Eunomia recently published a study for the European Commission offering recommendations on how EPR (Extended Producer Responsibility) schemes should operate – a policy approach where producers take financial responsibility for the end of life management of products.

The research reviews the French EPR scheme for end-of-use clothing, linen, and shoes – the only mandatory scheme for this sector in operation in the world. Mark Hilton, Head of Sustainable Business at Eunomia, is calling on fashion brands with sustainable ambitions to look at what’s happening in France and lobby for a similar system to level the playing field and get ahead of the game before policies change. We asked him why:

Fast fashion has spun out of control

Mark said: “Despite a host of initiatives within the sector to stimulate change, the negative environmental impact of the textiles sector remains extreme. According to the EU’s Circular Economy Action Plan (CEAP), published in March 2020, textiles are the fourth highest-pressure category for the use of primary raw materials and water, after food, housing and transport, and fifth for GHG emissions. Shockingly, it is estimated that less than 1% of all textiles worldwide are recycled into new textiles. The EU is now proposing a specific comprehensive EU Strategy for Textiles based on input from industry and other stakeholders, as part of its CEAP. One of the recommended measures is EPR, and even though it’s tricky to say when countries will start their schemes, it’s high on the list and coming pretty soon”.

A high price to pay for brands left behind

“Many textiles businesses are well aware of their environmental footprint and want to improve, but like any business, they have their hands tied to an extent if they are to remain competitive. The fashion world is also unusual in that even the biggest brands have a very small market share and hence can’t make the impact they would like too. Well-designed regulation, and EPR in particular, offers the ‘better’ businesses a means to level the playing field.”

“The other thing to point out is that in EPR systems going forward, products have to be scored against a set of criteria as part of a system called eco-modulation. Under eco-modulation, the fees paid by the producer vary according to specific criteria relating to aspects of their products’ environmental performance. The more ‘environmentally-friendly’ products are charged at a lower rate than those that are less ‘environmentally friendly’ to incentivise eco-design. We recently put together research for the European Commission that sets out some of the key criteria to be used, including: incorporating recycled content, improving durability, making products more repairable, and integrating reuse into business models. Another key area is in relation to so-called ‘product passports’- providing detailed information on materials for users and recyclers; particularly important given the known inaccuracy of garment labels today.”

The need for innovative design

“Design is obviously the key enabler in all of this – using more durable and lower carbon materials, including organic and recycled materials, and making clothing genuinely recyclable. While there are novel recycling techniques under development, chemical and mechanical, mono-materials are so much easier to deal with than mixed materials such as poly-cottons and cotton-elastane mixes; no-matter how attractive for designers and consumers. It may even be that the very worst materials, from an environmental performance point of view, will actually be excluded from the EU in the future through minimum eco-design requirements for market entry – there is a precedent in terms of minimum requirements for electrical goods and in relation to certain types of packaging being banned from 2021. EPR can then be used, over and above these baseline requirements, to incentivise better eco-design, through eco-modulation, for the vast majority of products that will remain on the market.”

A call for a new form of collaboration

“Collaboration in the sector on environmental matters has improved in recent years, and while voluntary agreements, such as the Sustainable Clothing Action Plan (SCAP) in the UK, are helpful in spreading good practice, and have influenced supply chains to reduce carbon and water use, progress has been extremely slow around end of life. The sector faces a perfect storm, whereby separate used textile collections are soon to be mandated in the EU, and hence will grow dramatically, and yet the value of the material (largely due to ‘fast fashion’ quality trends and market gluts) is often too low to make commercial clothes recycling stack up. Given that we are facing a climate emergency, it is time for the ambitious brands to come together and push for a world-class textiles EPR system as we believe that it’s the only way to make quick progress. Eunomia are keen to work with the industry to help shape that EPR system so that it gives the most environmentally-conscious brands the market advantage they deserve, and the whole industry a more sustainable future.”