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.
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.
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.
Three days of multidisciplinary perspectives to overcome our society’s obsession with economic growth, sounds like a good way to round out the month of June? Obviously…
Consumption Research’s Irene Maldini took the trip to Spain to talk about durability’s role in our obsession with growing the textile sector, perhaps one of the sectors that really needs the opposite, or?
June 19th-21st 1200 academics, activists, and civil society organizations came together at the ESEE/Degrowth conference in Pontevedra, Spain to discuss the urgency, barriers and levers to enable a post-growth society as a way to tackle the current poly-crisis. The conference was hosted by University of Vigo. It was the first time for this conference to include a session on clothing and another one on consumer goods more generally, chaired by Katia Dayan Vladimirova.
Economic activity is a means for humans to live a good life considering that of other beings. But confusing the role of economic growth with an end in itself is hindering progress towards a more sustainable society. In the sector of clothing, fear of confronting economic growth is preventing sustainability actions to focus on the challenge that really matters: reducing production volumes.
In this context and as part of the CHANGE project, SIFO researcher Irene Maldini presented a study conducted together with Professor Ingun Klepp on the EU Strategy for Sustainable and Circular Textiles, published in March 2022. In an analysis of the policy making process, they identified two main factors that hindered the inclusion of measures to tackle production volumes in the strategy:
a) the framing of the strategy in terms of competitiveness, with a focus on companies as main stakeholders, and the associated fear of economic decline in a market where fewer products are sold, and b) a policy-making process prioritizing input from anecdotal knowledge (through participation of interested and available stakeholders), rather than empirical knowledge on the effect of applied actions or lack thereof. As a result, the EU Strategy avoided a focus on production volumes, aiming instead at the softer and politically objective of improving product durability, with questionable environmental benefits.
This was just one of the presentations analyzing how the growth logic underlies western policy and law, preventing significant progress towards climate targets, and the only one focusing on environmental policy for consumer goods.
The conference included scholars from a variety of disciplines such as environmental economics, political science, geography, law, marketing, indigenous knowledge, industrial ecology, etc. who discussed very diverse subjects related to social inequality and the environmental crisis. Next year the event will take place in Oslo, hopefully an opportunity to consolidate an international community committed to question consumerism and our dependence on growing volumes of consumer goods in circulation close to home. Next year’s conference will be June 24th till 27th, and CHANGE will plan something in conjunction with the conference, so clear your diary already now!
Economic activity is a means for humans to live a good life considering that of other beings. But confusing the role of economic growth with an end in itself is hindering progress towards a more sustainable society. In the sector of clothing, fear of confronting economic growth is preventing sustainability actions to focus on the challenge that really matters: reducing production volumes.
In the photo: Irene Maldini, Meital Peleg Mizrachi, Amy Twigger Holroyd, Katia Dayan Vladimirov.
Here the abstract:
More durable, or fewer products? A case study of the EU Strategy for Sustainable and Circular Textiles
The volume of durable goods consumed in Europe, and clothing in particular, has increased dramatically in the last decades, with significant environmental damage globally (Manshoven et al., 2023; Niinimäki et al., 2020). While early environmental policy to mitigate such damage focused on better production and waste management, more recently, increasing product durability to extend product lifetime has become a central approach. In a review of EU and Norwegian environmental policy applicable to consumer goods, Heidenstrøm et al. (2021) found little focus on product lifetime between 2011-2015, and a massive increase in 2015-2020 in line with the growing influence of the circular economy framework.
However, the environmental benefits of product durability for clothing and other consumer goods are questionable. Achieving environmental savings from keeping products and materials longer in use presumes that there will be a reduction in the production of new items, but this expected effect has not been sufficiently studied. The empirical evidence that is used to support the durability approach is limited to comparative life cycle assessments of longer and shorter life products (see e.g. WRAP, 2012). Such studies build on a view of consumption that assumes but does not test the idea that durable goods delay replacement purchases and implicitly consider production decisions by companies as a process driven exclusively by demand, therefore taking the associated savings in the manufacture of new products for granted (Maldini et al., forthcoming). But wardrobe studies (Laitala and Klepp, 2022) and waste audits of textiles (Fashion for Good, 2022; Refashion, 2023) show that garments and accessories are massively discarded while still in good material condition. Moreover, only a minority of the clothes acquired are motivated by product replacement (Maldini, 2019). The drivers of production volumes decisions by clothing companies have not been thoroughly investigated, but a few case studies point to a variety of reasons behind such decisions including companies’ market expansion plans and the strengthening of their partnership with suppliers (see e.g. Paton, 2018). In short, the assumed effect of product durability on production volumes reductions is problematic.
