The Plastic Elephant tramples into the international conference room

The opening session at the Natural Fiber Connect conference in Biella, Italy at the very end of September, put the increasingly frequently mentioned elephant in the room center stage, namely overproduction and the plasticization that characterizes the textile industry.

The fact that the Italian Minister of the Environment opened the conference with a video greeting testifies to how important the textile industry is to the Italians, and not least how seriously they take the environmental problems that the same industry stands for. But in contrast to the industry as a whole, they have a great understanding that production, and particularly of synthetic materials, must be reduced considerably – which means more expensive textiles and more focus on natural fibres. This is music to the ears of the Italian industry, but also to natural fiber representatives who had gathered in Biella: cashmere, alpaca, wool, cotton and silk producers from farm level up to spinning mills, weaving mills and other industries.

Weighting the environmental burden

The key note speech was given by Veronica Bates-Kassatly. In contrast to Make The Label Count’s approach, which is currently persistently arguing that more parameters must be included in EU’s PEFCR, such as biodegradability, microplastics and renewability; Bates-Kassatly had the opposite approach. She believes that greenhouse gas emissions must be weighted much more (i.e. CO2 emissions in her argument), and that many of the 16 parameters that the EU’s Joint Research Center has decided should be included should be cut out or weighted much less. This includes water use and land use, two things which turns out to be unfortunate for natural fibres, but where the differences are large on a global basis so that average figures make very little sense. For example, a Norwegian sheep on open pasture will use huge areas of land to produce a few kilograms of wool, and this counts negatively.

Stand to increase plastics rather than decrease

A recent report from SIFO, the Plastic Elephant, followed Bates-Kassatly’s key note and the silk industry’s strong criticism of the data base for Higg and PEF (silk comes out as the worst fibre). The main message in the SIFO report is that a review of policy instruments, strategies from the industry and NGOs shows that to a very small extent they consider what can be done to reduce the volumes and not least to reduce the large increase over the last 40 years in synthetic materials and fast fashion. When the EU’s Textile Strategy wants to make “fast fashion out of fashion”, none of the tools in the toolbox are sufficient and, if anything, they will increase plasticisation. The report explains why, and the audience at the conference nodded their heads tellingly when the reasoning was explained.

The fact that the audience laughed out loud and applauded when the actual background for the Plastic Elephant report was presented at the start was, of course, liberating. This meant taking the audience back to the Copenhagen Fashion Summit in 2017, where the first Pulse report postulated that consumers must be persuaded to prefer synthetics to cotton; and where EcoAge’s Livia Firth asked H&M’s Helena Helmersson: “Why do you have to produce so much and constantly push new collections on consumers?” Helmersson replied that they are only doing what consumers want, to which Firth replied: “My children want sugar every single day, but do I give it to them? No.” The laughter resounded and a huge applause followed.

“Sugar” became the word of the day

The rest of the day, “sugar” was the word repeated over again, as equivalent with unhealthy consumption, and related to synthetics. Which means deplastification – also in the textile sector – may finally be on the agenda. To watch the whole morning session, go to this LinkedIn link. The Plastic Elephant report is easy to find here.

EU wants data on textile waste, and we have the answer

Text by Tone Skårdal Tobiasson

The proposal for the Waste Framework Directive, which is currently being read and analyzed by a myriad of companies, NGOs, researchers, policy-makers and interested citizens throughout Europe, handles two major consumer ‘goods’: Textiles and food. We are mainly concerned with the former, however, we have found that food offers us two good guiding principles.

The first one is to eat up what is on your plate. The second is waste audits as a means to gain meaningful knowledge on what gets “eaten up” and what doesn’t. In three separate documents, we ask the EU to heed these two guiding principles and apply them to apparel and other textiles.

One of the documents is our feedback on the textile part of the Waste Framework Directive (read the document here), where the authors have concrete recommendations for ensuring that the policy measures in the WFD can actually contribute to the EU’s ambition of putting fast fashion out of fashion. Currently, the Duration of Service is what is lacking in the available data (how long apparel has been in use and to what level the apparel and textile waste is ‘used up’ ), but even if the background document (#4) states “There is currently no sound method of estimating textile waste (collected and discarded in mixed municipal waste)”, this is just not true. And the two other papers elaborate on exactly this point. Waste audits/waste composition studies – which are very much used when gaining data on food waste – and wardrobe studies – are well-developed methods.

The document Status for developing methods for using waste as a resource for knowledge about the use phase of clothing (read the document here), offers an overview of exactly the current status for these methods, while the document USED, BUT NOT USED UP: Using textile waste to inform textile rating schemes (read the document here) explores how the data-collection methodology using waste audits can underpin several policy measures, such as the Product Environmental Footprint Category Rules, Ecodesign for Sustainable Products Regulation (ESPR), Labelling and Digital Product Passport (DPP), the Green claims directive, as well as EPR and the WFD. We have called the ongoing waste audit method for Targeted Producer Responsibility (TPR), as we originally saw it as a more effective means for levelling a EPR fee, using the Duration of Service as the measuring stick. However, we also now have realized that taking the waste as the point of departure, has many other ramifications that can be leveraged.

