What the EU Textile Strategy means for the UK fashion industry

On 30 March, the Euro­pean Com­mis­sion pub­lished the antic­i­pat­ed EU Strat­e­gy for Sus­tain­able and Cir­cu­lar Tex­tiles as part of its Green New Deal. In a bid to make sus­tain­able prod­ucts the norm, the objec­tive of the strat­e­gy is to “make tex­tiles more durable, repairable, reusable and recy­clable, to tack­le fast fash­ion, tex­tile waste and the destruc­tion of unsold tex­tiles, and to ensure their pro­duc­tion takes place in full respect of social rights”, accord­ing to the Euro­pean Commission’s offi­cial state­ment. 

How the UK’s 34,000 busi­ness­es employed in the UK fash­ion and tex­tile sec­tor are meant to com­ply with these rules fol­low­ing the offi­cial depar­ture from the Union in 2020 remains a grey area. Uncer­tain­ty could threat­en progress on envi­ron­men­tal sus­tain­abil­i­ty as well as incur costs for the SMEs that make up 99% of the UK’s fash­ion indus­try. 

The strat­e­gy has been designed to dri­ve cir­cu­lar­i­ty and sup­port cit­i­zens through­out the green tran­si­tion as the glob­al econ­o­my moves to decar­bonise. This is espe­cial­ly impor­tant for Europe, one of the largest importers of clothes, which reached a val­ue of €154bn (£130bn) in 2019, accord­ing to Euro­stat. 

The intro­duc­tion of extend­ed pro­duc­er respon­si­bil­i­ty (EPR) with­in the strat­e­gy is set to make pro­duc­ers respon­si­ble for the waste their prod­ucts cre­ate and incen­tivise design deci­sions that would make gar­ments eas­i­ly recy­cled, decon­struct­ed or repur­posed at their end of life. This is vital giv­en that approx­i­mate­ly only 1% of glob­al tex­tiles are recy­cled. 

EPR has been wel­comed by envi­ron­men­tal cam­paign­ers giv­en the huge neg­a­tive exter­nal­i­ties asso­ci­at­ed with tex­tile pro­duc­tion where brands and man­u­fac­tur­ers, many of whom are British, flaunt £1 biki­nis or 5p dress­es online and do not pay the true envi­ron­men­tal and labour costs asso­ci­at­ed with a gar­ment. George Hard­ing-Rolls, cam­paign advis­er for the NGO, Chang­ing Mar­kets Foun­da­tion argues that the promise of the EPR “could have far-reach­ing effects, both by mak­ing brands pay for the waste they cre­ate and by cre­at­ing invest­ments in end-of-life man­age­ment for prod­ucts”. 

The strategy’s review of labelling reg­u­la­tions and the use of dig­i­tal prod­uct pass­ports (DPPs) is anoth­er pos­i­tive devel­op­ment. DPPs store essen­tial prod­uct data on mate­ri­als that can be used by stake­hold­ers in the tex­tile ecosys­tem. If all reg­u­lat­ed pro­duc­ers were to have DPPs it could facil­i­tate repair, recy­cling and the trac­ing of harm­ful sub­stances across the sup­ply chain and reduce waste. DPPs in the form of dig­i­tal IDs are being cre­at­ed by EON, a retail plat­form work­ing along­side The Prince of Wales’s Sus­tain­able Mar­kets Ini­tia­tive Fash­ion Task­force, to bring this to UK house­hold names that include Burber­ry and Stel­la McCart­ney. 

Else­where, the Com­mis­sion recog­nised the intrin­sic link between fos­sil fuels and tex­tiles when it stat­ed: “The grow­ing demand for tex­tiles is fuelling the inef­fi­cient use of non-renew­able resources, includ­ing the pro­duc­tion of syn­thet­ic fibres from fos­sil fuels.” The shed­ding of microplas­tics was men­tioned too, but Hard­ing-Rolls does not believe this goes far enough. “The strat­e­gy falls short of rec­om­mend­ing reduc­ing these fos­sil-fuel derived fibres as a way of cut­ting microplas­tic shed­ding,” he notes. 

Green­wash­ing was also cast into the spot­light to com­ply with con­sumer pro­tec­tion laws on green claims between the UK and Europe. UK fash­ion busi­ness­es have already been work­ing to adjust com­mu­ni­ca­tions to guid­ance on envi­ron­men­tal claims under the UK Com­pe­ti­tion and Mar­kets Author­i­ty (CMA) Green Claims Code, released in Sep­tem­ber 2021. ear­ly 2022. The urgency of doing so is high­light­ed by the research from the Chang­ing Mar­kets Foun­da­tion which found that 59% of all green claims by Euro­pean and UK fash­ion brands from the 2021 Spring/Summer col­lec­tions were mis­lead­ing.  

For UK brands, adapt­ing to the require­ments of the strat­e­gy will be no small feat. Pri­mark is in the throes of review­ing how to align its busi­ness and sourc­ing deci­sions to new guid­ance. Lynne Walk­er, direc­tor of Pri­mark Cares, com­ments: “Pri­mark wel­comes any pro­pos­als that lev­el the play­ing field and cre­ate the poten­tial to dri­ve indus­try-wide change. We are cur­rent­ly review­ing the EU pro­pos­al in detail but look for­ward to play­ing our part in con­junc­tion with our ongo­ing work and com­mit­ments towards becom­ing a more sus­tain­able busi­ness”. 