This contribution builds on a case study of the 2022 EU Strategy for Sustainable and Circular Textiles (European Commission, 2022) to show how, despite the lack of evidence mentioned above, product durability is promoted as a sustainable approach during the policy making process, while a direct focus on production volumes reductions was avoided through several mechanisms.
The study analyses how product durability and production volumes are regarded during the policy making process, on the basis of four aspects; 1) the strategy context, and its relation to other policy instruments and efforts, 2) the actors involved in the development of the strategy and their roles, 3) the discourse around product durability and production volumes, and how they are addressed during the policy making process, and 4) the knowledge base of the strategy; the sources of information that were considered to identify problems and applicable solutions. The material used to conduct the study includes policy and other publicly available documents, complemented by interviews with five key participants in the development of the strategy: one key employee of the European Commission, two members of external organizations that accompanied the development of the strategy from the early phase until it was released, and two key participants (and invited speakers) of the public consultation workshops. The interviews were conducted between February and April 2023.
Two main factors hindering the inclusion of product volumes reduction measures are identified: a) the framing of the strategy in terms of competitiveness, with a focus on companies as main stakeholders, and the associated fear of economic decline in a market where fewer products are sold and b) a policy-making process prioritizing input from anecdotal knowledge (through participation of interested and available stakeholders), rather than scientific findings or lack thereof.
The strategy aims at implementing the commitments of the European Green Deal (European Commission, 2019) and the Circular Economy Action Plan (CEAP) (European Commission, 2020a), as well as the Industrial Strategy (European Commission, 2020b) and post-COVID Recovery Plan (European Commission, 2020c). The EU’s CEAP has a two-side agenda focusing on the transformation of industrial processes, increasing resource efficiency, reducing environmental impact and the use of raw materials and hence bringing economic benefits and business opportunities to companies (European Commission, 2020a). Furthermore, the environmental targets of the Green Deal were matched with the Industrial Strategy, and the economic concerns about recovery of the EU from the COVID-19 crisis. Within the European Commission, DG Environment and DG Grow shared responsibility over the development of the strategy, reinforcing its two-sided nature. In this context, the narrative of value retention associated to the circular economy was a good fit, as it was product durability. Yet targeting production volumes reductions was out of the scope.
Corporations, and business associations were central actors in the policy making process. They were invited to provide informal input in the preparatory phases of the strategy, setting the stage for a consultation process that also emphasized business actors as main stakeholders. The online survey was accessible to anyone, but companies had the capacity to provide extensive input, while the representation of other stakeholders was limited. Although the report of the public consultation mentions that several NGOs and government representatives called for direct measures in consumption reductions (PlanMiljø, 2022), only durability makes it to the concrete solutions listed in the strategy, with overconsumption and overproduction expected to decline as a result of product lifetime extension and reuse (European Commission, 2022).
A critical analysis of the state of the art in scientific knowledge would have confronted the approach outlined above, but the knowledge management in the policy making process did not prioritize reliability and completeness of information. Members of the scientific community stressing the centrality of production volumes were discredited, and the focus was placed on ensuring adherence from businesses. In using secondary, tertiary, and non-peer reviewed sources as a knowledge base, the information was simplified and generalized to an extent where it met the anecdotal knowledge shared by involved stakeholders.
In sum, the EU Strategy for Sustainable and Circular Textiles provides an example of how the growth logic continues to shape environmental policy, leading to measures and regulation with questionable environmental improvements, and hindering the development of more effective measures to reduce the impact of European consumption.
References
European Commission, 2022. EU Strategy for Sustainable and Circular Textiles.
European Commission, 2020a. A new Circular Economy Action Plan. For a cleaner and more competitive Europe.
European Commission, 2020b. A New Industrial Strategy for Europe.
European Commission, 2020c. Europe’s moment: Repair and Prepare for the Next Generation.
European Commission, 2019. The European Green Deal.
Fashion for Good, 2022. Sorting for Circularity Europe.
Heidenstrøm, N., Strandbakken, P., Haugrønning, V., Laitala, K., 2021. Product lifetime in European and Norwegian policies. Oslo.