The cut-off point for feedback to the WFD keeps being postponed, but we encourage everyone to respond, as a functioning EPR scheme which actually takes the waste hierarchy seriously, can be reality, if we use waste audits as the basis for eco-modulating the fee. What we urgently need is for companies to add the date of production or when the product goes to market to the brand label. Then we can look both upstream, and downstream, from the time apparel and other textiles enter the different waste streams.

PhD Masterclass on Wardrobe Research

13th of April this year an online PhD masterclass was conducted within the scope of the CHANGE work package 5. The masterclass was online and involved the currently eight PhD students working with the wardrobe method or closely related methods and had the purpose of facilitating exchange of shared methodological implications, involved issues of interest, and the build-up of research network for young talents.

The 2-hour masterclass was informed by rapid pecha kucha type presentations of ongoing work and pre-formulated questions to facilitators and peers, and the workshop was hosted by Else Skjold who is PI of work package 5 of the CHANGE project. This work package involves, among other things, consolidation of existing wardrobe research and talent recruiting for new young research talent. Below is elaborated how the three themes cross-fertilized and interesting discussion that will hopefully just be the beginning of future work across the CHANGE partners to come. The presentations and discussions involved three selected topics emerging out of the ongoing PhD studies which were:

  • Wardrobe Practices
  • Secondary Use
  • Textile Techniques and Use

Wardrobe Practices

How can we understand the interactions between wearers and garments within the specific site of the wardrobe both at micro- and macro-level? This has always been the core pillar of wardrobe research since it was established in the mid 2000’s, and it was very interesting to see how young scholars pick up on this and formulate new ideas within the scope of their thesis work. A particular strong focus on local dress cultures and its effect on individual wearers were highlighted in this session, that brought about fruitful discussions on situated and contextual dress practices and how they are affected by climatic, cultural, economic and functional parameters.

Secondary Use

How can wardrobe research methods cast a light on the types of mechanisms and value creation that takes place between wearers and their vintage- and secondhand garments? This line of research is an interesting extension of ‘first generation’ wardrobe researchers’ work, in that it investigates what actually happens with garments beyond first use. This way it speaks back to concepts such as design for longevity/circularity and what they entail in the lifespan of garments between generations, body types, dress cultures and shifting ideas of fashion over time. And furthermore, how that informs practices of acquiring and discarding – an issue that has also been central within wardrobe research right from early pioneer studies in the early 1990’s.

Textile Techniques and Use

What types of competences used to be involved in maintaining personal wardrobes historically and how can we learn from this in an era with overproduction and overconsumption? Mending, repair and repurposing are all practices that have been deeply integrated in historical practices of use, as resources were typically scarce and costly – as opposed to now where much knowledge has been lost due to cheap, replaceable products and short use phases. This session looked into wardrobe maintenance practices of embellishment, print or other textile techniques for prolonging the lifespan of clothing, for projecting activist ideas, and generally for informing future practices and aesthetics of scarcity.

The masterclass will be repeated during the fall of 2023.

Ecodesign position paper: Textiles and footwear

In a position paper from the Change and Wasted Textile projects, authors Kate Fletcher, Irene Maldini, Ingun Grimstad Klepp, Kirsi Laitala, Jens Måge and Tone Skårdal Tobiasson have addressed the background document from EU’s Joint Research Centre on Ecodesign for Sustainable Products Regulation (ESPR).

The main theme in the position paper, is that the JRC document Preliminary study on new product priorities lays the basis to increase environmental burdens rather than reduce these. Therefore, in the paper, the authors ask that the work with the ESPR incorporates more empirical understanding about ecodesign, clothing consumption, and textile and fashion design. This in order that the directive will have the effect of reduced environmental burdens (including on climate) and will minimize inappropriate or unintended side effects.

The aim in writing the paper is to support the ESPR process for textiles and footwear in fostering deep and lasting environmental change.

The authors applaud the efforts of the EU in regulating the textile and footwear sector and agree in the priority that has been assigned to clothing and footwear on the bases of high consumption volumes in the EU, potential environmental improvements, and lack of previous regulation. However, it is the view of the authors that the current work with the Ecodesign Directive is based on some assumptions that are not in line with the knowledge that is there, nor is it targeted towards the main and interconnected challenges in clothing and textiles: overproduction and the increasing plasticization of the material content of products.

These two factors are interconnected due to the fact that an increase in production is not possible without the cheap, easily available fossil fuel-based raw material for fibres, materials, dyes and other processing chemicals.

It is therefore questionable whether textiles and footwear should actually be the initial priority for ESPR. Perhaps starting with cement would be better.

