Telling it like it is: Lambasting consumer-facing Higg-based label

In a newly published article from Consumption Research Norway SIFO at Oslo Metropolitan University, Who Can Stop the Greenwashing, penned by Ingrid Haugsrud and Ingun Grimstad Klepp, the authors literally lambaste how the Sustainable Apparel Coalition (now Cascale) misused outdated and faulty data for their launch of a Higg (now Worldly) consumer-facing sustainability label.

In a detailed and thorough review of the case brought forward by Naturvernforbundet (Friends of the Earth) in Norway against sportswear actor Norrøna, who used the Higg MSI tool-based labeling scheme to market an organic cotton t-shirt as ‘less thirsty’ than a conventional cotton t-shirt, the authors question who has both the will and the impetus to stop greenwashing.

In the chapter, which is published in Mediating Sustainability in Consumer Society (Routledge 2024), they highlight the specific case in which The Norwegian Consumer Agency (NCA) issued a ruling in 2022: “the Higg MSI data did not constitute sufficient documentation for the claims made by the Norwegian trader in their marketing. The NCA concluded that the trader’s use of Higg MSI data in marketing was misleading, and therefore prohibited under the Norwegian Marketing Control Act”.

How the Higg Index Sustainability Profile Label was presented by Norrøna.

The result of the ruling was massive international media coverage, name-changes for both Higg and SAC, and that the Higg MSI-based label was discontinued. Assistant Director Tonje H. Drevland was responsible for the case on behalf of the NCA and is therefore an important part of this case. In addition to ruling that “Higg MSI data in marketing [is] misleading, and therefore prohibited under the Norwegian Marketing Control Act, which is based on the EU Unfair Commercial Practices Directive (UCPD). This conclusion could be seen as a warning to other traders operating in the EU/EEA area, as the NCA found that the use of Higg MSI data in marketing towards consumers in general could easily be misleading.”

The NCA has for a long time provided general guidance on the use of environmental claims in marketing. As a result of the ruling, the SAC (Sustainable Apparel Coalition) asked for more specific guidance. This resulted in GUIDANCE TO THE SUSTAINABLE APPAREL COALITION ENVIRONMENTAL CLAIMS IN MARKETING TOWARDS CONSUMERS BASED ON THE HIGG MSI – written in collaboration with the Netherlands Authority for Consumers and Markets (the ACM).

Brad Boren (Norrøna) and Tonje Drevland (NCA) discussing the ruling.

The ruling was presented in letters, on webpages, in the aforementioned guidance, in lectures, and in the SAC’s annual conference for the textile industry. Here, Drevland’s message is particularly clear: “I want H&M, Inditex, all large players to take a step back and realize that the steps they are taking internally may feel [like a great cost] to them but remember to look at it from the other side, from the environmental perspective.” She also stressed that “wrong information is worse than no information“.

Which, of course, is counter to the argument used by SAC (Cascale), who have repeatedly claimed that lack of perfection should not come in the way of using the Higg data, nor hinder it from being fed into the Product Environmental Footprint Category Rules data-base.

Ingun Grimstad Klepp explaining the process that is also described in the recent publication.

The critique from the NCA on the use of the Higg MSI or rather the Higg Index Sustainability Profile is as follows:

  • Global averages are not product-specific.
  • The LCA data that backs the global averages and the Higg MSI is outdated.
  • In addition, the LCAs underpinning the claims were not intended for the comparisons that were made.

More consequences followed: The NCA sent a warning to the Swedish fast fashion actor H&M, in case they considered using the Higg Index Sustainability Profile in marketing in Norway, as well as a letter to the SAC (Cascale) telling them to inform all their members about the ruling, and what consequences similar claims on the market in Norway could trigger. In addition, they informed other consumer authorities in the EU/EEA about the decision and issued a general warning to “other traders operating in the EU/EEA area”. Furthermore, NCA started a coordinated action from the Consumer Protection Cooperation Network (CPC), coordinated by the European Commission and led by four consumer protection authorities from Germany, Denmark, Norway, and Sweden against Zalando. According to a press release from the EU from February 2024, Zalando removed all their misleading environmental claims from their website. Thus, a large international player was forced to follow “the ruling”.

