SIFO-paper presented at Degrowth conference: More durable, or fewer products?

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.

Letter sent to the EU Council

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.

On clothing and … love!

June 3rd, 2024, Ana Neto graduated as a Doctor in Design at the Lisbon School of Architecture, University of Lisbon with her research on “Usership in Fashion: A Grounded Theory on Wearer-Clothing Relationships”, which she carried out under the supervision of João Batalheiro Ferreira (IADE) and Gabriela Forman (ULisbon)

SIFO researchers Kate Fletcher and Irene Maldini were part of the scientific committee in the defense, therefore it was not just an important day for Ana, but also for SIFO. In 2022, Irene was part of Ana Neto’s intermediate evaluation committee and they worked together at the REDES office in ULisbon, where Irene was a visiting researcher. Later the same year, Ana Neto participated in a series of discussion sessions for international PhD candidates on fashion and sustainability organized by Irene at Lusófona University. In 2023, Ana Neto met the other SIFO clothing researchers during the PLATE conference in Helsinki. She has been an active member of the Union of Concerned Researchers in Fashion and has worked closely with Tone Tobiasson in the Social Change and Policy working group of UCRF.

In her thesis, Ana Neto draws a parallel between interpersonal love and wearer’s relationships with clothes, stressing the importance of overcoming conflict as an inevitable element in any relationship, and using wardrobe studies among other methods. She highlights the role of design in assisting processes of use to promote longer lasting clothing relationships with wearers. Such issues are explored under guidance of the following questions:

How do wearers develop long-lasting relationships with their clothes?
What is the role of design in supporting wearer-clothing relationships?

Ana Neto’s engaging writing style helps readers to stay connected to the conceptual depth of her research. Her curiosity, hard work, and proactive attitude to connect with relevant scholars in the field have been outstanding, and she will surely continue contributing to the field in the years to come. See her contribution to SIFO’s Wardrobe library here.

In the photo: Dr. Ana Neto and the scientific committee during her PhD defense at ULisbon. From right to left: João Batalheiro Ferreira (supervisor), Ana Neto (candidate), Vitor Manuel dos Santos, Kate Fletcher, Graziela Sousa, Maria João Pereira Neto, Irene Maldini

The output of Ana Neto’s PhD trajectory includes the following publications, which are compiled in her thesis:

Neto, A. and Ferreira, J. (2020) ‘From Wearing Off to Wearing On: The Meanders of Wearer–Clothing Relationships’, Sustainability, 12(18), p. 7264. Available here.

Neto, A. and Ferreira, J. (2021) ‘Through Thick and Thin: Committing to a Long-Lasting Wearer-Clothing Relationship’, 4th Product Lifetimes and the Environment Conference (PLATE 2021), Limerick, Ireland (online), 26–28 May 2021. Available here.

Neto, A. and Ferreira, J. (2021) ‘‘I Still Love Them and Wear Them’— Conflict Occurrence and Management in Wearer-Clothing Relationships’, Sustainability, 13(23), p. 13054. Available here.

Neto, A. and Ferreira, J. (2023) ‘Lasting Bonds: Understanding Wearer-Clothing Relationships through Interpersonal Love-Theory’, Fashion Theory, 27(5), pp. 677–707. Available here.

Neto, A. (2023) ‘Wearer-Clothing Relationships as a System (and where to intervene)’, in K. Niinimäki and K. Cura (eds) Product Lifetimes and the Environment Conference, Proceedings 5th PLATE Conference, Espoo (Finland), 31 May–02 June 2023. Espoo, Finland: Aalto University publication series, pp. 711-716. Available here.

Neto, A. and Forman, G. (forthcoming) ‘Mediating wearer-clothing

relationships: a case study in Fashion Design Education’, in K. Scott, B. Curtis and C. Pajaczkowska (eds) The Future of Fashion Education: Speculation, Experiences and Collaboration, Routledge.

Neto, A. (forthcoming) ‘One Dress, 100 Days: Addressing Pervasive Conflict in Wearer-Clothing Relationships’, Clothing Cultures, 9(1).

Socks – the most neglected of all garments

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

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

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

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

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

ECOBALYSE feedback delivered

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.