Laitala, K., Klepp, I.G., 2022. Review of clothing disposal reasons. Oslo.
Maldini, I., 2019. From speed to volume: reframing clothing production and consumption for an environmentally sound apparel sector, in: Nissen, N.F., Jaeger-Erben, M. (Eds.), Proceedings of the 3rd PLATE Conference. TU Berlin, Berlin, pp. 519–524. https://doi.org/10.14279/depositonce-9253
Maldini, I., Klepp, I.G., Laitala, K., forthcoming. The environmental impact of product lifetime extension: a literature review and research agenda. Clean. Responsible Consum.
Manshoven, S., Vercalsteren, A., Christis, M., De Jong, A., Schmidt, I., Grossi, F., Mortensen, L., 2023. Consumption and the environment in Europe’s circular economy.
Niinimäki, K., Peters, G., Dahlbo, H., Perry, P., Rissanen, T., Gwilt, A., 2020. The environmental price of fast fashion. Nat. Rev. Earth Environ. 1, 189–200. https://doi.org/10.1038/s43017-020-0039-9
Paton, E., 2018. H&M, a Fashion Giant, Has a Problem: $4.3 Billion in Unsold Clothes. New York Times.
PlanMiljø, 2022. Synopsis report on the consultation on the EU Strategy for Sustainable and Circular Textiles. Veksø.
Refashion, 2023. Characterisation study of the incoming and outgoing streams from sorting facilities.
WRAP, 2012. Valuing our Clothes: the Evidence Base. Technical Report.
Tanja Gotthardsen, a Danish anti-greenwashing specialist, Continual, and member of the advisory board for textiles at the Danish Consumer Council, Forbrugerrådet Tænk, has together with Professor Ingun Grimstad Klepp and Tone S. Tobiasson, penned a letter to the EU Council ahead of their vote on Green Claims Directive.
If the EU’s Green Claims directive is truly to become a silver bullet against greenwashing, it must, first and foremost, avoid contributing to greenwashing, which it stands in danger of doing, as the recent integration of references to the Product Environmental Footprint (PEF) for apparel and footwear (A&F) in the text, makes it possible to use this faulty tool for making green claims.
For us, it’s not a question of fibers or materials, but a question of consumers being misled by a tool of the EU’s own making. And the inclusion of PEF is truly premature, as it does not account for how apparel is actually, functionally worn and used – and use is, by far, the most important indicator for a garments environmental impact.
We therefore wrote in our capacity as researchers, concerned consumers, farmers, textile companies throughout the value chain, and NGOs regarding this potential damaging inclusion of PEF.
In the letter, which you can read here, we address specifically the numerous shortcomings of PEFCRs for A&F, which have been pointed to by many and certainly in the latest open public consultation. As it is far from clear how PEFCRs for A&F will be operationalized and this will be clear at the earliest in Q4 of 2024, we challenge the validity of including PEF as a potential system or tool for making green claims. That it is not mandatory, but still remains an option, is not acceptable as long as its final design is an unknown.
The letter builds on decades of wardrobe research conducted and policy recommendations provided by SIFO and Continual, as well as many other excellent people. A big thank you goes out to all the wonderful co-signatories from research, civil society and industry, that managed to get back to us so swiftly – this was truly a race against the clock.
SIFO has actively contributed with feedback to EU’s Textile Strategy, including on PEFCR, ESPR, the Waste Framework directive, etc. and also – as ECOBALYSE is based on much of the same background data – decided to deliver feedback on the French proposition.
In the feedback, we commend the French government, ADEME and ECOBALYSE is genuinely wanting to halt Fast Fashion (FF) and putting forward legislation that aims to do exactly this. However, we believe that something must be done about the fact that the tool underpinning the labelling scheme currently favors plastics. We are concerned that a labeling scheme which is intended to show what products are better for the environment, ends up supporting FF by promoting the continued plastification of apparel and footwear.
It is also commendable that ECOBALYSE includes an operationalized definition of Fast and Ultra Fast Fashion. Both the use of price and length of market presence are good indicators. For the length of time a product is on the market, we are, however, a bit confused by the longest and shortest intervals, and thereby that everything above and below 65 and 300 days, flats out.
We also have supplied some concrete suggestions, which you can read about in the feedback, which you will find here.
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.
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.
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.
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.
“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.”
“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.
