conditions that need to be met for durability to have the desired effect? And are these conditions present in real product lifetimes and in our everyday lives? What new ways of thinking can help us in advancing the field for more significant impact? These are questions that we (co-chairs of this session) find very relevant today and would love to address together with the presenting authors, while building on the quality research that we know this community can deliver.

The Good Wool Collective’s first webinar

A new initiative from Sweden has surfaced, The Good Wool Collective, started by Lisa Bergstrand. As part of their inaugural webinar, Australian Wool Innovation’s Angus Ireland and I gave talks.

The theme was the shortcomings of EU’s Product Environmental Footprint (PEF) and how it disadvantages natural fibers. The audience was mainly Nordic brands, but also some from further afield.

Lisa Bergstrand is a wonderful Swedish woman with an extensive design background who has embraced wool and its benefits, while Angus Ireland has been an important driver in the PEF process, and for wool’s sustainability credentials, and part of the ongoing work in PEFCRs.  He is Program Manager for Fibre Advocacy and Eco Credentials at AWI, with extensive experience in wool’s environmental impact and advocacy in EU sustainability initiatives.

During the hour and a half long webinar with breakout-rooms towards the end, Angus Ireland first described the role of the wool industry in the PEF process, but also the work outside ‘the box’ in Make The Label Count (click here), and who are key players in this landscape. Next, he went on to PEF’s 16 parameters, with details about shortcomings and how plastic waste and microplastic release are not accounted for. With recent publications from Nature (click here for access) and from Changing Markets Foundation, have more or less upended the arguments that we do not have enough knowledge on microplastic release during laundering (a main argument from industry), as the Precautionary Principle is now being called into action, as laundering only represents a microscopic percentage of the total release over time, according to the Nature study.

The endemic bad quality of data and questionable parameters were Angus Ireland’s main focus. He also brought into play Consumption Research Norway’s research that relates to duration of service, that France’s Ecobalyse has been sniffing around, alongside the natural fiber sector seeing a ‘French opening’ with ADEME’s approach (sorry, only Scandinavians will see the humor in a French opening).

There is hope, as Angus Ireland described, even though the new LCA commissioned and peer-reviewed, still has not been accepted un GaBi – the database used by the EU – a process that has taken close to two years with no results so far. The Holistic Durability Working Group in PEF for apparel and footwear will hopefully succeed in their work to make for a more even playing-field.

Next up was myself, questioning whether natural fibers will ever get a fair rating in LCAs. I did a historic backtrack to the Made-By assessment tool in 2011 (wool labelled as ‘red’, recycled polyester as ‘green’) and fast forwarded to the Pulse of Fashion Report in 2017, where recycled polyester is what consumers should be ‘enhanced’ to choose. Certainly, over cotton, but obviously over all natural fibers. Amazing Grazing and other wool projects, such as the Textile farmer were introduced to the audience.

Alternative thinking needed

Changing Markets Foundation recent report Fashion’s Plastic Paralysis: How brands resist change and fuel microplastic pollution, was also something I came back to, especially the implications for our health related to microplastics. This is, as Angus talked about, something that should enter under the precautionary principle, not be continually dragged out in endless debates and delaying tactics.

Talking about “durability” and the general misunderstanding that ‘more durable products’ are going to save the world, when we are drowning in products, I went on to talk about TPR and work by the OR Foundation, which has been inspired by the waste audit approach.

My talk then turned to the functional unit, and pointed to a new PhD (click here to access) that has raised the million-dollar question not addressed in PEF; what is actually the functional unit for apparel? Is it number of wears, really? I used the example of my bunad and my daughter’s imminent marriage (wedding dresses are worn once, at least by the first owner), and my national costume’s 50 years of service, while my daughter’s is inherited from my mom, so the functional unit and duration of service will be exponential. I chose my bunad for the event (first part) and another not-enough-worn for the second disco-dancing part, and the functional unit of feeling worthy, safe, socially acceptable and dressed for the occasion – delivered!

Summing up, it all comes down to common sense, which is currently lacking in the whole shebang, and that the small ray of hope is that France has understood that solutions and how one evaluates companies and products needs to address the business model that underpins everything, not the product-specific criteria. This was followed by passionate and very good questions and engaging break-out discussions, showing that once one gains insight into the process surrounding PEF, people in the industry understand that the EU is currently headed on a fast track in the wrong direction.

Some more thoughts on this theme can be accessed here, if you’re on LinkedIn.