A full PLATE with a 7-course SIFO menu

Photo Tuomas Uusheimo

Holding on or letting go? Why don’t consumers complain more? Why do we hang on to stuff that is flawed? How to make fast fashion out of fashion and actually degrow the textile sector? All these questions will be answered at the PLATE conference at Aalto University, in Espoo, Finland.

At the end of May and beginning of June, Consumption Research Norway SIFO at Oslo Metropolitan University will partake in the biannual PLATE (Product Lifetimes and The Environment) conference with a full menu of all in all six papers, and all in all four presenting findings from LASTING, where one is by authors from the Norwegian University of Science and Technology.

The project Change will also be presented with volumes of consumption as the appetizer. Studying clothing consumption volumes through wardrobe studies: a methodological reflection is written by Irene Maldini, Vilde Haugrønning and Lucrecia de León. As not all wardrobe methods take advantage of their volume-centric possibilities, the paper explores lessons from a wardrobe pilot study conducted in Uruguay, Portugal and Norway in 2022 with both male and female respondents. Preliminary findings show that a volume perspective on wardrobe research can give valuable insights on the particularities of clothing use in relation to quantities.  

Putting on a different set of glasses

In another paper, which is a result of the Wasted Textiles project, this is also explored related only to textiles and clothing: Regulating Fast Fashion out of Fashion, authored by Kerli Kant-Hvass and Ingun Grimstad Klepp. The analysis underpinning the paper is based on a review of 10 textile strategy documents from public, private and non-profit organizations, on whether and how growth and overproduction in the textile industry is being addressed. Merging this with research and findings from the opposite end of the value-chain than these textile strategy documents do (which use design and a focus on “preferred fiber” choices to potentially optimize lifetime), the paper puts forward Targeted Producer responsibility (TPR) as a means to curb volumes effectively and thus reduce environmental impacts.

Another paper, written by Kirsi Laitala, Lisbeth Løvbak Berg and Pål Strandbakken, addresses consumers’ use and knowledge of the Consumer Purchases Act by asking: Why won’t you complain? Consumer rights and the unmet product lifespan requirements. The paper discusses the reasons for not complaining, based on six consumer focus groups, where in total 36 consumers described furniture, electronics, and textile products that they were dissatisfied with and hadn’t necessarily taken the trouble to claim their consumer rights.

Clearer guidelines in order

There is a need for clear guidelines on what the consumer rights are for the specific products, the authors write, to make it clear what is considered unacceptable abrasion and normal use, but also to differentiate between commercial warranties and legal rights. Complaints are, after all, an important avenue for businesses to gain information about the performance of their products, and thereby improve them.

In Norway, the right to complain is extended to 5 years for some durable goods, which exceeds the EU requirements of 2 years. This creates confusion about which products and which duration is valid, where consumers often link this to price, rather than the type of product. In addition to clearer guidelines, there are possibilities for new technical solutions to facilitate the storage of receipts and purchase information related to each product, which was especially problematic for low-priced items. Digital product passes, which is on EU’s menu of policy instruments, may be developed with this in mind, and could also include information about consumer rights.

Focus groups offer insights

Two other Lasting papers, are both about what we keep or discard and why, and are based on focus groups, but also some interviews with business representatives. The overarching theme was product longevity of three product groups: electronics, textiles, and furniture. In Flawed or redundant: products with long lifespans against the odds, co-authored by Harald Throne-Holst and Kirsi Laitala, the theme is explored related to reasonings behind keeping things – by only storing them and not using them – or trying to use them even though they are broken or flawed. Five groups of reasoning were presented: Economical, Ethical, Social, Emotional, and Intentions.

In Holding on or letting go? Conflicting narratives of product longevity: a business vs. consumer perspective, authors Lisbeth Løvbak Berg and Marie Hebrok have found that technical and emotional durability are the two dominant ways of understanding product longevity by business representatives, and as such what they aim to embed in their products. Consumers, however, tell a different story, of living with their things, of use, of time passing, and life events triggering change – factors that are external to the product itself. The authors argue that corporate narratives of product longevity divert our attention away from production toward consumption, keeping questions of volume and growth at arm’s length.

Stockings as stress

In relation to durability, the Reduce project will present The devaluation of stockings. Tone Rasch, Ingrid Haugsrud, Kirsi Laitala and Atle Wehn Hegnes (Tone is associated with the Norwegian Museum of Science and Technology) explore nylon stockings for women as an example of a product that first was recognized as high fashion, but later has been devalued and is now seen almost as a single-use product. Thin stockings represent a good example of how we value and take care of delicate items has a significant contribution to their lifetimes. Looking into the historical context is beneficial for learning about the points in time when changes occurred and how they contribute to consumer practices.