The SAC issued a response to the NCA ruling, stating that they will launch a third-party expert review of the Higg MSI and collaborate with the NCA on how to present information to consumers, and in 2023 KPMG did publish a report, but this did not answer the main question whether the data was suited for consumer-facing information or not. They wrote that this would depend on how PEF developed. The NCA’s strong criticism of the Higg Index Sustainability Profile was particularly serious as the SAC and their work with the Higg have been central to the development in the early stages of the EU’s planned anti-greenwashing weapon, PEF. Seeing the ruling and PEF (and the data underpinning PEF) in coherence is a discussion theme – which the EU Commission has tried to avoid – repeatedly dodging the “bullet” and insisting that they are not at all related.

The SAC (Cascale) is also a member of the Policy Hub. Prior Chair of the Policy Hub Baptiste Carriere-Pradal has been the Chair of the Technical Secretariat of the Apparel EU Product Environmental Footprint. The secretariat voting members are dominated by the industry, and the SAC members have a majority of the vote, which they pay a substantial sum to have. As already mentioned, the data and the studies that underpin the Higg MSI are to a large extent the same data and studies that are being used in the development of the PEFCR.

Discussing the ruling during the IWTO Roundtable in Nürnberg in 2022.

The European Commission’s Joint Research Centre has been tasked with verifying the scientific robustness of the database. Obtaining new Life Cycle Assessments (LCA) suitable for comparison is both challenging and expensive, and even more difficult if global averages cannot be used, which is the mainstay of the LCA-based Higg MSI. Another problem is that parts of the tool are behind a paywall and therefore unavailable to consumers and for documentation, further hindering a democratic process. When the complaint was filed by Friends of the Earth Norway, they chose to pursue the case because the complaint referred to scientific papers that questioned the Higg MSI data.

This gave research and critical journalism an important role in unpacking the issue. Most notable was the work of Veronica Bates Kassatly, an independent analyst and consultant who has authored several white papers with Dorothée Baumann-Pauly: The Great Green Washing Machine: Part 1 and more importantly Part 2) The Use and Misuse of Sustainability Metrics in Fashion. Worth mentioning is also her significant contributions related to cotton and other fibres, and how the incorrect claims and misuse of LCA data abound. The articles can be found here.

Both academic research and critical journalism have pointed out serious weaknesses in the Higg MSI in general, and the claims surrounding cotton in particular. It is also evident that research and critical journalism played a role in documenting the controversies and providing the necessary information to the consumer authorities.

The NCA’s ruling stated that the Higg Index Sustainability Profile was greenwashing if the use of the scheme was consumer-facing. In contrast, their authority had no means to say anything about the tool as such. It can still be used business to business (B2B). The same information used B2B could be particularly harmful because it is to a greater extent used as a basis for decisions – which in turn affects the consumers’ options and the downstream producers. It is also possible that the power of consumer authorities, and especially the NCA, shown in the ruling, is easily pulverized if the communicator of the unreliable information is no longer the company itself, or industry organizations such as the SAC (Cascale), but authorities such as the EU, through tools like the PEF.

The article stresses that this perspective is important, and also resulted in a lot of attention in the international press in the aftermath of the ruling. Articles with headlines like “EU PEF tool’s regulations in question now after Higg’s MSI” stating that “A group of 12 organisations have expressed their concerns over the EU Commission’s plans to use Product Environment Footprint category rules (PEF-CR) ‘as a standalone method’ for communicating green claims in apparel and footwear” or “After Higg Came Under Fire for Greenwashing, Now This One’s in the Hot Seat, Too”. PEF might, in other words, just as well be a powerful greenwashing tool – if the knowledge it is based on is insufficiently documented, outdated, contested, or irrelevant, to mention some of the criticisms against the Higg MSI.

The SAC (Cascale) themselves, have called for speeding up the PEF process, and one can wonder why.

It will become more difficult to stop greenwashing based on a lack of documentation if this is hidden in the PEF system. Finding the numbers behind the score will demand a lot of detective work from consumers and others. It will perhaps become even more important to establish what is essential and relevant information for consumers.

Tonje Drevland discussing the consequences of the ruling during an OECD conference.

“Mediating Sustainability in the Consumer Society”, edited by Astrid Skjerven, Lisbeth Løvbak Berg, Liv Merete Nielsen and Dagny Stuedahl, will be launched in Oslo January 29th 2025, 4 PM. More info here.