Wardrobe Methods webinar opens up the field

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

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

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

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

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

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

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

New consultation on PEF: Feedback delivered

We have submitted feedback for the Product Environmental Footprint Category Rules. A total of 355 responses have been submitted with a total of 5125 comments. You had to fill in an Excel form, which was a bit challenging to navigate. We have therefore extracted the answers from the Excel sheet and created a document that is easier to read, click here.

PEF is intended to be used for all products, but this consultation concerns clothing and footwear. The aim has been a label for everything put on the European market, but the plan has been scaled down to a tool that will “only” be used to document green claims. The calculation tool itself, however, is the same. Products put on the market can be compared with a “normal” product in the same category. 13 categories have been created to cover all types of clothing and shoes.

The only of these categories where fiber or material is mentioned are under sweaters, where wool is mentioned (but not alpaca) and jackets/coats, which include leather jackets. For each of these “phantom garments” what is measured and weighted is very different, and this makes it hard to understand what you are actually comparing against. For example, “land use” (how many kilograms of fiber you get per square meter) is the most important factor for sweaters and “midlayers”, not for any of the other product groups. What the logic is for this, is impossible to find out in the many and long background documents.

Stumbling blocks

The consultation process itself has been anything but democratic, with stumbling blocks on all levels. Just getting into the EU database to deliver a response has been difficult without a black belt in passwords and apps, and as mentioned, you had to read hundreds of pages of background material and refer to exactly which document, which chapter and which line was being addressed. But perhaps the worst thing is that the documents don’t really say what the result of all the various data-inputs will actually be. Before we submitted the response, everyone could participate in a webinar where we were told that, for example, complaining about microplastics not being included would fall on deaf ears because the very tool underpinning PEF (LCAs) do not allow any new parameters to be added.

So even though the EU Commission had instructed the working group working with PEF for clothing and shoes to include the problems surrounding microplastics, we were told that there was no point in pointing out the obvious weakness that this has not been done. The fact that one can voluntarily say something in the product information about microfibres (not microplasics specifically) does not solve this major problem.

Understanding the functional unit

Another problem is the weak understanding of the functional unity. This is the very foundation of LCAs, for them to provide meaningful information. This means that the thick, warm Devold sweater that you wear all winter in Norwegian wool will be a true environmental disaster (Norwegian sheep take up an incredible amount of space when they graze) compared to the thin acrylic sweater that you bought on sale and are considering throwing away having discovered that you get an electric shock every time you pull it over your head. How long and how much clothing is worn is important for the environmental impacts in an LCA, but here too PEF falls short. This is particularly where we at SIFO have contributed to bring out knowledge and methods that can be used to correct this. Read more here.

Biodiversity does not count either, which the sheep contribute to in the grazed rangelands. Nor that they contribute to carbon storage in the soil. All that counts are the negatives, even when in the case of land use, the wide space is actually a positive! In connection with the consultation, there are many small producers of wool and other natural fibers who have responded, because they are scared that their livelihood will be evaluated as “red”, not “green”. The question then is whether the EU will listen, or whether they plan to override common sense and the need to reduce actual environmental impacts, and still introduce PEF for clothing and footwear to show action and justify all the time and resources that have been spent to develop the system.

SIFO has delivered a response. Let’s hope it helps.

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.

New method to capture relationship between properties and use

Waste audit interviews: A method for understanding the link between intrinsic quality and apparel lifespans, is the latest publication from Consumption Research Norway SIFO at Oslo Metropolitan University, co-authored by Kirsi Laitala and Ingun Grimstad Klepp.

New proposed regulation of clothing and textiles in the EU necessitate a deeper understanding of the products, encompassing their usage patterns, duration of use, and strategies for prolonging their lifespan and enhancing utilization rates. SIFO has therefore developed a new method for this purpose, and are simultaneously asking for funding to do studies based on the method, in order to guide the regulation processes for clothing and textiles.

The method is based on the many years of research in this sector, pioneered through wardrobe studies, and lately enhanced by waste audits of different waste streams. The former method is extremely rich in data-collection, but very costly; the latter captures data by casting the net wider, but with less detail about how long the service life has been. Further, the method connects the real use of clothing with results measured in a laboratory related to physical durability. This approach shows that it is feasible to measure the use phase objectively, something policy makers, the industry and research organizations advising policy have so far deemed to be “difficult” or “impossible”.

This note gives an overview of the method and the project proposal, with a rough budget estimate.

The note can be accessed and downloaded here.

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.