The weakest link: How technical lifespan extension can be counter-effective for climate goals looks at scenarios for kitchen durables (fridge, dishwasher, stove, and kitchen cupboards) to explore lifetime extension, and investigate the extent to which these interventions could in fact be counter-effective for climate goals set for 2050. The authors, Kamila Krych and Johan B. Pettersen, found that the extra resources invested to ensure more durable products that anyways can land in waste bins prematurely, can be counter-effective in reaching the climate goals set for 2050.

Tasty alternatives

Faster environmental benefits, the authors write, could be achieved by increasing the repair rates by extending product warranties, subsidizing repair services, supporting the development of innovative repair businesses, demanding the availability of spare parts at affordable prices, and increasing the convenience of repair. The paper also points to policy addressing “problematic” products as more effective, such as dish-washers that fail more frequently. A belief in design-focused interventions, is clearly questioned, as the authors see this as taking longer to bring effect.

So, all in all, attendees should be well-satisfied and full of new knowledge, considering this rich menu, which is of course only a small part of the three-day proceedings in Finland. The research papers will be published after the conference.

Microplastics or microfibers: Does anyone really get what this is about?

OPINION: What we do know, is that all synthetic clothing and materials, sooner or later, will become microplastics, a «time-delayed» pollution bomb. And thus, they will ultimately become a problem for seabirds, and us.

A new report on microfibers in waterways is gaining attention, as it claims the results show more natural fibers than synthetic ones, and therefore demonizing microplastics is wrong. However, a very recent study on the intestines of seabirds gives a different conclusion: Fossil-based particles do cause harm.

The recent report from The Microfibre Consortium (TMC), together with the Norwegian Research Center/NORCE has analyzed samples taken along the coast of Kenya and Tanzania, and found that of 2403 textile fibers in the water, 55 per cent were of natural origin, 37 per cent were synthetic and 8 per cent viscose/rayon-based.

To read this op ed, written by Professor Ingun Grimstad Klepp, Founder of Fibershed, Rebecca Burgess and journalist and writer Tone Skårdal Tobiasson, follow this link.

A conversation with Kate Fletcher

First of all, we would like to welcome you as a colleague! This is a very happy development for Consumption Research Norway (SIFO) and our clothing research group, alongside of course, the work in the projects you have the lead of work packages. So firstly: welcome!

For such a long time, we have associated you with London College of Fashion, and now you are affiliated with three Scandinavian institutions. Is there a special affinity to this region that has resulted in this tripling of your affiliation?

Well, it is a very beautiful region! Seriously, there has been a steady – and growing –  presence in sustainability, design, fashion and textiles work in the Nordic countries over the last twenty-five years and I am now honoured to be able to connect with this work in three different institutions.

Are the other two positions very different from your role at SIFO?

All the roles are fairly distinct, drawing on different parts of my knowledge and skills. Some are more design-based, others more strategic, while the work at SIFO is more specifically linked to research projects.

Your research project, Craft of Use, brought in a new perspective on how we use our clothes in a myriad of ways; that has inspired many to rethink their relationship with clothes. How did this research lead to for example Earth Logic and your input to new research? Can you give us a ‘thread’ that weaves through your research?

The Craft of Use project started out in 2008 as a way to glimpse what ‘fashion’ might look like ‘post growth’. The idea was that in a world beyond consumerism when clothes are no longer bought mindlessly, the skills of using garments well, with dedication and care, take on new significance. These skills would become the currencies of post growth fashion, they also emphasise practices not just products and users, not just garments. Through a hybrid ethnographic-design research project the Craft of Use project connected the everyday (the lifeworld of the user), systemic questions about taken-for-granted economic and social structures, and relational potential of design to act and connect differently. Earth Logic is, I guess, an obvious continuation of this approach. It also uses a similar action research methodology and is similarly radical.

From left to right: Else Skjold, Trine Skødt, Mette Dalgaard Nielsen and Kate Fletcher. From the launch of the Klothing Research Center.

In the two projects Lasting and CHANGE, where you lead two work packages, you are looking outside the Global North concept of consumption and fashion/clothing practices with a new lens or kaleidoscope. Is this challenging to you personally and also research in general?

It is both personally challenging, and challenging to research, and necessarily so. For too long the dominant ideas in fields like fashion and sustainability have been assumed to be universal, with the assumption that no one sits outside of these ideas, beyond this epistemic territory. But with this assumption comes erasure, and denial of other perspectives, realities, possibilities etc. Looking to more plural perspectives tackle some of the biggest subjects like Western hegemony, human exceptionalism, patriarchy, but it also asks about small practical things like how writing items in a list introduces a hierarchy, which in turn introduces an inadvertent priority or power relation.

Some of the focus in Mathilda Tham’s and your Earth Logic, is about a more localized and diverse approach to clothing and fashion. I personally find this fascinating, and it resonates with so much of what needs to be in place in order “repair” our current system, if we can even repair it. Do you have any thoughts at all that you are willing to share, on systemic change within the current economic system?

