by Tanja Gotthardsen (first published in Danish in November 2021)
translated from Danish by Tenna Johanning Hjelm
Lack of holism, useless data, and unreliable tools. In this article, we look at how the recently proposed European environmental labeling scheme for fashion and textile products* could potentially end up misleading brands and consumers alike. And we also take a brief look at the industry's wider data problem. The idea of a common European labeling scheme for the products we surround ourselves with is by no means new, and many would say long overdue. But while the first pilot projects for the so-called Product Environmental Footprint (PEF) have been underway since 2013 for everything from food to electronics, it is only recently that a more concrete proposal for the labeling of fashion and textile products has entered the agenda.
The *PEF is called the Apparel and Footwear Product Environmental Footprint Category Rules and includes footwear. The latest consultation period ran from 7 July to 24 September 2021, but the proposal has attracted limited attention, except for activities in line with the Make the Label Count campaign. This post will therefore be updated should opportunities for action arise at a later date.
Labeling will, by all accounts, depend on a methodology that is utterly devoid of the holism that the EU claims to operate under. And digging a little deeper, it is striking that the secretariat of the proposed labeling scheme is made up of the very same organization that consistently promotes synthetic materials as more sustainable - and does so using inconsistent and unsubstantial data.
The Product Environmental Footprint (PEF) should be understood in the context of the EU Green Deal, which seeks to decouple economic growth from increased resource consumption, and the Circular Economy Action Plan (CEAP), the EU's post-COVID strategy to make so-called “sustainable products” the norm in the EU. The latter in particular has a pronounced focus on empowering consumers to consume in a more circular and so-called sustainable way, especially concerning resource-intensive industries, of which textiles is one. Indeed, the EU rates textile consumption as the fourth largest pressure category in terms of raw material and water use (after food, housing, and transport), and the fifth-largest in terms of greenhouse gas emissions (European Commission 2021). Many underlying initiatives, such as the Sustainable Product Initiative (SPI) Directive, which focuses on products being "...durable, reusable, repairable, recyclable, and energy-efficient" (European Commission 2020), are therefore also under development. However, the PEF is a very specific measure, aimed directly at guiding consumption.
Unfortunately, there are strong indications that the PEF risks falling victim to the same biased data selection that we have seen from the industry's major players in recent years. For example, according to the Make the Label Count campaign, the PEF methodology includes land use, water use, and emissions for the fiber stage of natural materials, while the score for synthetic materials completely omits the impacts resulting from fossilization - and it does not take into account, for example, how natural materials, especially those farmed under regenerative practices, may assist in lowering emissions. At the same time, the PEF also does not take into account long-term microplastic pollution, which again skews the picture in favour of synthetic materials. Then adding parameters such as renewability, recyclability, and biodegradability - all qualities that are to be found in natural materials - and synthetic materials start falling short. However, these parameters are not included in the PEF calculation. And we haven't even started talking about durability and longevity (technical as well as emotional), which is also largely absent from the PEF (Make the Label Count 2021b). So, the picture is that the PEF's "Cradle to Gate" life cycle analysis will conveniently give preference to the frequently cheaper, synthetic materials used mainly by the industry's fastest movers - and will completely underplay the importance of the clothing's use phase. And this, despite recent research suggesting that different fibers are preferable for different functions (Laitala, Grimstad Klepp & Henry 2018).
"If we make a mistake about labeling today, we lose our moral authority to revert to all other forms of greenwashing. And there is an epidemic of greenwash in our industry." (Livia Firth, keynote, Make the Label Count, 2021a)
But there is also something striking about the fact that the PEF is only linked to environmental impact, without accounting for social responsibility, if the aim of the EU is really to move towards more responsible products. Especially since natural materials represent such an important source of income for many of the world's poorest populations (Bates Kassatly & Baumann Pauly 2021). And indeed, the potential unilateralism of the PEF also contrasts with the overarching sustainability definition on which the EU leans: namely, the Brundtland definition, which, while not particularly concrete or operational, emphasizes a high degree of holism. In case it has been forgotten, it goes: "Sustainable development is a development that meets the needs of the present without compromising the ability of future generations to meet their own needs." But as Veronica Bates Kassatly and Dorothee Baumann Pauly point out in a whitepaper for the agency Eco-Age from earlier this year, the definition does not end there: indeed, the Brundtland Report also states that the focus on "needs" is particularly linked to the world's poorest and that these must be given overriding priority (Bates Kassatly & Baumann-Pauly 2021). But here too the PEF does not seem to be of much help.