The article Who Can Stop the Greenwashing, can be accessed here.

Clothing Research’s Lisbeth Løvbak Berg, who is co-editor, also has written the last article in the book: Indigenous approaches to mediation of the climate and nature emergency: a conversation with Vanessa Andreotti. 

Access the book here.

Clothing Care

“And he don’t even care for clothes” sang Nina Simone in “My Baby Just Cares For Me” which is how the chapter “Clothing Care” opens in the new, impressive and comprehensive book “The Palgrave Handbook of Sustainability in Fashion”. 

Clothing researchers in SIFO use the Nina Simone quote to discuss the connection between “care[ing]  about clothes, people, and nature. There is a connection between care as something practical and mundane, such as washing and repairing clothes, and the more general feeling of wishing to preserve something. The chapter spans from presenting knowledge on techniques used to maintain (care for) clothing such as washing, repair and storage; to discussing the prerequisites for caring about this.”  

Ingrid Haugsrud is the first author. The text is based on data from her MA thesis in Fashion and Society from OsloMet. In 2016, s0he performed a wardrobe study with six informants in their 20s, and 63 favorite garments that the informants valued especially were registered. These were the garments that their wearers cared for both in emotional and practical terms. The other authors, Ingun Grimstad Klepp and Kirsi Laitala, use these specific examples to paint a picture. Together, they have extensive experience with scientific publications about different care techniques such as washing, repair and clothing use, as well as repurposing of clothing in the wardrobe. As such the text summarizes a lot of knowledge in addition to relating it back to topical discussions today; what can lead to change and the relationship between technical lifespan and longer use time.  

The chapter is a product of the CHANGE-project. It uses wardrobe studies, empirical data and discusses a variety of topics such as how one environmental challenge, the volumes of clothing that are being produced, can be reduced. It points out that helping consumers to better take care of their clothes is not a vailable solution, as consumers would only take better care of their if they owned fewer pieces. For Ingrid, this work is not only important because it brings forth the important work she did on her MA thesis, but also because it is an early preview of what she will work on in her PhD, which is fittingly a part of the larger CARE-project. She hit the ground running by acquiring a publication in the field at the very start of her PhD journey.  

We have not read the book in its entirety thus far, yet we have to prize its wide subject matter. It does not only include the environmental side of sustainability, but also the cultural and social aspects. We were able to find much more information in this book compared to most books on topics such as clothing consumption and production of clothing and shoes in and outside of Western Europe and USA.

Post growth (?) fashion webinars

Dec. 13th 2024 15-16 CET (3-4 pm)
and
Jan. 16th 2025 15-16 CET (3-4 pm)

Two consecutive talks by Consumption Research Norway SIFO at OsloMet
First one with Prof. Ingun Klepp and Tone Tobiasson and in January Kate Fletcher.

December 13th: Prof. Ingun Klepp, Professor at the National Institute for Consumer Research, and Tone Tobiasson, Author and journalist, from Oslo, Norway. One of the most passionate and influential tandems in the textile research / policy space, with a long track record of pioneering research projects that changed our understanding of the use phase of garments, post consumer textile flows and plastification of fashion.

There is a cap for 100 people to attend each webinar. To attend, RSVP through the associated link to get a calendar invite.

January 16th. Kate Fletcher is one of the most renown sustainable fashion researchers. Her work, including that on systems change, post-growth fashionfashion localismdecentering durabilityEarth Logic and nature relations both defines and challenges the field of fashion, textiles and sustainability. She has written and/or edited 13 books available in eight languages, and in 2022 she was identified by author Margaret Atwood as a visionary. Kate is a co-founder of the Union of Concerned Researchers in Fashion. Her most recent work is about design, clothing and nature.

There is a cap for 100 people to attend each webinar. To attend, RSVP through the associated link to get the calendar invite.

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.

New PhD makes a splash: The function of the laundry and the limitation in self-reported data

Chalmers University In the heart of Gothenburg hosted the defense for Erik Klint on September 6th. Klint’s PhD, consisting of 5 published articles and some additional published material, was discussed with professional curiosity and benevolence, and the atmosphere was positive throughout.