Community based action is seen, time and again, as the radical basis of sustainability change. For it is in local places that lives are lived. One of the strands of work that is ongoing within Earth Logic is an exploratory project around a local fashion government. In Earth Logic, when we talk about government and governance people often think about big government, like what happens at national or pan-national levels, but what Earth Logic is interested in is at a different level. Our interest is the small sets of individual, household, community and regional decisions around organising and regulating clothing provision and expression. To be clear, this is not about what can be produced in a region, but more about how to meet needs with the clothing that we already have. This for me is systemic change. I’ll let you be the judge if it sits within the current system or not.

What do you feel should be further explored at SIFO, what themes do you see as unaddressed?

One of the critical challenges for fashion and sustainability is to tackle rising consumption volumes. I would like to get straight to heart of this challenge and to explore consuming less, and to do that with colleagues with expertise from across the SIFO family.

Kate with the CHANGE team at Finnskogen, flanked by Ingun Klepp (left), Ingrid Haugsrud, Else Skjold and Lea Gleisberg, Vilde Haugrønning in front.

Do you feel research councils understand what the actual problems are? Do you have a wish for a call you haven’t seen?

In general terms it seems research councils prefer funding projects that are similar to existing ones, that use related thinking, and aligned with established economic priorities. What I hope for is that bolder, riskier, farsighted projects will also be funded. Such projects generally create the compost that other projects then go on to sow the seeds of change in. And without the compost, other seeds of future projects will not germinate. So, this is ultimately an investment in the future.

Consumption, as a word and a concept; what do you find the most problematic and what do you find to be valuable?

Etymologically, I find the term consumption problematic, meaning, as it does, “to use up”. And in the fashion context, its strong association with the culture of consumption is antithetical to ecological balance. Yet inspired by the words of the poet and farmer Wendell Berry, I am also seeing consumption, as about husbandry. That is, the name of all practices that sustain life by connecting us conservingly to our places and our world. It is the art of keeping tied all the strands in the living network that sustains us.

Questions related to the TPR proposal

The Wasted Textiles team have had many meetings with policy-makers, politicians, NGOs, textile industry representatives and other interested parties regarding our Targeted Producer Responsibility proposal. We have collected questions we have been asked and here you will find the answers to these questions. If you have other questions, feel free to send them to us, and we will answer them as best we can, and make them publicly available.  

Q: How to obtain knowledge about the lifespan of textiles?

A:   Lifetime can be measured in number of years, or the number of times something is used. The proposal is to use the length of the use phase as the most important criterion. We propose that the brand and date of production/import will be made mandatory in the future legislation. In the long term, it will then be possible to measure how long the usage phase is on average per brand. We will also be able to say something about the number of uses. The clothes that have not been used will usually be recognizable, and likewise, clothes that have been used until they are worn out. The main method of TPR will be waste analyses and it is possible to do the analyses of the life span in different ways, also related to the type of textile.

Q: Is it only the quantity and age of the textiles in the waste stream that determine the size of the fee?

A: Our proposal is that the quantity and age of discarded textiles shall determine the fee together with the cost of capturing the End of Life (EoL) value for the products. This means that textiles with a high price on the second-hand market, or based on their material composition are a resource for recycling, will have a lower price or even not generate a fee at all, in accordance with the “polluter pays” principle.

Q: How to guarantee that the product carries information about the garment and the brand?

A: The rules today safeguard this to a certain extent, as the labels or the printed information need to withstand a certain number of laundry cycles. It is often also possible to determine the brand by visible logos or because the clothes are recognizable for other reasons. In practice, some will be unidentifiable, but as the sample pick analysis will give representative numbers, this is not the biggest hurdle. There will be enough waste to make statistical and significant compilations.

Q: With the Digital Product Passport (DPP) work underway to update the rules on what information is mandatory on textiles, is it premature to require that the date of manufacture (or date of placing on the market) must already appear on the label?

A: No. There can be interim solutions on the way to a product passport, and as picking analysis is a known method to gather data from waste streams, this is vital in order to quickly assess how long products have been in use before they are discarded. It is possible to analyse the age of clothes in the waste streams without dating the clothes, but dating will give better accuracy and make the analyses easier. In addition, the dating of clothes will have a number of positive effects for consumers, such as giving consumers a greater opportunity to compare the technical quality of the clothes and determine how long they have been in use. This will strengthen the right to complain which is linked directly to the number of years, thus empowering EU citizens.  It will also be an important link to transparency about production conditions. We, therefore, suggest that product date labelling should be included in the coming revision of the EU Textile Labelling Regulation, independently of EPR/TPR.

Q: Who will do the waste picking analysis?

A: We envision the work being carried out by third-party analysis agencies/research institutions with expertise in picking analyses and apparel, overseen by a public authority to oversee the implementation and ensure transparency.