"Apart from the occasional anecdotal evidence, none of them attempt to measure sustainability in terms of meeting the needs of the world's poor. The only area of focus is environmental impact, and almost without exception, brands and initiatives mix ... sustainability with environmental impact." (Bates Kassatly & Baumann-Pauly 2021)
But why does the PEF look the way it does? One explanation could be that it's because of the tools that the EU is using as a template - a tool that has continuously been under criticism for exactly the type of data selection we're seeing now. Here I’m referring to the so-called Higg Index, which has been heavily criticized for its Materials Sustainability Index (MSI). Among other things, the Higg MSI has received criticism about the data used being called "ridiculously outdated and irrelevant" (Grimstad Klepp & Skårdal Tobiasson 2020) and downright unscientific (Bates Kassatly 2020b). An example being polyester scores that are supposedly calculated according to European best practice, even though the vast majority of the world's polyester is neither produced in Europe nor the result of best practice manufacturing, while cotton scores are calculated according to a global average (Bates Kassatly, 2020a; Wicker 2020).
At the same time, coverage by Apparel Insider reveals that the Sustainable Apparel Coalition (SAC), which is behind the Higg Index, has not even consulted with leather, alpaca, or silk manufacturers to obtain data for their respective materials, and that a case has now been brought against SAC/Higg (Apparel Insider 2020). And when comparing the MSI scores for regular cow leather (176/kg), alpaca (320/kg), and silk (1086/kg) with the scores from their synthetic substitutes polyurethane (37.2/kg), acrylic (48.7/kg), and acetate (79.6/kg), the picture shows the MSI giving preference to synthetic materials (Wicker 2020). The lower the score, the lower the environmental impact, it seems. But again, the MSI, like the PEF, is only Cradle to Gate, meaning it does not take into account the impacts that stem from usage and end of life, just as it is selective about what is included in the cradle parameters. The argument for using Higg's methodology anyway is most often that it is currently "the best we have" - but honestly, should we really be reliant upon a tool that leaves out so many crucial parameters when it comes to something as comprehensive as the legislation and, in fact, labeling that will direct our consumption?
“We believe that anyone supporting the Higg MSI is running a serious reputational risk. Given its addition to the online database used by global law enforcement agencies to investigate and prosecute questionable business practices, the trustworthiness of the SAC is irrevocably tarnished.” (Bates Kassatly & Baumann-Pauly 2021)
If we look at who has been appointed as the technical secretariat of the EU PEF, it is the very same SAC, the organization behind the Higg Index and the MSI, that has been left in charge. In other words, the same organization that is under fire for dubious business practices is running the show. And the voting members of the preparation of the PEF? They include H&M, Inditex (Zara, etc.), C&A, Nike, VF Corporations (Vans, The Northface, etc.), etc. Here, see for yourself. Of course, this is not much different from BESTSELLER being appointed by the Ministry of Business as head of the task force for sustainable transformation of the Danish fashion industry, despite their criticizable cancellation of already produced orders in 2020 (see Worker Rights Consortium 2020 here, here and here) - but it still creates a doubt about which interests are being served.
“The Higg Index is only cradle to gate - what happens when that garment is worn and ultimately disposed of, is not included. In short, the Higg Index can only claim to deliver a holistic overview of all fabrics that behave in the same way when used and disposed of. And we know they don’t.” (Bates Kassatly 2020a - also Laitala, Kirsi, Ingun Grinstad Kleep & Beverley Henry 2018)
However, it is not only about the Higg Index and now, presumably, the PEF that the fashion industry has a data problem. In the report "Cotton: A case study in misinformation," published in early October 2021, it appears that some cotton is designated as "preferred" or "better" on shaky grounds and that the fiber report on which the industry broadly bases its decisions is deeply flawed (Transformers Foundation 2021). But we'll save that for the next post. Thanks for reading along.
Update: Since this article was initially published, multiple brands have been forced to remove consumer facing usage of the Higg MSI in multiple countries, whereof Norway is the most prominent case, as authorities have concluded that the current material claims made under Higg are, in fact, greenwashing. How and whether this will affect the EU’s development of the PEF remains to be seen, but this author, as well as the team at Make the Label Count are working hard to ensure that future legislation will, in fact, be a matter of ensuring sustainability over profitability.
Bio of author:
Tanja Gotthardsen is an independent researcher and owner of the sustainability consultancy Continual, based in Aarhus, Denmark. She specializes in the intersections between cultural history and communication, human rights, conflict theory, and sustainability. She is an approved consultant under the Danish government funded corporate social responsibility (CSR) program, “Textile Demands of the Future”, and has worked extensively with the Danish independent consumer council, Forbrugerrådet Tænk, on strengthening sustainability-related consumer law.
References:
· European Commission (2021): EU Strategy for Textiles, Roadmap, ref. Ares(2021)67453
· European Commission (2020): Sustainable Products Initiative, Inception Impact Assessment, Ref. Ares(2020)4754440