Revision of the EU green public procurement (GPP) criteria for textile products and services : technical report with final criteria.
Date: 2017-06-29
Institutions: Joint Research Centre
Subjects: durable goods, eco-label, environmental impact, environmental protection, green public procurement, manufactured goods, public contract, recycled product, research report, service industry, textile fibre, textile industry, textile product

Revision of the EU Green Public 
Procurement (GPP) Criteria for 
Textile Products and Services 

Technical report 
with final criteria 

Nicholas Dodd, Miguel Gama Caldas (JRC) 

June 2017 

EUR 28666 EN 

This  publication  is  a  Science  for  Policy  report  by  the  Joint  Research  Centre  (JRC),  the  European  Commission’s 
science and knowledge service. It aims to provide evidence-based scientific support to the European policymaking 
process. The scientific output expressed does not imply a policy position of the European Commission. Neither the 
European Commission nor any person acting on behalf of the Commission is responsible for the use that might be 
made of this publication. 

Contact information 
Name: Nicholas Dodd 
Address: Edificio Expo, c/ Inca Garcilaso, 3. E-41092 Seville (Spain) 
Email: jrc-ipts-textiles@ec.europa.eu 
Tel.: +34 954 488 728 

JRC Science Hub 
https://ec.europa.eu/jrc 

JRC107241 

EUR 28666 EN 

PDF 

ISBN 978-92-79-70109-2 

ISSN 1831-9424 

doi:10.2760/906174 

Luxembourg: Publications Office of the European Union, 2017 
© European Union, 2017 

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How  to  cite  this  report:  Dodd  N  and  De  Oliveira  Gama  Caldas  M.  Revision  of  the  EU  Green  Public  Procurement 
(GPP) Criteria for Textile Products and Services: Technical Report with final criteria. EUR 28666 EN. Luxembourg 
(Luxembourg): Publications Office of the European Union; 2017. doi:10.2760/906174 

All images © European Union 2017, except where the source is specified in the caption of a figure or a table and 
cover page, promicrostockraw, 2016, Fotolia.com. 

Title:  Revision  of  the  EU  Green  Public  Procurement  (GPP)  Criteria  for  Textile  Products  and  Services: 
Technical report with final criteria. 
Abstract 
The revision of the Green Public Procurement (GPP) criteria for Textile products and Services is aimed at helping 
public  authorities  to  ensure  that  textiles  products  and  services  are  procured  in  such  a  way  that  it  delivers 
environmental improvements that contribute to European policy objectives for energy, chemical management and 
resource  efficiency,  as  well  as  reducing  life  cycle  costs.  In  order  to  identify  the  most  significant  improvement 
areas  for  criteria  development  an  analysis  has  been  carried  out  of  the  environmental  impacts  of  manufacturing 
and using textile products and providing textile services. The most commonly used procurement processes have 
been  also  identified  and  are  further  addressed  in  the  separate  criteria  document  (published  as  a  Staff  Working 
Document of the Commission). Together these two documents aim to provide public authorities with orientation 
on how to effectively integrate these GPP criteria into their procurement processes. 

Table of Contents 

1. INTRODUCTION ........................................................................................................................................................................ 5

1.1 Criteria definition and scope ......................................................................................................................................... 6 
1.2 Market analysis ................................................................................................................................................................. 10 
1.3 GPP criteria currently in use by selected Member States ......................................................................... 12 
1.4 The key environmental impacts of textiles ....................................................................................................... 15 

2. GPP criteria proposals ....................................................................................................................................................... 19

2.1 Textile product related criteria.................................................................................................................................. 19 
2.1.1 Selection criteria for tenderers ........................................................................................................... 19 
2.1.2 Fibre sourcing ............................................................................................................................................... 21 
2.1.2.1 Cotton fibres ............................................................................................................................ 21 
2.1.2.2 Wool fibres................................................................................................................................ 31 
2.1.2.3 Man-made cellulose fibres (e.g. viscose, modal, lyocell)................................ 33 
2.1.2.4 Polyester and Polyamide (nylon) fibres.................................................................... 40 
2.1.3 Chemical restrictions ................................................................................................................................ 47 
2.1.3.1 Substances to be tested for on the final product............................................... 48 
2.1.3.1  Restrictions  on  the  use  of  substances  to  be  verified  by 

production sites ................................................................................................... 53 
2.1.4 Durability and lifespan extension ...................................................................................................... 57 
2.1.4.1 Durability standards ............................................................................................................ 57 
2.1.4.2 Availability of spare parts and accessories ........................................................... 61 
2.1.5 Energy conservation during use ......................................................................................................... 62 
2.1.5.1 Fabric selection to minimise drying and ironing energy use ........................ 62 
2.1.5.2 Care labelling textile maintenance ............................................................................. 65 
2.1.6 Design for re-use and recycling ......................................................................................................... 67 
2.1.6.1 Design for re-use .................................................................................................................. 67 
2.2 Textile service related criteria ................................................................................................................................... 68 
2.2.1 Scope of the textile service criteria .................................................................................................. 68 
2.2.2 Selection criteria for tenderers ........................................................................................................... 69 
2.2.3 Asset management systems ................................................................................................................ 71 
2.2.4 Fabric selection to minimise drying and ironing energy use ............................................. 75 
2.2.5 Laundry energy and detergents use ................................................................................................ 75 