Author: Ingun Grimstad Klepp

It is not easy to work interdisciplinary, but as the head of the Grading committee Professor Michael Zwicky Hauschild, Denmark’s Technical University summed up: Here we have well-defined research questions, identified knowledge gaps and an exciting journey between the two different academic traditions, a travel from environmental impact to psychology and then back again to Life Cycle Assessments (LCAs).

Functional unit must define a function

The work’s most important conclusion is that what people do – and what psychologists call behavior – must be included in LCAs. The functional unit cannot be kilos of laundry, but rather what the function is or can be. The most important function of clean clothes is to make us feel socially safe. This is the functional unit that Klint argues for and was supported by the LCA expert from the Technical University of Denmark. A FU must be a function, something the product or test is used for in order to achieve an outcome.

There was a lot of discussion about this point during the defense, both from the opponent, Professor Wencke Gwozdz, Justus Liebig University of Giessen, and from the audience. Because: Doesn’t laundry also have other functions? And can this be a function or functions that is or are actually difficult to measure? Yes, but as Klint demonstrates, it is this (that is, what is needed to perceive something as clean) that has changed the most and also has the greatest impact on the environmental footprint of laundering.

Both during the discussion and in the thesis, Klint draws in clothes and their functions, and I took the opportunity to point out that the use of LCAs is much more problematic for clothing than for laundry, and that his work will thus possibly have greater consequences for this field.

Better data

After the defense, the supervisors and the committee took part in a tour of the Living Lab, flats inside the Chalmers campus area that has been trialing new solutions and more community-based services. A shared laundry room was located centrally in the building by the entrance, and together with a pleasant living room that included tools for repairing clothes, exercising, or a space just for hanging out. The Living Lab has student housing and apartments, and those who live there must approve that data from their laundering is included in research.

Greg Peters explains how data was collected from the washing machines. He holds up a chip similar to those sewn into the clothes to provide data on washing frequency. Not surprisingly, the ethical aspects of this type of data collection were also discussed during the defense.

Supervisor Gregory Peters Professor, Environmental Systems Analysis, Technology Management and Economics, proudly showed off how they had modified the machines to collect data and also the chips they had sewn into the clothes to collect details about washing frequency – among other things. In his work, Klint contrasts what people say and what they do. And the difference is big! Not least, this applies to washing “full machines”, where the result shows that that what people think is a full machine, varies greatly. This has major consequences for the environmental impact of laundry, which easily becomes more than twice as high if the filling rate drops to half capacity. In the comparison of self-reported data and data from the Living Lab, Klint also used pictures to illustrate what the machine looked like when it was fully loaded. This gave a clear picture closer to the actual degree of filling, than words alone.

Numbers and culture

The work done by Klint is based on quantitative analyzes and a lot of number crunching – as is expected in a thesis that seeks to improve an LCA tool. But Klint himself found that the cultural aspects of cleanliness and changes in these, alongside that there are so many different ways of thinking about how things should be sorted and what can be washed together with what, were a very interesting aspect to explore. It was thus with great respect for the nuances of human nature that his analyzes were made. He found that attitudes towards the environment played no role in washing frequency, but that other variables could explain quite a bit. Another nail in the coffin for the idea of ​​”enlightenment” as important for changing people’s actions.

Increased sensitivity to disgust, shame, or cleanliness norms were associated with a higher washing frequency per person. Thus, most important were shame and disgust – i.e. the discomfort perceived in what dirt and smell causes in social settings.

Both concepts were discussed based on psychological theories and literature on these feelings. Klint argued that people do not load a load of laundry to use (or not use) energy, but to have clean clothes, or because the laundry basket is full. This is obvious – but as long as LCAs are developed with a technical starting point, e.g. how efficient a machine is – it is necessary to point this out and change the LCAs so that what people actually do, is taken into account.

Changes in technology and infrastructure also change habits, and this interaction disappears if only kilograms of laundry are studied, not the need for clean clothes. This then immediately raises bigger questions because what is really a need? And how is it that what is perceived as necessary, common, decent, etc. changes? Klint couldn’t answer everything, and this was not expected. Nevertheless, we couldn’t help ourselves – because his work opens up big questions that will probably become even more urgent if we transfer the discussion from laundry to clothing.