TPR brought forward in What Fuels Fashion? Report

In the recently published report, What Fuels Fashion?, issued by Fashion Revolution, Consumption Research Norway SIFO’s suggestion for a Targeted Producer Responsibility method has received substantial attention alongside the Plastic Elephant report. In addition, the ruling by the Norwegian Consumer Authority against the Higg consumer-facing label also is brought forward.

All in all, What Fuels Fashion? gives much attention to the research from Oslo Metropolitan university, which is an important part of the Wasted Textiles project. What Fuels Fashion? is a single-issue, special edition of Fashion Revolution’s annual Fashion Transparency Index. They have reviewed 250 of the world’s largest fashion brands and retailers and ranked them according to their level of disclosure on climate and energy-related data in their own operations but primarily in their supply chains.

A key finding is that there is hardly any transparency around over-production. “The fashion industry wants to have its cake and eat it too. Most big fashion brands (89%) do not disclose how many clothes they make annually. Alarmingly, nearly half (45%) fail to disclose neither how much they make nor the raw material emissions footprint of what is produced, signalling the industry prioritises resource exploitation whilst avoiding accountability for environmental harms linked to production.”

On page 36 in the report, we can read: “Governments are now cracking down on greenwashing. In addition to investigations into several brands’ environmental claims taking place in the UK and Australia, the Norwegian Consumer Authority ruled the Higg Materials Sustainability Index (Higg MSI) unlawful to support such claims from retailers. These actions, which have resulted in accountability, illustrate why transparency is crucial to enable change. Nonetheless, the need for robust evidence-backed claims remains a persistent issue.”

Furthermore, on page 38, we find this quote: “Already we are seeing that overestimating the importance of garment durability and underestimating the environmental impact of overproduction is shaping the policy landscape. Research by Oslo Met University reveals the “Plastic Elephant in the Room” – which critiques the EU’s Sustainable Textiles Strategy, particularly its focus on durability. The research argues that the most effective way to reduce the fashion industry’s environmental impact is to cut production volumes rather than merely extending product lifespans (and that focusing on durability unintentionally supports synthetic fossil fuel-derived fibres).” Let’s hope someone from DG ENVI and DG GROW actually read this report!

On page 39, the report has a full-fledged explanation of TPR as a viable alternative to EPR (see illustration). Which is good news for the on-going discussion on how we can make fast fashion actually ‘out of fashion’ with regulatory instruments, and halt business as usual. Being taken seriously in such an important report, will hopefully garner further attention to SIFO’s research.

Socks – the most neglected of all garments

Maria Kupen With’s Master thesis is entitled A new narrative of Neglected Socks. An exploration of new value creation and narratives for materials through creative fashion practice.  She recently delivered her Masters at the Department of Art, Design and Drama – Fashion and Society – at OsloMet.

Inspired by the preliminary results from Anna Schytte Sigaard’s PhD in Wasted Textiles, Maria Kupen With decided to work with socks – the item discarded in the largest quantities and the worst condition. Socks are so intimate and used socks are not sold in second-hand shops, maybe not even shared for fear of contamination. If these could be upcycled, then what could not be?

Her practice-led approach included collecting socks from friends and family and a local charity, analyses of the socks’ condition, their disposal reasons etc., and creative exploration of the material and its potential.  She created prototypes and a pre-exhibition to confront viewers with the transformed material – in the form of a jacket-tent, sweaters and textured pieces – and registered their potential to elicit emotional responses and challenge current attitudes and perceptions of discarded and worn-out materials.

The thesis touches upon our relationship with nature through cleanliness, bacteria, bodily fluids, as well as pilling and other signs of wear, and how this can change when engaging with the objects, as Maria herself experienced in the practice of making from worn socks, going from thinking they are “icky” to deciding to wear her own pieces. The visitor of her pre-exhibition also reflected on their relationships with second-hand clothing usage more broadly.  The thesis hence uses design to create both value and discussions around value, a much needed perspective in a throw-away consumer culture.

Maria Kupen With was supervised by Lisbeth Løvbak Berg at SIFO and also Siv So Hee Steinaa. In the photo we see the three of them at the Master’s exhibition, enveloped in Maria Kupen With’s work.

How does repair affect the value of clothes?

Kinga Zablocka is one of the Master students at OsloMet’s Master of Aesthetic Practices in Society (Fashion and Society), Department of Art, Design and Drama. Professor in Clothing and Sustainability, Ingun Grimstad Klepp, has been one of her supervisors on her Master’s thesis, Is it worth it? An exploration of clothing repair and value using wardrobe studies.