3 

List of Tables 

Table 1. Fabric consumption by major public services (average 1990-2000) .............................. 11 

Table 2  Scope and criteria coverage of ten Member State GPP criteria sets ............................... 13 

Table 3. Overview of organic and IPM cotton production for 2012/13 ............................................. 21 

Table 4  Indicative recycled content 01/12 – 04/12 for GRS certified fibres ................................ 42 

Table 5  Indicative concentrations of functional and residual substances on final textile 

products ................................................................................................................................................................ 48 

Table 6. Proposed textile durability performance testing requirements ........................................... 58 

List of Figures 

Figure 1.  Impacts of textile consumption in the EU27 according to life cycle phase and 

midpoint indicator ........................................................................................................................................... 16 

Figure 2.  Global certified organic cotton production trend 2004-2012. ......................................... 23 

Figure 3  Normalised results for 1 ton of PET fibre using a “cut-off” approach with cradle-

to-factory gate for second life. Source: Shen et al (2010) ..................................................... 40 

Figure 4. Indicative overview of the EU textile supply chain ................................................................... 47 

Figure 5. Sankey diagram of primary energy use in an indicative flatwear laundry ................. 63 

Figure 6  Temperature settings of domestic washing machines in European countries ......... 66 

Figure 7  Specific Energy Consumption (SEC) of industrial laundry sites ........................................ 76 

4 

1. INTRODUCTION

This document provides the evidence base information for the revision of the Green Public 
Procurement  (GPP)  criteria  for  textiles.  The  study  has  been  carried  out  by  the  European 
Commission's  Joint  Research  Centre  (JRC  B5)  on  behalf  of  the  European  Commission's 
Directorate General for the Environment. 

The report also presents the final revised criteria which were developed taking into account, 
amongst other considerations, the revised EU Ecolabel textile criteria published in 2014. It 
records  the  discussions  and  feedback  received  from  stakeholders  during  the  revision 
process.  It  also  identifies,  based  on  the  background  technical  analysis,  new  criteria  areas 
for  consideration  in  order  to  better  address  key  environmental  impacts  of  the  product 
group. This includes a proposed new area of focus on textile services. 

1.1 How the EU GPP criteria are structured and can be used 
Green Public Procurement is a voluntary instrument. The criteria are divided into selection 
criteria, technical specifications, award criteria and contract performance clauses. For each 
set of criteria there is a choice between two ambition levels: 

- 

- 

The  Core  criteria  are  designed  to  allow  easy  application  of  GPP,  focussing  on  the 
key  area(s)  of  environmental  performance  of  a  product  and  aimed  at  keeping 
administrative costs for companies to a minimum.  

The  Comprehensive  criteria  take  into  account  more  aspects  or  higher  levels  of 
environmental  performance,  for  use  by  authorities  that  want  to  go  further  in 
supporting environmental and innovation goals. 

The different types of GPP criteria that can be included in an Invitation to Tender (ITT) are 
described in the Buying Green handbook (EC, 2011) as: 

-  Selection  criteria.  When  assessing  ability  to  perform  a  contract,  contracting 
authorities  may  take  into  account  specific  experience  and  competence  related  to 
environmental  aspects  which  are  relevant  to  the  subject  matter  of  the  contract. 
They may also exclude operators who are in breach of environmental law in some 
cases,  and  -  for  service  and  works  contracts  only  -  ask  specifically  about  their 
ability  to  apply  environmental  management  measures  when  carrying  out  the 
contract. 

- 

Technical  specifications.  These  constitute  minimum  compliance  requirements  that 
must be met by all tenders. They need to be related to characteristics of the work, 
supply  or  service  being  purchased  itself  –  and  not  to  the  general  capacities  or 
qualities of the operator. It is also very important that they are clear, understood by 
all operators in the same way and possible to be verified. 

-  Award  criteria.  These  can  be  used  to  stimulate  additional  environmental 
performance  without  being  mandatory  and  therefore  without  foreclosing  the 
market for products not reaching the proposed level of performance. 

-  Contract  performance  clauses.  These  specify  how  a  contract  must  be  carried  out. 
For supply contracts, the main opportunity for the use of environmental clauses is 
often to specify how the goods will be delivered. 

5 

1.2 Criteria definition and scope 

In this section the current scope of the EU GPP criteria are compared and contrasted with 
the revised EU Ecolabel criteria of 2014.  The findings from this comparison, together with 
feedback from stakeholders, are then used to formulate a new scope proposal. 