Despite the fact that we at SIFO is neither an LCA expert, nor a strong psychological approach, the conclusions was just as much what we have – or could have – done a lot. The will to find better data than what people themselves report, and not least the combination of technical and social science approaches, made the work familiar in a certain sense. There were also plenty of SIFO references in all the articles.

Cheers for Chalmers

It was fun to take part in this defense, everything from small technical details and information, to the big questions, were handled quickly and professionally. There was a good mix of friendly conviviality and academic celebration over the ceremony.

In the back, from the left, supervisor Greg Peters, Professor of Quantitative Sustainability Assessment, Scientific Director Swedish Life Cycle Center, Division of Environmental Systems Analysis, Department of Technology Management and Economics, Chalmers University of Technology, Professor Lars-Olof Johansson University of Gothenburg, Department of Psychology, Grading committee member Dr Alessio Mastrucci, International Institute for Applied Systems Analysis. Next row: Grading committee members Professor Michael Zwicky Hauschild, Denmark’s Technical University and Professor Ingun Grimstad Klepp, Oslo Metropolitan University, Opponent Professor Wencke Gwozdz, Justus Liebig University of Giessen. In front Erik Klint.

For me, this was an educational trip that shows that other subjects and traditions have a lot to contribute, but also that ideas and traditions we have advocated for decades, such as the importance of the use phase, are indeed supported in other subjects and methodologies.

Access the PhD here.

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.

Feedback delivered on ESPR 1st milestone

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

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

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

–          verify the work done to date, and

–          collect additional evidence on the investigated topics.

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

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

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.

Wardrobe Size (Volume of Clothing) and Shopping Practices in India  

Author: Richa Jha, India, Ambassador @RemakeOurWorld, Member @UCRF

Aim of the study

It was a fact-finding study to create awareness and behavioural change.

The objective of the study

The objective of the study was to find the shopping preferences and volume of clothes owned by an average Indian woman and a man.

What has influenced or inspired your approach?

I was influenced by the Wardrobe studies on this blog and particularly influenced by The Plastic Elephant Report, which said that poor fit and quality leads to wardrobe surplus and in-turn to over-consumption and over-production. Hence, I was curious to find similar statistics for India.

Method

  • An online questionnaire was circulated to individuals from different cities and professions. The questionnaire was sent to over 400 individuals out of which 105 chose to answer voluntarily.
  • There were questions such as – How many clothing items they buy? How many times a year? How many clothing items they own by category such as t-shirts, trousers, sarees, etc.? How many items they discard? Do they opt for repair, why not?
  • The income class of the respondents was middle class and above, i.e. Rs 500,000 per year
  • 70% of the respondents were women and balance were men.
  • More than 56% were Gen X, another 31% millennials, and 12% Gen Z. More than 56% were from Metros, 36% from Non-metros and the balance 9% were living outside of India.
  • Calculation of average wardrobe size – In the questionnaire, respondents were asked to tick mark the count for each clothing type such as Trousers, Shirts, T-shirts, Coats, Indian Wears, among others. The ranges were 0-5, 6-10, and so on till more than 30. The wardrobe volume is calculated by adding the average numbers for each clothing type for each individual.

Link to questionnaire here.

Key findings of study

The majority of the respondents shop up to 10 items annually and the average discard rate is also 10 items per person per year.

The volume of clothing owned (by this group) ranges from 30 to 308 in case of women and 27 to 162 in case of men. The mean is 120 for women and 80 for men.  For millennial women, average is 110, on the other hand for Gen X it is 130.  This suggests that women’s collection grow as they age, over time, they tend to accumulate Indian traditional wear such as sarees.

1 in 4 respondents do not use more than 40% of their wardrobe. The reasons for not utilising the wardrobe fully were occasional wears, woollens, fit issues, out of fashion and lifestyle changes in that order.

Only 20% of the respondents do not opt for repairing their clothes, on the contrary only 13% opt for upcycling. Among those who do not repair or do not opt for professional repair, majority do not see any value in repair or feel that new clothes are available at affordable rates.

The utilisation of the garment is optimum as most people said that they wear the garment till it fades or is worn out. Only for occasional wear or in some cases for formal wears, the number of wears is less. Some respondents mention they prefer to give to charity rather than repairing or upcycling.

But 80% of the respondents are willing to get their clothes repaired through a professional service and are willing to pay 15-20% of the original cost of the dress.