Sim­i­lar­ly, a spokesper­son from the John Lewis Part­ner­ship says that the EU’s Tex­tile Strat­e­gy, Cir­cu­lar Econ­o­my Action Plan and Sus­tain­able Prod­ucts Ini­tia­tive “will do a great deal to nor­malise ethics and sus­tain­abil­i­ty with­in busi­ness prac­tices”. The retailer’s 2020 Part­ner­ship Plan and inclu­sion of take-back solu­tions by 2025 and com­mit­ments to use recy­cled and sus­tain­able mate­ri­als high­light how they are work­ing to align their oper­a­tions to the EU Green Deal. 

Indus­try com­men­ta­tors have react­ed with cau­tious opti­mism to the strat­e­gy, argu­ing that social due dili­gence remains large­ly ignored. Hard­ing-Rolls sees that the “strat­e­gy ignores work­ers in the sup­ply chain and does not cre­ate any more ambi­tious require­ments on sup­ply chain vis­i­bil­i­ty and trans­paren­cy”. 

It’s not just NGOs that think the strat­e­gy could have gone fur­ther. Ber­nice Pan, founder and cre­ative direc­tor of Deploy, a UK-based sus­tain­able brand, adds that the stakes must be high­er to dis­in­cen­tivise retail­ers on over­pro­duc­tion and waste gen­er­a­tion. “It should be tan­gi­bly pushed for­ward to include a ban on send­ing unsold mer­chan­dise to land­fills and incin­er­a­tors. France has intro­duced a levy of penal­ty charges or tax­a­tion on com­pa­nies who do so,” Pan says. 

If France can do it, why shouldn’t the UK? Bind­ing mea­sures to incen­tivise an absolute reduc­tion in mate­r­i­al use, for exam­ple, through a tax on vir­gin mate­ri­als and envi­ron­men­tal impact, are miss­ing from the EU Tex­tile Strat­e­gy but need not be miss­ing from UK reg­u­la­tions on fash­ion and tex­tiles. 

While progress with­in Europe is wel­comed – many are scratch­ing their heads as to where exact­ly it leaves the UK fash­ion indus­try fol­low­ing Brex­it. Trad­ing rela­tion­ships are crit­i­cal giv­en that the UK cloth­ing indus­try is the third-largest in Europe and the fash­ion and tex­tile indus­try con­tributed approx­i­mate­ly £20bn to the UK econ­o­my as of 2020, accord­ing to the UK Fash­ion and Trav­el Asso­ci­a­tion. 

Tama­ra Cin­cik, founder of Fash­ion Round­table, a UK-based think tank focused on fash­ion, express­es deep con­cerns about the diver­gence between the UK and its EU trad­ing part­ners. “I wor­ry about the UK being left behind on the glob­al stage in our sus­tain­abil­i­ty ambi­tions. Brex­it also means added costs and impacts,” she not­ed. 

The UK’s fash­ion econ­o­my has expe­ri­enced increased fric­tion from Brex­it trad­ing com­pli­ca­tions such as a rise in cus­toms and freight duties. Cin­cik high­lights that of the 34,000 busi­ness­es oper­at­ing in the UK fash­ion and tex­tile sec­tor, 99% of these are SMEs, and the impact incurred due to mis­align­ment through­out Brex­it is not some­thing they can afford. 

Deploy’s Pan shares her expe­ri­ence as a founder of a British brand that lacks the human resource to ded­i­cate to research and adap­ta­tion of chang­ing import-export reg­u­la­tions. She states: “Brex­it has erod­ed favourable con­di­tions between the UK and EU. It has made it chal­leng­ing for com­pa­nies to nav­i­gate com­plex, diver­gent agen­das, whilst stay­ing com­pet­i­tive and weath­er­ing the pan­dem­ic storm.” 

Along­side an increase in costs, the UK can­not afford to fall behind on envi­ron­men­tal progress, espe­cial­ly in mit­i­gat­ing tex­tile waste as our land­fill capac­i­ty con­tin­ues to rapid­ly dimin­ish. A 2020 study by Labfresh found that the UK is the fourth-largest pro­duc­er of tex­tile waste in Europe. 

Tex­tile waste was addressed in the EU strat­e­gy, stat­ing that by 2024 dis­clo­sure from brands on the num­ber of dis­card­ed prod­ucts will be manda­to­ry and the destruc­tion of unsold tex­tile goods will be banned. 

For any strat­e­gy to work both in the UK and EU, it must go beyond vol­un­tary ini­tia­tives.

The UK Fix­ing Fash­ion Report, pub­lished in 2018, was reject­ed by the gov­ern­ment on all 18 claus­es that put for­ward ideas like the intro­duc­tion of a 1p gar­ment levy to tack­le fast fash­ion. Two years lat­er, in Octo­ber 2020, the Envi­ron­men­tal Audit Com­mit­tee stat­ed it would reopen the case but tan­gi­ble advance­ments are yet to be made. 

Suc­cess­ful future poli­cies require a holis­tic approach, incor­po­rat­ing envi­ron­men­tal, social, and com­mer­cial fac­tors cou­pled with legal­ly bind­ing tar­gets. What remains cer­tain is that progress to cre­ate long-term sus­tain­abil­i­ty can­not stop at the bor­der of the EU, giv­en the glob­alised nature of the tex­tile val­ue chain.