1.2.1 The scope of the current EU GPP criteria 

The current GPP textile criteria were published in early 2012. The criteria reflects the scope 
in article 1 of the Commission Decision of 9 July 2009 "establishing the ecological criteria 
for the award of the Community Ecolabel for textile products’’ [Decision 567/2009]. Three 
categories are defined: 

o  Textile  clothing  and  accessories:  clothing  and  accessories  (such  as  handkerchiefs, 
scarves, bags, shopping bags, rucksacks, belts etc.) consisting of at least 90 %  by 
weight of textile fibres; 

o 

Interior  textiles:  textile  products  for  interior  use  consisting  of  at  least  90  %  by 
weight of textile fibres. Mats and rugs are included. Wall to wall floor coverings and 
wall coverings are excluded; 

o  Fibres,  yarn  and  fabric  (including  durable  non-woven)  intended  for  use  in  textile 

clothing and accessories or interior textiles. 

Moreover,  for  ‘textile  clothing  and  accessories’  and  for  ‘interior  textiles’,  feathers, 
membranes  and  coatings  need  not  be  taken  into  account  in  the  calculation  of  the 
percentage of textile fibres. 

1.2.2 The scope of the revised EU Ecolabel criteria 

The revised EU Ecolabel criteria have a modified scope which is expanded to define three 
categories of product and two additional categories of intermediate products: 

(a) 

(b) 

Textile  clothing  and  accessories:  clothing  and  accessories  consisting  of  at  least 
80 % by weight of textile fibres in a woven, non-woven or knitted form; 

Interior  textiles:  textile  products  for  interior  use    consisting  of  at  least  80 %  by 
weight of textile fibres in a woven, non-woven or knitted form; 

(c)  Fibres,  yarn,  fabric  and  knitted  panels:  intended  for  use  in  textile  clothing  and 
accessories  and  interior  textiles,  including  upholstery  fabric  and  mattress  ticking 
prior  to  the  application  of  backings  and  treatments  associated  with  the  final 
product; 

(d)  Non-fibre elements:  zips, buttons  and  other accessories  that  are incorporated into 

the product. Membranes, coatings and laminates; 

(e)  Cleaning products: woven or non-woven fabric products intended for the wet or dry 

cleaning of surfaces and the drying of kitchenware. 

Cleaning products and non-fibre items such as zips, buttons and accessories were added as 
specific new sub-categories. The change to an 80% weight threshold was intended to align 
the  EU  Ecolabel  with  the  Textile  Names  Directive  (EU)  1007/2011  which  regulates  the 
labelling  of  textiles.  In  Article  3  of  the  Decision  the  exemptions  were  also  modified  to 
include linings and paddings of the kind that can be found in uniforms and suits: 

'For  ‘textile  clothing  and  accessories’  and  for  ‘interior  textiles’  fillings,  linings, 
padding,  membranes  and  coatings  made  of  fibres  included  in  the  scope  of  this 
Decision  need  not  be  taken  into  account  in  the  calculation  of  the  percentage  of 
textile fibres.' 

6 

 
 
Moreover, the scope of the textile fibres addressed by the criteria is now defined as follows: 

(a) 

(b) 

(c) 

(d) 

'textile fibres' means natural fibres, synthetic fibres and man-made cellulose fibres; 

'Natural fibres' means cotton and other natural cellulosic seed fibres, flax and other 
bast fibres, wool and other keratin fibres; 

'Synthetic fibres' means acrylic, elastane, polyamide, polyester and polypropylene; 

'Man-made cellulose fibres' means lyocell, modal and viscose. 

This was based on a view amongst stakeholders to clearly exclude textile fibres for which 
no ecological criteria were set, with silk and aramids being cited as examples. 

1.2.3 Stakeholder feedback on the current GPP criteria scope 

Feedback on the current scope of the EU GPP criteria was invited from stakeholders during 
the EU Ecolabel  revision process. The main comments received  are briefly summarised  in 
Box 1. 

Box 1. Summary of stakeholder feedback on EU GPP textile criteria scope 

Q1. Is the current scope clear and adequate? 

The  general  view  was  that  the  scope  was  clear  but  views  differed  on  whether  they  are 
adequate. 

The need to focus on specific products was highlighted e.g. work wear, emergency services, 
healthcare. 

Applications differ significantly, and it was questioned whether these could be adequately 
assessed with one set of criteria. 

Q2.  Are  there  any  areas  where  you  think  the  scope  should  be  more  specific  to  reflect  GPP 
procurement priorities? 

There  is  a  need  to  identify  specific  GPP  related  products  and  end-uses  e.g.  clothing/work 
wear,  work  wear  cleaning  services,  interior  office  decoration  (wall-,  floor-,  window 
coverings), bedclothes. 

