The Policy Hub – Circularity for Apparel & Footwear, remains committed to supporting the climate, environmental, and human rights goals that form the basis of the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD). We also support efforts to maintain the competitiveness of the EU single market by ensuring sustainability, aligning obligations across frameworks, and simplifying reporting requirements to better merge the regulatory context of the CSDDD, CSRD, and the EU Taxonomy Regulation.
The objective of this document is to map existing efforts, such as standards, guidelines and tools, already available for the implementation of due diligence. The specific focus of this exercise is on the garment and textile sector. The paper further seeks to outline the key areas where effective guidelines are most needed, not only in the context of the garment and textile sector, but also to support the exercise of developing the general CSDDD guidelines and accompanying measures. The document underscores the interconnected nature of components critical to fulfilling due diligence obligations, emphasising the need for coherence among tools and strong collaboration among stakeholders.
The Policy Hub – Circularity for Apparel and Footwear, representing over 700 stakeholders and encompassing more than 50% of the apparel and footwear sector, supports the European Union's commitment to harmonise initiatives governing the labelling of textile products. As the industry undergoes transformative changes, characterised by the emergence of novel fibre materials and innovative labelling options, the Policy Hub acknowledges the imperative to amend the Textile Labelling Regulation. This necessitates a comprehensive approach, encompassing modernisation, digitalisation, and alignment with ongoing and upcoming EU textile-related initiatives.
The Policy Hub was launched with a mission: uniting stakeholders across the textile and footwear value chain to speak in a shared voice with European decision-makers. Our goal? To advocate for an ambitious regulatory framework that prioritises environmental and social sustainability within the sector.
We encourage the EU authorities to sustain and strengthen collaboration between policymakers and industry stakeholders, recognising the favorable results achieved through constructive engagement in the 2019-2024 mandate. As a sector, we are prepared to offer valuable insights and feedback, leveraging our industry and market expertise, to support the EU authorities’ endeavors in fostering well-informed policymaking.
These high-level recommendations, developed by the Textile Industry using a multi-stakeholder approach, are designed to guide the European Commission in developing guidelines for the textile sector on the implementation of the Corporate Sustainability Due Diligence Directive (CS3D), notably regarding the due diligence processes, the specific risks of adverse impacts for our sector, the use of multi-stakeholder initiatives (MSI) and industry initiatives in due diligence processes as well as stakeholder engagement.
The EU has a range of instruments in its "toolbox" for climate policies for the apparel and footwear sector. It’s a matter of wielding the instruments within the toolbox, including being optimised individually and leveraged as a system. A review of potential policy options linked to both climate mitigation and climate adaptation was undertaken to evaluate how extensive the current EU positioning on climate and textiles is compared to the possible types of policy instruments available.
The EU has a range of instruments in its "toolbox" for climate policies for the apparel and footwear sector. It’s a matter of wielding the instruments within the toolbox, including being optimised individually and leveraged as a system. A review of potential policy options linked to both climate mitigation and climate adaptation was undertaken to evaluate how extensive the current EU positioning on climate and textiles is compared to the possible types of policy instruments available.
Over the past years, significant developments have taken place regarding novel fibre materials and new labelling possibilities. Given these developments, the Policy Hub supports the necessity of amending the Textile Labelling Regulation. This involves modernising, digitalising, as well as harmonising the regulation with existing and developing textile-related EU initiatives.
The Policy Hub – Circularity for Apparel and Footwear supports the efforts of the European Commission to set up the EU's first detailed set of rules on how companies must substantiate reliable, comparable, and verifiable claims about the environmental impact, aspect and performance of products and services they offer across the EU. We support the ambition to make these types of claims reliable, comparable, and verifiable across the EU and put an end to greenwashing. This ambition shall not, however, lead to green hushing. Clear, actionable, and unambiguous rules should direct the textile sector to make science-based environmental claims.
The EU consumed a total of 6.6 million tonnes of clothing, footwear & household textiles in 2020. Our systems to manage these materials at the end of their life are wholly inadequate for a circular economy. As such, the majority of these products being disposed of in residual waste. Extended Producer Responsibility (EPR), a cornerstone of the EU Strategy for Sustainable and Circular Textiles, has the potential to deliver transformative improvements in the collection and management of used and waste textiles.
The textiles industry is a highly complex, interconnected value chain that plays an important role in global economies. However, it is also accountable for significant negative impacts on the environment. In 2020, total consumption of clothing, household textiles and footwear in Europe amounted to 6.6 million tonnes (15kg per person). That same year, textile consumption in Europe had, on average, the fourth highest impact on the environment and climate change from a global life cycle perspective, after food, housing and mobility.