In the Wasted Textiles project, the analyses are based on a collaboration between an analysis agency, MEPEX, with experience from sorting agents for other waste streams, researchers with experience with textiles, and the largest charity in Norway, along with Consumption Research Norway (SIFO)’s experience with different versions of wardrobe methods. Collectively, a method has been developed to look at the composition of the textile waste. Based on this work, it will be possible to further develop a method that meets the specific requirements of an EPR/TPR system.

Q: How to estimate how old a garment is by looking at waste streams or reuse collection streams?

A: Unused clothes are generally recognized by the fact that they have price tags on them, or that they are found in large quantities of similar clothes (unsold). Age can otherwise be assessed based on style, technical details and wear-and-tear. We are not talking about detailed information, but about broad assessments. Textile waste today consists of textiles produced over many decades and there have been technological and aesthetic changes in apparel over the past 50 years, although apparel has not changed as quickly as e.g., electronics. Accuracy will of course be easier when the date becomes a mandatory part of labelling textiles. Accuracy will also be better if the staff who carry out the analysis have the appropriate textile expertise.

Q: What are the criteria for a TPR fee?      

A: TPR can be used and combined with different varieties of EPR and other political instruments. If it is to have the effect of reducing overproduction and making fast fashion out of fashion, then it depends on the fee being high enough to affect the producers, their business models and downstream decisions. However, it is not the size of the fee that distinguishes TPR from other EPR systems, but the way it is calculated.

Producers would pay different levels of EPR fees depending on:

  • How old the clothing is when going out of use (very old clothing generates no fee, while very new would generate a high fee)
  • How reusable/recyclable the clothing is (clothing types with profitable pathways have a low fee)

TPR will ensure a level playing field for a European-based textile industry, global brands and online producers, so-called ultra-fast-fashion brands.  TPR will catch all textile waste, regardless of where the garment was made or imported from, thus addressing the challenge of online trade/e-commerce and “free-riders”. Further work is needed on the details of how the fees are calculated for each individual producer, for specific product groups or for the industry as a whole.   

Q: Can picking analysis actually underpin the legal validity of fees?

A: The legal foundation, implications and further development of TPR are in the current EU Waste Framework Directive, and in the coming revisions. The current WFD (article 8a) defines minimum requirements for member states and their EPR-systems, f. ex. stating that eco-modulation shall be used when it is possible. But until now we have not seen eco-modulation being used in accordance with the waste hierarchy, nor the polluter pays-principle, when it comes to irresponsible production and consumption, and its waste export, and there are limitations in the current directive when it comes to setting fees that go beyond the waste phase. The EU textile strategy from March 2022 announced that there will be a harmonised producer responsibility in the EU set forth in the coming revisions.

We will rely on legal experts and funding for further work with the legal aspects of TPR. It is likely that the retroactive aspect will be contended. If producers are held responsible for the waste they have produced long before the scheme comes into effect, they will balk. It will, however, only be a temporary problem. It is also possible to use TPR combined with sales/import statistics, so that TPR is used to modulate the fee, but that it is based on the imports/production taking place at the same time. We consider it unlikely that the analysis of the waste itself would not be reliable enough. Picking analyses are used on other waste streams and is a recognized method.

Q: Will TPR be costly to operate?

A: The costs of operating the scheme will be covered by the fee, as is normal for other control schemes for industries. TPR is based on national samples taken annually or every two years, and is assumed to be administered at low cost.

For TPR to work (reduce quantities and thus environmental burdens) it is important that the fees are high enough. This will provide money that can be used for, among other things, the operation of the system. In existing EPR-schemes the fees are often set very low so that there is little room for covering other than minimum administrative costs.

In general, there is too little waste regulation supervision and with many new EU regulations to be followed up, it is necessary to strengthen supervision on national and municipal levels. The knowledge that the picking analysis will provide is important data for monitoring the effect of the EU’s textile strategy and for making the best possible use of textile waste. It is difficult to imagine effective policy and product development without knowledge of the waste.

Q: How can we trust those who will be doing the picking analysis, that the data they collect is good enough to eco-modulate fees based on the findings?

A: In contrast to much environmental work, TPR is not based on information provided by the actors themselves, but by an independent third party with no financial interests in the matter. Why should a research or analysis agency not be trusted? It is, after all, common to use a third party to obtain information precisely to ensure independence. A major problem in the textile industry is that concepts, perspectives and what is perceived as knowledge are often produced by the industry itself and its organisations. Selective analyses, on the other hand, can be carried out by independent analysis agencies/researchers.

Q: Will TPR affect companies that want to invest in circular business models and charities that are dependent on revenues from second-hand trade?

A: Circular BMs, such as repair, rental, etc. are struggling financially today due to the competition with cheap new clothes. By making it more expensive to sell what hardly gets used, the over-production will be impacted and eventually reduced (provided the fee is high enough). This will strengthen the possibility for such BMs. The companies that work with further processing of textile waste (repair, redesign, recycling and all intermediate forms) will be able to receive financial help for product development and support from the EPR system and this subsidy will improve their financial sustainability.