Kinga Zablocka has explored what garments are being repaired and why and how repair affects the value of the clothes.  Similar to the PhD in Change, Zablocka has interviewed couples and used wardrobe studies as the method.  Four Norwegian couples between the ages of 19 and 34 have explained how and why they have or haven’t repaired their garments and how repair affects value both before and after repair. This is therefore a dive into a younger generation’s thoughts and praxis which might be important for the future of repair.

The most significant barrier to repairing for those in the study was a lack of competence, in line with the work of Iryna Kucher and others. An important contribution of the thesis is that repair is not only seen as a technical problem but also connected to the value of the garments in a broader sense, where both wearer-clothing relationships and social and economic values ​​are included.

The low price of fast fashion could be used as an excuse not to repair a garment She contributes to both the knowledge of repair and clothing processes in general and ends her Master’s with a discussion of the findings related to the EU Textile strategy. Repair is not only an important part of clothing consumption, but also policy.

Kinga Zablocka has besides being supervised by Ingun Grimstad Klepp, also been supervised by Joanne Cramer, and is part of the Change project. Klepp is hopeful that it will be possible for Zablocka to continue with this work and research.

The photo was taken at the Master exhibit where Zablocka (to the right) let the public decide on some repairs with varying degrees of visibility. Does the repair contribute to increasing the value of the garment or not?

Wardrobe Methods webinar opens up the field

On 17th April 2024, UCRF (Union of Concerned Researchers in Fashion) hosted a Wardrobe Methods Event in conjunction with the CHANGE research project to explore a way of researching the contents and dynamics of wardrobes.

78 had registered for the event, and 41 attended the webinar on Wardrobe Methods, which is about the use phase in the lives of clothing and the practices that go on there. This has long been seen as a way to break apart the monolithic understanding of ‘use’ and ‘consumption’ that industry and sustainability initiatives often promote. In the attendees at the live meeting, at least 15 different mother tongues spoken: Spanish, Ukrainian, Russian, Dutch, Hungarian, English, Portuguese, Swiss German, Danish, Turkish, Hindi, Italian, German, Polish, Norwegian.

The event hosted by Professor Kate Fletcher and Karishma Kelsey from the UCRF Board was facilitated by a talk from Professor Ingun Grimstad Klepp which gave a round-up of the history of the set of methods, along with current uses, also in policy-work. Here Klepp briefly touched on the new method developed by Consumption Research Norway SIFO called Waste Audit Interviews. This is part of SIFO’s ongoing work on addressing the short-comings of EU’s Textile Strategy, where ‘durability’ and ‘repairability’ are seen as the beacons of a long life for apparel.

The event’s goal was to explore ways to extend wardrobe methods further, including in more diverse ways. The talk was followed by a lively discussion and breakout-sessions. See the whole webinar by clicking here.

The discussions raised many intriguing propositions and development for Wardrobe Methods, a selection from the break-out rooms is summarized here:

  • Using wardrobe methods to help show the variety of understandings about key terminology related to textile qualities and descriptions, e.g. ‘quality’.
  • Potential ethnographic study of indigenous Mayan textile artisans in Guatemala, who traditionally weave their own capsule wardrobe but now supplement it with western clothing items.
  • Using wardrobe studies to investigate ageing and clothing. Look at how the studies can be a guide and pathway to other ways of being. 
  • Taking a lifecycle perspective: look at the wardrobe as history. 
  • Deploying wardrobe methods to investigate identity and identity change: for example, gender, sexuality, everyday life, menopause, pregnancy, biopolitics and non-conforming men.
  • Investigating how digital apps can go beyond quantification of wardrobe – learn about user preferences, emotional durability, reasons for why clothes fall out of use.
  • Exploring the assumption that fit translates into longevity of use.
  • Using wardrobe methods as a way to create behaviour change – increasing engagement and awareness among people for example in power positions and politics.
  • Qualitative and quantitative data are important. Using hybrid wardrobe methods to investigate items sent for repair or taken to clothing swaps at work places, are good ways to follow their story and give valuable data for the use phase. 
  • Awareness raising power of wardrobe studies, how can we use wardrobe studies in developing new business methods that are not growth oriented? 
  • Comparing with post-Soviet countries, specifically in smaller villages in the country-side to open up bigger cultural context.

The participants were encouraged to contribute with their own related research, and we are looking forward to seeing these and adding them to the Wardrobe Studies Library.

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.

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.

A day worth marking for clothing research

April 8th, 2024, Iryna Kucher defended her PhD “Designing Engagements with Mending. An Exploration of Amateur Clothing Repair: Practices in Western and Post-Soviet contexts”.

Iryna was a guest lecturer at Consumption Research Norway SIFO a period as research fellow, she has used wardrobe studies as a method and Ingun was her first opponent. This was therefore not just an important day for Iryna, but also for the clothing researchers at SIFO – and clothing research in general.