Additional feedback received from the GPP Advisory Group was that textile services was an 
increasing area of focus. Some countries such as the UK, the Netherlands and Denmark are 
working  with  the  sector  and/or  are  looking  to  incorporate  such  a  focus  into  new  national 
GPP  criteria.  Moreover,  it  was  highlighted  that  the  Nordic  Swan  eco-label  has  a  specific 
criteria set addressing textile services. 

1.2.4 Defining textile services 

A number of stakeholders highlighted the importance of addressing textile services within 
the  scope  of  the  revised  criteria.  As  an  example,  the  Dutch  Work  wear  criteria1  include 
provision for services within their scope, defining them as: 

'logistical services (systems for the provision of work wear), measurement taking, 
repairs, stock management and design.' 

A separate criteria set has also been developed for 'Workwear cleaning services' with the 
suggestion that the two sets can be combined for certain types of services contracts. 

1  Dutch  Ministry  for  Infrastructure  and  the  Environment,  Criteria  for  the  sustainable  procurement  of  Work  wear, 
Version 1.3, October 2011 

7 

 
 
 
 
                                                        
Based  on  this  feedback,  together  with  a  review  of  literature  published  by  the  European 
Textile Services Association (ETSA), several possible elements of textiles services contracts 
can be described, namely: 

  Laundry – The procuring authority owns the textile products, is responsible for their 
maintenance but contracts out their cleaning (either in the form of laundry or dry 
cleaning). Collection and delivery are typically included within such a contract; 

  Maintenance  -  The  procuring  authority  owns  the  textile  products  and  contracts 
repair services intended to extend their useful life span. Typical examples of repair 
operations would be the replacement of small items like buttons and zippers, fabric 
panel replacement and the retreating/reproofing of functional coatings; 

  Take-back – A service provider is contracted to collect and sort the textile products 
(which are the property of the procuring authority) in order to ensure specified End-
of-Life management objectives. The procuring authority waivers the property of the 
textile products at the moment of their collection; 

  Renting – In this type of contract the procuring authority benefits from use of the 
textile  products  covered  by  the  contract  but  their  ownership  remains  with  the 
service  provider.  These  contracts  typically  involve  cleaning  services  as  well.  A 
typical  example  would  be  the  supply  of  clean  bed  sheets  to  a  hospital.  In  this 
contract the service provider would collect used bed sheets from the hospital, clean 
and  iron  them  (and,  if  considered  necessary,  repair  or  replace  them)  and  then 
deliver the cleaned bed sheets to the hospital. 

There is the possibility of combining some of these types of contracts, as in a laundry and 
maintenance contract, for instance. 

1.2.5 Proposal for a revised GPP textile scope 

Revision  of  the  scope  definition  for  the  EU  Ecolabel  for  textile  products  implies  the 
following modifications to the GPP scope definition: 

  The  inclusion  of  non-fibre  accessories:  Zips,  buttons  and  other  accessories  that 
are incorporated into the product were included in the EU Ecolabel scope. Whilst 
accessories are  of limited significance from a life cycle  perspective (see Section 
1.4) they should be included if they are of importance in relation to, for example, 
the repair of garments. 

  Specific  reference  to  membranes,  coatings  and  laminates:  These  may  be  of 
particular  importance  for  outdoor  garments.  Criteria  within  the  EU  Ecolabel  now 
address the environmental impacts of certain types of membranes. 

  Alignment of the weight threshold: The 90% weight threshold is proposed to be 
updated  to  80%  in  order  to  align  with  the  Textile  Names  Directive  (EU) 
1007/2011. 

The  scope  also  warrants  further  updating  to  introduce  a  specific  focus  on  GPP  textile 
applications. This would apply to items in (a) and (b) of the current GPP scope definition. In 
order to clearly indicate to specifiers and procurers of textiles within contracting authorities 
the relevance of the GPP criteria, it is proposed to introduce specific reference to products 
such as bed linen, towels, uniforms, work wear and Personal Protective Equipment (PPE). In 
relation to PPE, the Dutch work wear criteria specifically exclude PPE to which specific EU 
legislation applies – for example, high visibility garments. It is therefore proposed to include 
a  note  highlighting  that  performance  specifications  required  under  EU  or  national 
legislation shall take precedent.   

8 

 
 
The introduction of a new criteria area with a focus on textile services will  also require a 
specific scope definition. Based on the discussion in Section 1.1.4, it is proposed to include 
in  the  scope  the  rental  of  textiles,  maintenance,  laundry  services  and  end-of-life 
management.  It  is  also  proposed,  based  on  input  from  stakeholders,  to  note  that  such 
services  can  offer  life  cycle  cost  and  environmental  benefits  when  compared  to  outright 
purchase. 