Q: In the EU, 99,9% of the actors in the textile sector are SMEs. How will TPR capture meaningful data about them, and ensure that they are not treated unfairly?

A: For once, we are lucky that the fashion and sports apparel sector are dominated by big, global companies with large volumes. This means that they will dominate in the picking analysis.

Q: How will the collected fees be allocated and used?

A: The allocation of the fee has not been elaborated in the proposal for a TPR system. However, we believe that it is important that the TPR funds will be allocated to support as a minimum (non-exhaustive list):

  • operation of the system (incl. picking analysis and calculations, the logistics)
  • support proper use of collected textiles according to the waste hierarchy, incl. charities, markets for reuse and repair
  • support the work with reducing synthetic textiles, preventing the spread of microplastics and cleaning up the textile waste in developing countries
  • support municipalities that need to build up collection, sorting and treatment facilities
  • support countries, regions, businesses and NGOs in the global south in cleaning clean up landfills and rivers and establish functioning waste management systems
  • stimulate technology innovation, research, development and investments

Q: Can TPR be useful for other policy measures than EPR? 

A: TPR is a way of “capturing” the use phase, which otherwise remains a “black hole” in LCAs. In other words, a very important factor for calculating environmental impact in the whole lifecycle of a product, is not taken into account. TPR will make a valuable contribution to gathering meaningful data – and thus can have an impact on many policy measures, especially the ones based on LCA data.

Q: The EU Textile strategy aims for durable, repairable, recyclable apparel and footwear, that also contains recycled content – does TPR contribute to this, or is it counter to these aims?

A: TPR will contribute by bringing forward knowledge and data on how effective these aims are in delivering on the issues around durability. Through the picking analysis it is possible to collect various information on discarded or donated products, i.e., if the discarded or donated items have been repaired, or other relevant information related to the Textile Strategy aims.

Q: Does the TPR have the potential to address just transition, more local value-chains, eco-design and other issues that the EU are addressing through other strategies and programs?

A: The results from the picking analysis will feed into eco-modulation, and be the opposite of traditional eco-design, which only projects assumptions on lifespan. The data collected will be ‘proof of the pudding’ on what actually has a long lifespan, and cancel part of the eco-design directive, through providing actual data and incentives for making lasting products. TPR will use the market forces, and let the companies themselves decide how they tackle this, but make it costly to make products nobody wants.  This will be valuable for the New European Bauhaus. We also see synergies for Farm to Fork, the EU’s new Soil Mission, and other programs and strategies, for example, the Plastic strategy. We know the EU aims for a more holistic, non-siloed way forward, and TPR offers an opportunity for this, based on how to award apparel that stays in use for a long time (indigenous, traditional, local, etc.) up against low-quality products that have a very short lifespan.

Q: How will TPR help to phase out fast fashion?

A: If the fees are high enough to deter the increased plastification of our wardrobes and for clothing that we keep, use and love for a long time, to be awarded amnesty, then TPR will help phase out fast fashion.

Q: How will this affect the developing countries, who rely on second-hand clothes from the EU and the trade of these clothes?

A: TPR has the potential to affect developing countries in two ways. Firstly, the TPR fee should address the issue of waste colonialism, i.e., quantities of textile waste exported (as mentioned earlier in the paper but needs further study for concrete proposals).

Secondly, in line with the EU’s strategic goal to handle its own textile waste rather than exporting it to the Global South, TRP will indirectly affect this export in the long run, through the expected reduction of fast fashion and the volumes being exported.

TPR is also an opportunity for EPR to reduce quantities imported into the EU and thus if the fee is set high enough, it will affect the quantities that go out of use and thus what is exported to developing countries. This is very important, as it is the Global North that creates the major waste problems, which has been recently documented by EEA, Changing Markets Foundation and The OR Foundation. TPR’s goal is to affect the quantities being produced (fast fashion) and exported as waste and thus reduce negative environmental impacts and the related problems in production, use and disposal. These are environmental problems that particularly affect developing countries in that both the production takes place there and that the waste ends up there.

Q: Can TPR be used in other product areas?

A: Yes. That is a good idea to explore. As far as we know, there are no similar systems for other product groups; however, many products are sold with dates and also information on expected lifespan, which is a good basis for developing a TPR system. It would be possible to install a counter in f. ex. a laundry machine or coffee maker, so that the fee is not only based on years of use, but also laundry cycles or coffee-pots made. Using both years of service life and other available information in the modulation of the fee will contribute to more durable products for many product categories.

See the full briefing paper that was sent to the EU representatives below.

New briefing outlining research behind the TPR proposal

During a meeting earlier this year with a team from the European Commission Executive Vice-President for the European Green Deal, Frans Timmermans’ office, the authors of this new paper were asked to supply more background on the Targeted Producer Responsibility they presented.