Alongside Ingun in the assessment committee, was Senior Researcher Olga Gurova, Laurea University of Applied Sciences, Helsinki, Finland and Design School Kolding’s own emerita Vibeke Riisberg. The main supervisor had been Ulla Ræbild, and also Amy Twigger Holroyd, who followed online.

The thesis is a broad and deep dive into the culture of mending.  By looking at the history of
clothing consumption in post-Soviet and in the Western world, it describes how different histories have formed ideologies of consumption and clothing repair practices in people’s everyday life. Iryna contributes with lifting the description on repair out of a mainly Western-centred perspective. She has used a variety of literature and sources in Russian, Italian and Nordic languages, so not only English, being so often the case. The thesis has surprisingly no research question, but instead does a deep dive into:

1) Understand how mending practices are conceptualised in Western and post-Soviet contexts.

 2) Understand what kind of infrastructures, devices, and materials facilitate the enactment of mending practices.

 3) Understand what competences are employed when mending practices are enacted and what contributes to successful clothing repair.

Skål for Iryna! Surrounded by Ingun, Vibeke and Olga in the assessment committee.

The methodology is original and rich, and brings design research, the social sciences and wardrobe studies together.  Her wardrobe study has focused on what has been repaired – and what hasn’t been repaired – as much other research. An original contribution here is that this is not only done by the candidate’s main informants, but that together with their mothers or other older relatives, they did a similar exercise with the older generation. This gives the opportunity to look at the informants’ background and training and thus the relationship to repair over time. It is ambitious to draw in both comparisons in time and space. Iryna received a lot of praise for this during the defense, but also critical questions as she has gone to great lengths to summarize and simplify differences. After all, the history of repair is both invisible and full of holes, and it is easy to assert what are, strictly speaking, assumptions.

Contributions from the work that will probably be cited and develop further understanding are the concepts seamless, discreet and expressive approaches to clothing repair, instead of visible and invisible, which are more commonly used. Iryna’s point is that both invisible and expressive (what is often discussed under visible mending) require special expertise, while discreet is what most people try to achieve in private repairs – which is the vast majority.

It is also interesting how different groups do the same thing, e.g. repair for different reasons. «Post-Soviet ‘mothers’, who used to live in the Soviet repair society, which was characterised by scarcity, still associate mending with necessity. In contrast, Western ‘daughters’, who live in a time of eco-anxiety, associate mending with sustainability”.  The quote shows how comparing across generations and consumer cultures (post-Soviet and Western) makes sense. Also interesting from a SIFO perspective is Iryna’s discussion of the importance of home economics – i.e. training in needlework and repair at school. This is an important part of her description of how the infrastructure around repair disappeared in both the Western and post-Soviet context. In order to rebuild repair, a build-up of this infrastructure is needed, which is not only a willingness to teach, but also workshops in schools, sewing machines, textbooks, etc.

Many had found their way to the design school’s premises – and others followed the event online. Iryna’s work is nuanced, particularly well-presented visually and exciting, as already stated, a big day for clothing research.

TPR gets some serious airplay

Volumes, policy measures and Targeted Producer Responsibility all fitted into discussions the week before Easter, where some of us jumped back and forth between Webex, Zoom and Teams, recordings and live webinars. The take-aways are that several policy tools are mired in antiquated ideas that seriously need updating from research, and that the conversations around volumes and sufficiency are what actually can drive change.

STICA’s Climate Action Week coincided with intense webinars from EU’s Joint Research Center on ESPR’s stakeholder review and also PEFCR for apparel and footwear’s open hearing, presented by the Technical Secretariate’s lead. Yes, it was dizzying, but most importantly, Targeted Producer Responsibility and questions surrounding how EU actually plans to address the issue of volumes and degrowing the sector did got airplay.

Kerli Kant Hvass, who is one of our Wasted Textiles partners, presented Targeted Producer Responsibility during the session on the obstacles facing new circular business models during STICA’s Climate Action Week, hosted by Michael Schragger from Sustainable Fashion Academy and lead for Scandinavian Textile Initiative for Climate Action (STICA). In the session Circular Business Models Are Critical for Climate Action – So What Is Preventing Them from Becoming Mainstream? she explained the concept, and continued her argument during the panel discussion towards the end:

“Focusing on the product and assuming this will result in sustainability has serious limitations. Instead, collecting data in the waste streams, and establishing if a product has been used for half a year or for ten years, actually establishing its duration of service (DoS), can give the database for modulating fees.”