Final scope definition 

GPP Criteria scope 

Textile products 

The criteria for textile products encompass the following products, which include finished products as 
well as intermediate products and accessories: 

 

 

 

Textile clothing and accessories: uniforms, workwear, personal protective equipment (PPE)2 
and accessories consisting of at least 80 % by weight of textile fibres in a woven, non-
woven or knitted form. 

Interior textiles: textile products for interior use consisting of at least 80 % by weight of 
textile fibres in a woven, non-woven or knitted form. This includes bed linen, towels, table 
linen and curtains. 

Textile fibres, yarn, fabric and knitted panels: intermediate products intended for use in 
textile clothing and accessories and interior textiles, including upholstery fabric and mattress 
ticking prior to the application of backings and treatments associated with the final product. 

  Non-fibre elements: intermediate products that are to be incorporated into textile clothing 
and accessories, and interior textiles. This includes zips, buttons and other accessories, as 
well as membranes, coatings and laminates that form part of the structure of clothing or 
interior textiles and which may also have a functional purpose. 

For the purposes of these criteria, textile fibres comprise natural fibres, synthetic fibres and man-
made cellulose fibres. The scope of textile fibres for which GPP criteria are provided is as follows: 

 

 

natural fibres: cotton and other natural cellulosic seed fibres, wool and other keratin fibres; 

synthetic fibres: polyamide and polyester; 

  man-made cellulose fibres: lyocell, modal and viscose. 

2 Performance requirements for PPE that are laid down in EU and/or national legislation take precedence over any 
GPP performance requirements.

9 

 
 
 
 
                                                        
 
Textile services 

Textile services are included within the scope as they can offer environmental life cycle cost benefits 
when  compared  with  outright  purchase.  Such  services  comprise,  as  a  basic  scope,  laundry, 
maintenance  and  take-back  services  for  textile  products  that  may  be  owned  by  the  contracting 
authority  or provided  as part  of  a  rental  arrangement. The  different  potential  elements  of  a  textile 
service for which environmental criteria are provided are defined as follows: 

 

Laundry:  the  collection,  cleaning  (using  a  wet  or  dry  process)  and  return  of  textiles  to 
specified standards of cleanliness and hygiene. 

  Maintenance: the maintenance and repair of textile products in order to extend their useful 
life span. This includes the replacement of accessories and parts, fabric panel replacement 
and the retreating/reproofing of functional coatings. 

 

Take-back:  the  collection  and  sorting  of  textile  products  in  order  to  maximise  their  reuse 
and/or  recycling.  The  procuring  authority  waives  ownership  of  any  textile  products  at  the 
moment of their collection. 

1.3 Market analysis 
A guide to socially responsible public purchasing published in 2007 by Eurocities and ICLEI 
highlighted the significant role of the public sector as purchasers of textiles and clothing, in 
particular  work  wear3.  It  has  been  estimated  that  a  quarter  of  the  workforce  may  be 
required to wear clothing provided by their employer4. Work wear was defined as including: 

o  Representative work wear (e.g. police uniforms) 

o  Functional work wear (e.g. for waste collection services) 

o  Protective clothing (e.g. for firemen) 

Protective  textiles  –  a  subset  of  work  wear  –  were  highlighted  by  the  EU  Lead  Market 
Initiative  (LMI)  as  a  key  area  for  industrial  innovation5.  Public  procurement  of  functional 
protective  clothing  for  fire-fighters,  emergency  services,  police  forces  and  the  military 
sector as well as for health care professionals in public hospitals was identified as a key 
market driver for innovation. 

Other  significant  areas  of  procurement  highlighted  by  best  practice  projects  include  bed 
linen and towels by health services and care facilities, interior textiles such as curtains and 
upholstery,  and  textiles  used  as  part  of  general  hygiene  services  for  buildings  –  such  as 
washroom handtowels6. 

An important factor to consider is that some public sector contracts are for textile services 
rather than textile products. Companies therefore tender to provide and maintain a supply 
of  functional  textiles  to  specification7.  The  contractor  may  then  be  responsible  for  the 
useful lifetime of the product and end-of-life management. 

Statistics  relating  to  the  EU  public  procurement  of  textiles  appear  to  be  limited  in  their 
availability.  For  example,  the  Eurostat  PRODCOM  database  does  not  distinguish  public 
sector purchases. A number of high level estimates have been quoted by EU initiatives. The 
EU  Lead  Market  Initiative (LMI)  estimated  that  public  markets  for the textile  and  clothing 

3 ICLEI and Eurocities (2007) RESPIRO guide on socially responsible procurement of textiles and clothing 
4 Centre for Remanufacturing and Re-use, An investigation to determine the feasibility of garment labelling to enable 
better end-of-life management of corporate clothing, March 2009 
5  DG  Enterprise  and  Trade,  Lead  Market 
innovation/lead-markets/index_en.htm 
6  ETSA  and  Euratex  (2006)  Handbook  of  textile  purchasing:  Success  stories  relating  to  textile  service, 
http://www.eco-forum.dk/textile-purchase/index_files/Page2479.htm 
7 European Textile Services Association, Healthcare & hospitals, http://www.etsa-europe.org/homefs.htm 

Initiative,  http://ec.europa.eu/enterprise/sectors/textiles/research-

10 

 
 
 
                                                        
industry may have a value in the order of 10 billion Euros/annum. Eurocities and ICLEI In 
2008 estimated that the total turnover of companies in the EU15 selling workwear was €4 
billion, approximately half of which was thought to be accounted for by public procurement. 

