Towards sustainable consumer goods: the EU Textile Strategy and the Ecodesign regulation

On March 30, the European Commission published several long-awaited initiatives. Among others, the EU Strategy on Sustainable Textiles and the Ecodesign regulation are two main building blocks of the European Green Deal.

The Textile Strategy and the SPI will have ramifications across several policy areas, including traceability, the EU Eco-label, Product Environmental Footprint (PEF), self-regulation, market surveillance, Green Claims, and REACH, to name a few.

The EU Textile Strategy

Those who expected a long, detailed strategy on the future of the European textile sector might be disappointed by the published 14-page document. Still, the strategy results from years of consultations between the EU, businesses, and NGOs.

Over the last years, the textile sector has been put under the spotlight. Branded both as a signature industry of the Old Continent and the fourth most polluting sector, it is seen as a steppingstone in relaunching European leadership in the green and digital transition. Since the early days of the von der Leyen Commission, textiles have been identified as a priority sector for intervention. Intense public and behind-closed-doors consultations among the industry, EU institutions, member states and NGOs took place on a number of topics to identify key risk areas of the sector and design viable solutions to make the sector increasingly sustainable and contribute to the EU’s environmental and climate goals. This resulted in several targeted and cross-sectoral initiatives – some of which are already rolled out – covering varying needs from production and consumption, to finance, skills, transparency and due diligence. The Textile Strategy aims to coherently steer the deployment of these initiatives and contribute to making a more sustainable, resilient and competitive EU textile sector.

The strategy bundles together six flagship actions based on existing and upcoming proposals: mandatory ecodesign requirements to extend products’ lifecycle; stopping the destruction of unsold textiles, tackling microplastics pollution through an initiative on the unintentional release in the environment; introducing information requirements through digital product passports and reviewing the Textile Labelling Regulation; fighting greenwashing through Green Claims and Ecolabel; boosting Extended Producer Responsibility schemes to reuse and recycle textile waste.

The strategy also sets up the “enabling conditions” of this transition, identifying five: the co-creation of a Transition Pathway for the textiles ecosystem, curbing fast fashion, overproduction and overconsumption; ensuring fair competitiveness through market surveillance, supporting R&D, and developing reskilling and upskilling. Finally, the Strategy also binds the future of the EU textile sector to stricter due diligence rules across global supply chains and improving the restrictions on waste shipment.

The Ecodesign regulation

We have already spoken about the SPI in the past. This initiative is also the result of a long reflection process in the European Commission, which started during the second Juncker Commission in 2018 with the new Product Policy Framework. VdL’s Commission took up the baton, and today’s proposal has the ambitious goal to repeal the current Ecodesign directive with a regulation empowering the European Commission to develop ecodesign criteria for different categories of consumers products by embracing their whole lifecycle from raw materials to end-of-use and beyond with the recycling of materials. The Commission will carry out this task with the support of an expert group called Ecodesign Forum, representing a variety of stakeholders which includes industry and NGOs. Fulfilling these criteria will be a prerequisite for entering the EU market.

From the very first moment, it was clear this regulation would be the tip of an iceberg made of complex secondary legislation, technical rules and calculation methodologies. The proposal introduces several “performance criteria” measuring key sustainability aspects of products such as durability, reliability, reusability, repairability, recycling and remanufacturing, chemicals and recycled content, energy and resource efficiency, environmental footprint (PEF) and more. The Commission will also be tasked with drafting information requirements that establish what information should be accompanying the product, stretching from performance to handling and treatment.

Companies will be faced with a critical question: will my products be prioritised? The European Commission will base its prioritisation on several considerations ranging from a products’ contribution to the EU climate and energy goals, the absence of EU, national or voluntary rules, the volume of sales and the distribution of environmental impacts, energy use and waste generation across the value chain. What is not yet clear is how product categories will be identified. A complex sector like textiles is a textbook example of why these rules must be carefully crafted: besides fashion, textiles are used for a myriad of other purposes for which the same ecodesign criteria will be hardly applicable – from construction to medical equipment, following different rules and entailing different production processes and safety standards.

The SPI also introduces a digital product passport that must accompany all products and contain information on the ecodesign criteria and more. The proposal envisages an interoperable IT infrastructure allowing all existing traceability solutions to communicate with each other. However, uncertainty remains around the additional costs to build up and maintain the new IT infrastructure, the burden of producing and transferring large technical documentation, and the system to verify the veracity of the information in the DPP.

It will also be interesting to see how the SPI will interact with the upcoming Green Claims Initiative, meant to prevent greenwashing. Through the SPI, the Commission is empowered to regulate the content and layout of labels and the inclusion of performance classes for consumers to compare products. Companies should be ready to assess how their current labelling schemes will be impacted and how the comparability between products will be implemented in practice, a complex issue DG ENVI is already struggling with under the PEF work.

Finally, the SPI prohibits the destruction of unsold goods in the attempt to curb excess production and provide new streams of non-virgin raw materials. The prohibition comes with some exceptions – e.g. for damaged products or health and safety considerations – and with a sort of naming and shaming mechanism under which companies will have to disclose how many products they destroy, why and how.

Conclusions

All in all, the proposal promises to reshape the way consumer products are produced, consumed, and disposed of, calling on the EU private sector to radically rethink its supply chains. Through the Textile Strategy and the SPI, alongside other initiatives like the New Consumer Agenda, the PEF or the Right to Repair, the European Commission is truly delivering on its promise to “break down the silos” between different fields to design future-proof policies. Of course, this comes with an increasingly complex legislative framework. Lykke Advice has years of experience in lobbying the various EU institutions and can help you untangle and shape EU policymaking and exemplify to decision-makers the challenges and opportunities of your company or organisation.

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