What happened after the study/exercise? What did you do with the results? Did you meet your objectives? How? How were the data used?

The report was shared with all the respondents. It gives them an idea as to where they are as compared to the average and hence may lead to self-induced behavioural change. Link to the report here.

A discussion was held with Sustainable Fashion Advocates from RemakeOurWorld. It further brought out the “whys” from the data such as cultural reasons.

The findings are also used to create awareness campaign through social media.

How could this specific method be used by others (or is it used already)? What are other insights/results that this method can generate?

Quantitative surveys are the most commonly used data collection method in Market Research.

How could the results of your study/experience be used by others (or are they used already)? What is the most important experience you want to share with those who are new to wardrobe studies?

  • Need for bigger and scientifically chosen sample if conducting a quantitative study
  • In the count, have zero/none separately from lower counts, i.e. instead of having 0-5, have none, and 1-5

What insights does this method generate?

It gives quantitative data on the total volume of clothes owned and clothing type. Filling this survey itself was an eye-opener for many and for them to realise their ownership, usage and surplus. The questions on repair and upcycling will also lead to plausible solutions, such as repair, alter, resale, lend or rent to increase wardrobe utilisation.

References

The Plastic Elephant – access here.
How clothing affects climate change? – access here.
Nielsen Woolmark Study  – access here.

Appendix: Definitions of some terms

Metro – Metropolitan areas – Such as National Capital Region of Delhi, Mumbai, Bangaluru, Hyderabad, Ahmedabad, Pune and Jaipur

Non – Metro – All other Tier-2 and 3 Towns such as Indore, Dehradun, Rajkot, Bharuch, Coimbatore, Trivandrum, Ludhiana etc.

Saree – a garment consisting of a length of cotton or silk elaborately draped around the body, traditionally worn by women from South Asia.

Lehenga – Lehenga is a three-piece ensemble consists of the actual lehenga, a long ankle-length skirt, a well-fitted blouse top known as the choli, and a scarf to drape around the outfit, known as the dupatta.

Gen X – 43 to 58 Years I Millennials – 27 to 42 Years I Gen Z – 18 to 26 Years

Fashionscapes for Transformation: EU addresses plastification and a just transition

The main point made during EcoAge and MEP Alessandra Moretti’s joint event in the EU Parliament was to link the increased plastification in the fashion sector with social injustice upstream and downstream in the value-chain.

Livia Firth, founder of EcoAge and moderator of Fashionscapes for Transformation, has relentlessly these last months hammered in the point that these are two sides of the same problem at several high-profile events, namely the massive overproduction of apparel. No less for the second time in the EU Parliament.

The mix of speakers and participants was impressive, with representatives both old and young, from industry and research, as well as political heavy-weights, and voices both from the Global South and North. The voices heard during the event were diverse, but unison in their messaging: The massive overproduction, based on cheap synthetics, cannot continue. This has even sunk in with the policy-makers, who echoed the same concerns in well-prepared speeches, in line with Commissioner Virginijus Sinkevičius key-note, stating “fast fashion must become past fashion”.

SIFO’s Ingun Grimstad Klepp, who had been – together with Irene Maldini – a speaker at the last EcoAge event in the Parliament, had no official role in Fashionscapes; however, Livia Firth asked her intervention after the panel had presented and discussed multiple aspects related to social issues missing from the Textile Strategy, and what instruments could encourage deplastifying. The much-repeated idea that quality or durability are the silver-bullet that will instantly degrow the sector was, however, debunked by Klepp. But before getting to this, let us dive into the proceedings.

MEP Beatrice Covassi in the foreground. Right before Ingun Klepp (seated to her right behind) was asked to intervene.

It was to be sure, an intense two-hour wake-up call, related to EU’s Textile strategy and Green Transition. MEP Alessandra Moretti, as hostess of the event and key note speaker Commissioner Virginijus Sinkevičius both high-lighted how ambitious these plans are, and had many good points in what they brought forward. Where disagreement surfaced, was around fiber-to-fiber recycling of synthetics – presented as a potential for a thriving new European industrial bonanza. As several pointed out, this will only increase the use of synthetics, continue to bring down prices and result in even more microplastics. As China produces 95% of today’s synthetics, why should they sit back and see Europe take over the market? That is not how market economics work. This is a blind alley, or as we say in Norwegian ‘believing in Santa Claus’, as several in the audience reiterated.