An  estimate  of  fabric  consumption  for  seven  EU  countries  -  Germany,  Belgium,  Spain, 
France, UK, Italy, Netherlands – between 1990-2000 is presented in Table 1. Although the 
survey results are very dated, they are understood to still be relevant as a broad indication 
of the types of fibres consumed.  The equivalent estimate for health services was 56,000 
tonnes  8,  making  a  comparison  difficult  because  the  assumption  made  for  the  standard 
width of cotton fabric was not noted by Promptex. 

It is important to note that a number of significant public services were not included within 
the survey, for example local authority employed personnel involved in the direct delivery 
of services such as municipal  waste management.  More recent 2005 survey data for the 
same countries9 is understood to be available but could not be located within the scope of 
this study. 

Table 1. Fabric consumption by major public services (average 1990-2000) 

Public service 

Wool and blends 
(Thousand of 
metres) 

Cotton and blends 

(Thousand of 
metres) 

Army 

4,590 

Fire brigades 

- 

Police 

Post Office 

Railway 

Total 

1,685 

1,696 

1,860 

9,831 

Source: Promptex (2005) 

15,699 

1,800 

501 

1,744 

2,180 

21,924 

Synthetic and 
man-made fibres 
excluding blends 
(thousands of 
metres) 

1,140 

935 

 -  

220 

103 

2,398 

The  authors  of  the  Promptex  survey  highlighted  cotton  and  wool  as  being  the  most 
significant fibres procured, with synthetics (excluding natural-synthetic blends) accounting 
for only 7% of the market 10. Blends such as poly-cotton and poly-viscose are understood, 
however, to be important because of their specific qualities e.g. to reduce laundering costs, 
enhanced fabric durability. Notably, the survey also highlighted that approximately half of 
the total procured value was awarded to manufacturers located outside of the EU. 

A  survey  by  Eurocoton  of hospital  textile  use is  also  referenced  by  Promptex  (2005).  The 
findings illustrate the nature of cotton textile use in this public service. The estimated total 
annual use of 56,000 tonnes can be broken down into the following end-uses: 

o  Bed linen, 23,000 tonnes 

o  Bathroom linen, 12,000 tonnes 

o  Clothing, 10,000 tonnes 

o  Other articles (medical devices), 11,000 tonnes 

Of the pure synthetic fabrics used in the public sector, nylon (polyamide) is understood to 
be  commonly  used  for  abrasion  resistant  functions.  Limited  information  appears  to  be 

8 Promptex, Euratex and ETUF-TCL (2005) Public procurement awarding guide for the clothing textile sector 
9  Just  Style,  Public  sector  procurement  in  Europe  obscured  by  price,  26th  January  2007,  http://www.just-
style.com/comment/public-sector-procurement-in-europe-skewed-by-price_id96279.aspx 
10 See footnote 9 

11 

 
 
 
                                                        
available  about  the  procurement  of  specialist  technical  fibres  such  as  aramids  (modified 
polyamides),  but  they  are  understood  to  be  used  by  the  military  and  the  police  in  anti-
ballistic clothing.  The global  market is estimated to be  74.5m tonnes in 2014  11 but data 
for the EU portion of the market could not be obtained. 

Textile  services  appear  to  be  a  growing  sector.  A  recent  study  from  2014  carried  out  by 
Deloitte  for  the  European  Textile  Services  Association  (ETSA)  estimated  the  size  of  the 
textile rental market based on a survey  of ETSA members  12. The study focussed  on four 
market  segments,  of  which  two  –  healthcare  and  Industry/Trade/Services  (ITS)  –  are  of 
particular  relevance  to  GPP.  Of  the  total  estimated  market  value  of  €10.5  –  €11.5bn  in 
2012  healthcare  was  estimated  to  account  for  around  23%  and  ITS  30%.  Across  the 
market  segments  studied,  flat  linen  (e.g.  bedding,  towels,  table  linen)  and  workwear  (e.g. 
industrial  and  presentational  garments)  accounted  for  around  75%  of  the  textile  rental 
market. 

1.4 GPP criteria currently in use by selected Member States 

1.4.1 Selected Member States studied for the European Commission (as of 2010) 

A report prepared in 2010 by AEA Technology for the European Commission provides some 
insight into how Member States are implementing GPP textile criteria 13. Product scope and 
the environmental aspects addressed by criteria sets were surveyed for ten Member States. 
The findings are summarised in Table 2. 

