In a new report for Changing Markets Foundation and the European Environmental Bureau, Eunomia recommends that Extended Producer Responsibility (EPR) should be a core component of the EU’s forthcoming Textiles Strategy.
Textiles are identified as a key value chain in the EU Circular Economy Action Plan published in March 2020, with the Textiles Strategy set to outline measures to advance a circular economy for textiles.
Eunomia’s study, published yesterday (9 March) finds that the introduction of EPR in this space would be a key mechanism by which the polluter pays principle can be operationalised, by shifting the end-of-life costs of managing textile waste onto producers, and away from municipalities, and, by extension, citizens.
Tackling over-consumption and improving design
Ensuring that producers bear the financial costs associated with end-of-life management of the textiles they sell means that these costs – to the extent that they are passed through – are ultimately visited on consumers in proportion to the extent they consume. The study asserts that ‘it is only fair that those who consume more, pay more’, warning that an absence of EPR provides an ‘explicit subsidy to consumption’. Over-consumption, Eunomia states, is ‘at the root’ of the challenges faced by the textile industry, and EPR is essential in tackling this.
EPR, Eunomia asserts, also holds the potential to incentivise improved design of textiles through varying the levels of the EPR fees according to relevant criteria. The strength of such an incentive will depend, amongst other factors, upon the size of the fee relative to the sales price of the textile item to which it is applied.
Citing the French EPR scheme for textiles, Re_Fashion, the only currently operating scheme of its kind in the EU, the report highlights the need for ‘full coverage of end-of-life costs’. Fees paid to Re_Fashion by producers only cover a small proportion of the full end-of-life costs that could potentially be covered by EPR. Full coverage, Eunomia says, would increase the relative size of fees, and the influence of modulation on design choices. The report notes, however, that there ‘will always be some textile items that are less likely to be influenced by such incentives.’
The report also recommends that, as a priority, several minimum eco-design requirements are introduced alongside EPR, as well as a ban on the use of substances of very high concern (SVHCs) in textile products. These supporting policy instruments, Eunomia says, would both help to support the effectiveness of EPR schemes, and complement them by addressing issues that may be difficult to address through EPR.
These are as follows:
- Banning the use of hazardous chemicals and materials in clothing and textile products.
- Implementing minimum eco-design requirements for stress resistance and lifetime of products and components.
- Implement minimum eco-design requirements for design practices per product category that allow disassembly for replacement and repair, or for recycling.
- Implement minimum repairability and modularity requirements.
Eunomia also makes several recommendations as to actions that should be undertaken at the EU level to maximise the effectiveness of EPR in driving positive change through harmonisation of specific aspects, as well as requirements for performance. These are:
- Setting performance targets for the collection and management of used and waste textiles, including repair, collection, preparation for reuse, and recycling (with increasing proportions of closed-loop recycling).
- Establishing an EU-level definition for obligated Producers.
- Establishing an EU-level classification for when textiles become waste.
- Establishing EU-level classifications for granularity of fee structure and associated reporting obligations.
- Establishing EU-level criteria for eco-modulation and associated reporting obligations.
Other measures to be considered, as outlined in the report, include the implementation of recycled content targets in textiles, a VAT reduction on repair, limits on microplastics release, and establishing a data reporting and verification for material flows throughout the value chain.
Such measures, Eunomia states, have ‘the potential to change the landscape for textile circularity in Europe’.
Environmental impact
Textile consumption has a significant environmental impact in Europe. 2020 records show that textile consumption in Europe had, on average, the fourth-highest impact on the environment and climate change from a global life cycle perspective, with the total consumption of clothing, household textiles and footwear amounting to 6.6 million tonnes.
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