The main theme was divesting the fashion industry of its fossil fuel reliance, of course also in the fiber area, with waste colonialism and degradation of nature in the global south to satisfy the constant craving for newness in the global north, resulting in massive overproduction. This is of course based on fossil fuel input, but as just pointed at, recycling the same material is not the answer.

Livia Firth, MEP Alessandra Moretti, Commisioner Virginijus Sinkevičius, Simon Giuliani from Candiani Denim and CEO Laurence Tubiana, European Climate Foundation (ECF).

“This shows how the issues cannot be dealt with in isolation, but we need to look at them more holistically than is currently done in the 16 (or more) legislative pieces forthcoming from the EU,” was echoed by several participants after the meeting.

Laurence Tubiana, CEO of European Climate Foundation, who was the last speaker on the panel, claimed she was rather shocked that social issues are not better integrated into the Textile strategy where 80% of the work-force, we were told, is female and does not receive a living wage. However, these workers are also the ones facing the brunt of climate change, toxic chemicals in the soils and waterways, alongside being at the receiving end of our textile waste.

“Children in Ghana grow up not knowing what the ground looks like, as it covered with a permanent layer of textile waste,” Matteo Ward, Co-Founder of Wrad Living, told the audience. He was echoed by Yayra Aghofah, Founder of The Revival in Ghana who pointed out that they have to pay for this same waste that pollutes their environment and that will eventually end up as microplastics. This sad fate, several came back to.

MEP Beatrice Covassi immediately followed up Ingun Klepp’s intervention, requested by Livia Firth, Yayra Aghofah, founder of The Revival, online, in the background.

Black Friday was also a theme, as Yayra Aghofah suggested that they would be inundated with the results of this frenzy very soon, so action is needed now, not in 2026 or 2030. This, of course, underpins the need of immediately labelling season and year products go to market, so that Duration of Service can be captured when the items go into the diverse waste streams. Panelist Paola Migliorini from DG Environment claimed the EU “is helpless in regulating Black Friday”; ignoring that there are ways to legislate or counter-act such market forces with so obviously devastating outcomes. However, it was positive that overproduction had such a central place in the proceedings, both related to how they tie in with the plastification of fashion and with waste colonialism.

During the panel discussion, Livia Firth used the phrase “the Plastic Elephant in the Room” referring to the very back-bone of the fast fashion industry, synthetic fibers and their exponential growth, giving a nod to Consumption Research Norway’s recent report The Plastic Elephant: Overproduction and synthetic fibres in sustainable textile strategies.

Three from the audience were asked to intervene at the end, the first was Urska Trunk from Changing Markets Foundation, talking about the source for polyester for several fashion companies is still Russian oil.

Ingun Klepp, MEP Alessandra Moretti, and to the far right MEP Beatrice Covassi. The woman in the middle of th MEP-bouquet we haven’t yet identified…

Then Ingun Klepp was asked to comment on ‘quality’, and she explained how the only information consumers receive is price, and this isn’t necessarily directly related to quality. She then went on to say that with the EU’s strategy focusing on durability, plastics will win. This in light of the reality that people do not discard textiles because they are ‘used up’, and this is the problem facing the Global South and receivers such as The Revival. Especially as there is more and more polyester, and will be more, and these materials, when exported to the Global South rather than incinerated, will eventually end up as microplastics.

This was immediately picked up by MEP Beatrice Covassi, who clearly was frustrated with the fact that the consumer has so little information about the products available and thus struggles to make good choices, and wanted to applaud professor Klepp’s input.

The last person, who was asked to comment, was Nicholas Rochat, Founder of the plastic-free sportsbrand Mover, who said that with more recycled polyester – even fiber to fiber – will only contribute to more microplastics. He described being in the mountains at 2000 meters, and still encountering microplastics, and no longer being able to eat fish, as they are contaminated.

But the main take-away was that the Commission seems to have a belief that all the 16 plus different policy instruments will ‘even everything out’, but the reality is that they are in danger of making things worse in tandem, actually promoting synthetics, if the focus on durability continues alongside eco-modulating fees based on weight.

As the participants filed out, one of them sidled over to Klepp and said, simply: “Norway, douze points”.