The findings highlight that whilst most of the Member States surveyed had general product 
definitions,  Denmark  and  the  Netherlands  had  developed  criteria  and  guidance  that  are 
more specific to GPP applications. Denmark had focussed on work wear, protective clothing, 
curtains  and  bed  linen.  The  Netherlands  had  developed  criteria  for  office  soft  furnishings 
and work wear. Germany and Finland did not at the time have specific criteria addressing 
textile products. 

Up-to-date links to Member State GPP initiatives can be found at the DG ENV Green Public 
Procurement website:  

http://ec.europa.eu/environment/gpp/material_en.htm 

11  PR  Newswire,  Aramid  fibres:  A  global  market  overview,  23rd  July  2014  http://www.prnewswire.com/news-
releases/aramid-fibers-para-and-meta---a-global-market-overview-268301472.html 
12 European Textile Services Association, Quantifying the opportunity:European market sizing study for ETSA, June 
2014 
13  AEA,  2010.  Assessment  and  Comparison  of  National  Green  and  Sustainable  Public  Procurement  Criteria  and 
Underlying Schemes, Report to the European Commission 

12 

 
 
 
 
 
                                                        
Table 2.  Scope and criteria coverage of ten selected Member State GPP criteria sets 

Member State  GPP documentation 

Environmental  
aspects addressed 

Austria 

Criteria document - Ecological criteria for textiles  Pesticides 

Belgium 

Textiles and ready to wear 
Criteria document - Clothing and accessories 

Denmark 

Textiles and ready to wear 
Criteria document - Leather products 

Guidance Document for Clothing and textiles 
Work overalls 
Work-wear 
Work-wear with protective properties 
Curtains 
Gloves 
Bed linen 

France 

Guide  to  sustainable  public  procurement  –  GEM 
DD - Buying Clothing 

Netherlands 

Criteria Document for Office soft furnishing 

Criteria Document for Work-wear 

Norway 

Criteria Document - Clothing and textiles 

Chemical content 
Organic fibres 
Recycled fibres 

Chemical content 
Organic fibres 
Recycled fibres 

Chemical content 

Chemical content 
EMS 
Organic fibres 
Risk assessment 
Wastewater treatment 
Recycling of fibres 

Waste 
Chemical content 
End of life 
Organic/fair trade cotton 

Chemical content 
Recycling 
Recycled fibres 

Chemical content 
Recycling 
Recycled fibres 
Organic fibres 

Chemical content 
Disposal 
Packaging 

Chemical content 

Sweden 

UK 

Furnishing  and  textiles  •  Criteria  Document  for 
Textiles and Leather 

Criteria Document - Textiles Standards (currently 
under revision) 

Pesticides 
Emissions 

Source: AEA Technology for the European Commission (2010) 

Whilst  commonalities  can  be  identified  between  the  criteria  sets,  variations  can  also  be 
seen in the extent of their coverage  – for example, in terms of restrictions on the use of 
certain hazardous substances product design, supply chain management and product end-
of-life management. 

Other criteria areas that could be identified from the AEA Technology report and which are 
not addressed by the current EU GPP criteria are summarised below in Table 3, organised 
under  common  headings.  Where  necessary  the  findings  of  the  AEA  Technology  report 
summarised  here  have  been  updated  to  reflect  recent  changes  to  national  GPP  criteria 
since that study was carried out, for example in the UK. 

13 

 
 
 
 
 
 
 
Table 3. Additional criteria areas identified from the ten selected Member State GPP criteria 

Criteria area 

Technical focus and/or references to other criteria 

Product-specific requirements 

-  CE  marking  for  work  gloves  and  protective  work  wear 

(Denmark). 

Supply chain management 

-  Biological wastewater treatment (Denmark); 

-  Tracking  and  documentation  of  supplier  energy,  water  and 

chemical consumption (Denmark); 

-  Traceability  requirements  for  each  factory  and  the  industrial 

equipment they use (France). 

Product 
specification 

design 

and 

-  Specification  of 

fabrics 

that 

require 

less 

retreatment 

(Denmark); 

End of life management 

-  Design,  cleaning  and  repair  of  workwear  to  extend  its  life 

(Netherlands); 

-  Requirement  for  LCA  evidence  to  support  the  selection/use  of 

novel new bioplastic and durable fibres (UK). 

-  Working  overalls,  workwear  and  bed  linen  should  be  recycled 
or  re-used,  with  award  criteria  used  to  incentivise  innovation 
(Denmark, France, Netherlands, UK); 

-  Careful end of life treatment of clothing containing hazardous 

chemicals e.g. flame retardants (Norway). 

Reference to Type I Eco-labels 

-  Verification  by  Nordic  Swan  (Belgium,  Denmark,  Norway, 

Sweden); 

-  Verification  by  Oeko-Tex  100  (Austria,  Belgium,  Denmark, 

Netherlands and Sweden); 

-  Verification by Oeko-Tex 1000 (Sweden). 

