Feedback delivered on ESPR 2nd milestone
Consumption Research Norway (SIFO) and NICE Fashion have delivered feedback on the Preparatory study on textiles for product policy instruments: Ecodesign, EU Green Public, Procurement EU Ecolabel 2nd milestone. All in all 19 comments were prepared and submitted, after attending a two-day webinar in December 2024, where the 2nd milestone document was introduced.
The submission focuses on issues related to ‘durability’ and ‘repairability’, as these are key concepts from EU’s Joint Research Center, and according to them the main drivers for consumers to keep their apparel for longer. We do not agree with this, and have argued why in the feedback. The idea that Duration of Service can be predicted at the start of a product’s lifetime, is one of the things we argue against, and our recommendation is, as we have repeated often, to immediately start dating products, and use waste audits, or even better, SIFO’s new method to capture relationship between properties and use (more information on the method here clothingresearch.oslomet.no).
There are several other points we make, around issues such as PEFCRs, replacement, environmental impact, aggressive marketing, and volumes; and we hope this will be helpful in the work moving forward. We would wish that JRC took more of a consumer perspective, than an industry perspective in their future work on ESPR for textiles and apparel.
To read our feedback, you can download a pdf of our 19 comments here, each comment starts with where in the 2nd milestone the wording or issue we address is, as this was required in the feedback.