TPR got nods

We noticed that Maria Rincon-Lievana, from the EU Commission and DG ENV nodded a lot when Kerli repeated this. Sarah Gray from UK’s WRAP, who is wrapping up a PhD on to what degree circular business models actually have climate and environmental impact, wholeheartedly backed Kerli’s call for dating products in order to gain data on the actual DoS of products for comprehensive LCAs.  

Sadly Paola Migliorini, also from DG ENV, did not hear when Luca Boniolo from Environmental Coalition on Standards (ECOS) said the following in the session on The Legislative Race Is On: Legislation & Regulation in the European Union (we can only hope she reheard the entire session later):

“Labelling regulation presents an opportunity (…) for instance introducing the production date on the label (…) we can know how long the product has been circulated at the end of life. If we do waste audits, we can estimate the DoS to understand was it used to 10 years or was it used for two weeks and then it was discarded and it can also support consumers in knowing that they have the right of a legal guarantee from the purchase date of two years during which if the product fails under normal circumstances, they have the right of it being repaired for free.”

He said much of the same during the session on Sufficiency, To Green-growth, Overconsumption & Degrowth: Can Sufficient Emissions Reductions Be Achieved in the Current Paradigm?

“EPR can for instance be based on how long the product was on the market based on waste audits and the date of production, and thus we can modulate who will have to pay a higher fee. We need to incentivize the reduction of the volumes placed on the market.”

This is the whole idea behind TPR, and even if Luca did not specifically mention TPR, he was voicing the principles behind it.

Old-fashioned or not fit for purpose, or both?

So, what is old-fashioned about the approach the policy-makers are taking? What are the tools that are not fit for purpose?

As it was ESPR and PEFCR we were lectured on the same week, the following thoughts arise.

ESPR (Ecodesign for Sustainable Product Regulation) clearly is based on the faulty assumption that 80% of a product’s environmental impact is decided in the design phase. So, it is intertwined with predicting for example durability, repairability, recyclability and thereby assuming DoS. The problem is, as SIFO research shows, only one-third of textile products or apparel go out of use because they are used up, so if ESPR is going to eco-modulate EPR fees (which seems to be the idea) this will be based on pure guess-work, or what could be more diplomatically called predictions.

TPR suggests the opposite, building the eco-modulation on what becomes waste prematurely and modulated ‘against’ what captures value in the new business models, as Kerli so well described in her presentation.

The hen or the egg?

For PEFCR (Product Environmental Category Rules) the problem is that they are meant to underpin ESPR, but JRC have actually not decided if they are fit for purpose, they said as much in their presentation. So, currently PEF seems to be in limbo, perhaps only fit for Green Claims (Baptiste Carriere-Pradal said as much in his presentation, but also hinting that ESPR would have to use PEF).

PEF is not aiming to be a consumer-facing label, only a set of 16 “frankenproducts” (12 for apparel, four for footwear) which you as a company can compare your product to, and say if your product is “greener” than the “frankenproduct” based on very strict LCA parameters. The data-base that these parameters are resting on, have serious data issue, and may be why France when presenting their “amost-PEF-compatible” label, have taken out one of them (physical durability), In addition, France also is not making GHG emissions the most important parameter – counting for 1/4th of the ‘score’, which PEF currently does.

The main problem, though, is understanding. Consumers understanding what and why.

Simply: In ESPR there is a demand for recycled content, and this is heavily stressed. During the sessions, I asked simply “why?” and presented the latest IVL report with a 1.3% climate reduction for large-scale recycling in the EU. What also surfaced during the week was that only 11% of EU’s population want recycled content. So, win-win or lose-lose to demand recycled content?

Apparel for real life or for bureaucratic purposes?

The issue then feeds into PEF, and how the scores of the “frankenproducts” actually have meaning when talking about real life. Why are stockings, socks and leggings the same “frankenproduct”? What are sweaters actually – when we all know they differ enormously and also their function. It seems, in the end, that everything is a desktop solution for real life actualities.

Having good clothes that are fit for purpose, not apparel that fit policy purposes, should be the goal. They will be used the longest and deliver on DoS. Using ESPR, with PEF as the underpinning logic, will not at all help either the environment, climate change or Europe’s consumers.

So, all in all, listening to the STICA webinar, so well organized by Michael Schragger, gives better insight on where we need to go, than both the JRC organized webinar (which sadly is not publicly available even if it was recorded) and the PEFCR webinar (which can actually be accessed), put together. EU still needs to get their heads around that it’s not at the product level, but at the systems level, that change needs to happen. Let’s hope STICA gave them food for thought.