The Policy Hub - Circularity for Apparel and Footwear welcomes and supports the European Commission’s proposal to revise the Waste Framework Directive (WFD). The ambition of the Policy Hub is to improve the circularity of the textile sector by maintaining as much value as possible of resources used in the production of textile products. It is estimated that the textile waste in EU-27 and Europe will grow from 7.0 million to 7.5 million tons today to 8.5–9.0 million tons in 2030.1 It is necessary to take measures to deal with this waste through both waste prevention and the end-of- life management of textiles.
The Policy Hub – Circularity for Apparel & Footwear is a strong supporter of digitalisation and the use of digital technologies to communicate product information. Digital communication vehicles (for instance QR codes, Data Matrix) would provide better ways to share easily accessible, complete, up-to-date, comparable, trustworthy, and easy-to-correct information. Furthermore, from an environmental perspective, electronic labelling would avoid creating extra waste in the form of more or larger labels and hangtags to accommodate the required information and its translations in a given minimum font/format.
This is a summary document of Policy Hub's position paper on the EU's Sustainable Product Policy.
The Policy Hub – Circularity for Apparel and Footwear supports the EU’s plans to make sustainable products a norm as part of the Sustainable Product Initiative (SPI). We expect that the SPI will ensure harmonisation across the EU and create a needed level playing field when it comes to design requirements of textiles to make them fit for the circular economy. To fully leverage SPI’s potential and achieve its intended goal of making products sustainable, the Policy Hub provides recommendation in this position paper.
In the light of the upcoming regulatory requirement to separately collect textile waste in all EU Member States by 2025 and the expected publication of the EU Textiles Strategy, Extended Producer Responsibility (EPR) is being assessed by policymakers at EU and Member State level as a potential instrument to promote textile waste management as well as to support handling of the expected increase in textile collection volumes. The signatories of this position paper are committed to accelerate circularity in the textiles, apparel and footwear value chain by changing how textiles are produced, used and recirculated into new material, as well as to contribute to attain the sustainability goals.
The Policy Hub’s mission is to help develop a consistent European policy framework that accelerates the transition to a circular system for the apparel and footwear industry, incentivises textile products’ environmental performance at all stages of products’ lifecycle, and stimulates innovation in more sustainable and circular business models, materials, and production processes. In light of the ambitions and the experience of the sector it represents, the Policy Hub – Circularity for Apparel & Footwear highlights “critical success factors” that must be taken into account to make the EU Textile Strategy impactful and efficient.
In light of the current EU and its Member States discussions on the extended producer responsibility (EPR) schemes, the Policy Hub together with Circle Economy, Euratex, EuRIC, EuroCommerce, Government of Catalonia, and the Municipality of Milan sent a letter to the European Commission asking for EU-harmonised rules for EPR.
The Policy Hub welcomes the discussions on how to unlock the full potential of textile waste - including apparel and footwear. The core message is that textile waste shall ultimately be considered as a new material resource. The future for our sector is a circular textile system, where products are made to last longer, from safe, recycled or sustainably sourced inputs that can recirculate multiple times.
Looking back, the Policy Hub’s two-year progress report reflects on how our policy work started introducing our partner organisations and providing key highlights, such as the number of contributions we submitted to the European Commission. The report also discusses how the Policy Hub has been guiding the industry to become more sustainable.
Comparable and reliable claims require a common methodology to assess the impact of a product. Hence in its position paper, the Policy Hub is asking the EU to impose one common methodology and database for making green claims about a product. This is a major change as currently companies are free to choose any methodology to assess the impact of their products. Also, vague and ambiguous blanket claims such as "sustainable product" should be prohibited as they are misleading. Other claims related to sustainability need to follow a vigorous substantiation protocol in order to ensure that they are accurate and understandable to the average consumer.
The COVID-19 pandemic has shaken the global economy. The apparel, textile and footwear industry is no exception. This crisis coincides with sustainability programs and commitments have increasingly becoming the industry norm and steps towards achieving a circular economy and carbon neutrality are taken. Shifting the economy to a more circular one requires all hands on deck and is a collaborative effort by citizens, industry and policymakers who can build upon both existing commitments and new initiatives together. The Policy Hub proposes seven key principles that should serve as a roadmap to ensure economic recovery while also driving the development towards a circular economy.
Vision of the Policy Hub on how to include circular economy principles at the design stage of product development.
The Policy Hub supports the European Commission’s initiative to address the challenge of textile waste and welcomes the consideration of extended producer responsibility (EPR) as an option to implement the regulatory requirement to separately collect textiles by 2025.
The value of creating circular business models has been recognised for many of the EU’s waste streams and within the circular economy agenda – from plastics to electronics to cars – thanks to the substantial benefits to be gained both in environmental and financial terms. Textiles have been identified as one of the waste streams with the highest untapped potential to implement circular practices.