As the first step in supplying more research-based data and knowledge, the paper entitled “Critical review of Product Environmental Footprint (PEF): Why PEF currently favors synthetic textiles (plastics)” and therefore also fast fashion was sent to the meeting-participants and published online. This was, however, only the first of three papers promised. The second, “Research input for policy development based on understanding of clothing consumption“, a research briefing, goes into the research behind the proposal. It is now sent to the meeting participants and is therefore also made publicly available.

For this research briefing, additional researchers who are not part of the Wasted Textiles project were engaged, and who have also recently been recruited to roles at SIFO: Kate Fletcher and Irene Maldini. Authors from Wasted Textiles are Lisbeth Løvbak Berg (SIFO, OsloMet), Tone Skårdal Tobiasson (NICE Fashion/UCRF), Jens Måge (Norwegian Waste Management and Recycling Association). Kerli Kant Hvass (Revaluate/Aalborg University); and of course, the main author Ingun Grimstad Klepp.

This briefing paper builds on research and evidence from SIFO’s 75 years of consumer research on clothing and the ongoing projects CHANGE, Lasting as well as the mentioned Wasted Textiles, addressing the problem of overproduction of textiles. It draws attention to the importance of incorporating the latest consumer research in the design of Extended Producer Responsibility (EPR) – or rather our suggestion TPR – and other textile policies currently being developed in the EU. It is written by a diverse group of academics and practitioners who are seeking to support change in the sector.

The briefing puts forward that the authors see a trend in various policy discussions and documents based on the belief that making garments more durable, will reduce the quantity of clothing produced. Scientific research does not provide evidence for this, which is exactly what this briefing aims to show. The briefing is, however, not only a criticism of the lack of research-based policy tools. The authors also offer suggestions on how to make these tools effective in the challenge that lies ahead of us: Making fast fashion out of fashion.

Read the full briefing below.

Critical background paper on PEF for apparel and footwear

This week saw the publication of a critical background paper on concerns surrounding the Product Environmental Footprint Category Rules for Apparel and Footwear from a consortium representing the collaborative international research project Wasted Textiles at Consumption Research Norway SIFO at Oslo Metropolitan University.

The consortium were asked to supply more background information to the EU Commission after a knowledge sharing meeting January 25 hosted by Vice President Timmermans cabinet members and other EU officials from both DG Grow and DG Environment involved in the execution of the EU Textiles strategy, the revision of the Waste Framework Directive, and other Green Deal related policies.

As the first step in supplying more research-based data and knowledge, the paper entitled CRITICAL REVIEW OF PRODUCT ENVIRONMENTAL FOOTPRINT (PEF): WHY PEF CURRENTLY FAVORS SYNTHETIC TEXTILES (PLASTICS) AND THEREFORE ALSO FAST FASHION was sent to the meeting-participants this week, and the authors have decided to make the paper publicly available through the Clothing Research website, and can be accessed at the bottom of this page.

During the meeting, which was mainly about Extended Producer Responsibility, Professor in Clothing and Sustainability at Consumption Research Norway SIFO at Oslo Metropolitan University, Ingun Grimstad Klepp, brought up concerns surrounding PEF and PEFCR that could be addressed with the right policy measures to ensure better data collection for the use- and end-of-use phase. These concerns are based on research from three longitudinal research projects at SIFO (Wasted Textiles, CHANGE and Lasting), under the auspices of the Clothing Research umbrella. This research was what led to the meeting with several EU officials, who were all genuinely interested in how academic research can contribute to better policy measures.

Four of the authors, from left to right: Jens Måge, Ingun Grimstad Klepp, Tone Skårdal Tobiasson and Kerli Kant Hvass.

This paper is the first in a series of three that will be delivered to the participants of the meeting and will be made available on this website, related to EU’s textile strategy. The research consortium behind the critical papers, welcome EU’s ambitious strategy for apparel and footwear; however, the same research consortium sees that unless one takes a holistic view which includes the use and disposal of products, with a view from what actually ends up in the waste and how quickly – true sustainability-measures are in danger of supplying misleading information. By capturing this research and making it available, it is possible to spur policy measures that address the issue of over-production head on.

In conclusion, the paper states: “In essence, one can therefore say that PEFCR for clothing favors plastic due to a lack of political decisiveness on how to measure natural versus synthetic materials, together with giving the FF (fast fashion) industry power in the development of PEFCR and choice of underlying data. Fast fashion will remain in fashion if those who have the most to gain from it are making the rules.” The first critical paper is authored by Ingun Grimstad Klepp, Kirsi Laitala, Lisbeth Løvbak Berg (all SIFO, OsloMet), Tone Skårdal Tobiasson (NICE Fashion/UCRF), Jens Måge (Norwegian Waste Management and Recycling Association) and Kerli Kant Hvass (Revaluate/Aalborg University).

The SIFO Clothing Research team who are all co-authors: Kirsi Laitala, Lisbeth Løvbak Berg and Ingun Grimstad Klepp.