1.4.2  Member State GPP criteria not covered by the 2010 study 

A number of Member States which have adopted GPP textile criteria were not included in 
the 2010 AEA Technology survey.  In this section Italy and Spain are briefly reviewed.  The 
development of GPP criteria in these countries appears to reflect the continued significance 
of their textile industries. 

Despite its significant textile industry Italy was omitted from the 2010 survey . Whilst the 
majority  of  Italy's  GPP  criteria  reflect  those  of  the  EU  Ecolabel  and  EU  GPP  criteria  for 
Textile  products  there  are  some  distinct  differences14.  In  particular,  the  Award  criteria  for 
synthetic fibre recycled content and organic cotton content include minimum thresholds of 
30%  and  50%  respectively.  Moreover,  requirements  on  the  recyclability  and  recycled 
content of packaging are specified. 

A  number  of  the  autonomous  regions  of  Spain  which  retain  a  significant  textile  industry 
have also been active in developing and applying GPP criteria. For example, Pais Vasco has 
implemented workwear criteria15. The criteria are structured into three levels of ambition – 
basic,  advanced  and  excellent.  Novel  criteria  include  dye  restrictions  based  on  hazard 
classifications, the  use  of re-usable/returnable  packaging  and  award  criteria  linked  to the 
proportion of fibres that are compliant with the EU Ecolabel. 

14 Repubblica Italiana, 2011, Criteri ambientali minimi per l'acquisto di prodotti tessili, Supplemento ordinario n. 74 alla 
Gazzetta Ufficiale, 19th April. 
15 Gobierno Vasco, Textil ropa de trabajo, , http://www.ihobe.net (Accessed 2014) 

14 

 
 
 
 
 
 
 
                                                        
In  the  technical  discussion  of  the  criteria  areas  in  this  report  relevant  criteria  and 
procurement  experience  collected  from  existing  national  and  regional  GPP  criteria  is  also 
discussed. This includes criteria developed by regions (e.g. Western France; Catalonia, Spain) 
and municipalities (e.g. Nantes, Barcelona, Vienna).   

1.5 The key environmental impacts of textiles 

The preliminary report for revision of the EU Ecolabel textile criteria16 presented a review of 
Life Cycle Assessment (LCA) studies of textile products. The main reference for the overall 
findings was the IMPRO Textile LCA study carried by the Joint Research Centre17. The overall 
LCA results for EU  textile consumption are presented in Figure 1, noting that they are an 
aggregation  of  the  impacts  from  the  full  range  of  textile  products  and  fibre  blends 
consumed by the EU market. The following can be discerned from the results: 

  That  for  some  environmental  indicators  such  as  agricultural  land  use,  terrestrial 
ecotoxicity  and  eutrophication,  the  production  of  textile  fibres  can  be  the  most 
significant phase. 

  For  other  environmental  indicators  such  as  freshwater  ecotoxicity,  marine 
ecotoxicity and water depletion, the use phase can be the most significant phase in 
the life cycle of a textile product. 

 

In some cases the contribution of production and use to environmental impacts is 
evenly  balanced,  for  example  in  the  case  of  climate  change  and  linked  impacts 
such as terrestrial acidification and particulate matter formation. 

These  results  will  be  subject  to  sensitivity  depending  on  the  fibre  blends  used  to  make  a 
fabric, the finishes applied, how the textiles are washed, dried and ironed during their use 
and the lifespan of the textiles. 

16 Dodd.N, Cordella.M, Waidtløw.J, Stibolt.M, Hansen.E, 2012, Revision of the European Ecolabel and Green Public 
Procurement Criteria for Textile Products: Preliminary report, Joint Research Centre (IPTS), European Commission. 
17 Beton.A, Dias.D, Farrant.L, Gibon.T, Le Guern.Y, Desaxce.M, Perwueltz.A, Boufateh.I, editors  
Wolf.O, Kougoulis.J, Cordella.M, Dodd.N, 2013, Environmental Improvement Potential of textiles (IMPRO Textiles), 
Joint Research Centre (IPTS), European Commission 

15 

 
 
 
 
 
                                                        
Figure  1.  Impacts  of  textile  consumption  in  the  EU27  according  to  life  cycle  phase  and 
midpoint indicator 

Source: JRC-IPTS and BIO Intelligence (2013) 

Further to the overall findings for EU textile consumption, the following environmental ‘hot 
spots’ were identified as being of significance by JRC-IPTS's preliminary report 18: 

  Cotton  production:  The  ecotoxicity  associated  with  the  production  and  use  of 
fertilisers  and  pesticides  is  the  main  contributor  to  both  energy  consumption  and 
ecotoxicity. The resource impact of water use for irrigation was also highlighted as 
being significant. 

  Synthetic  fibre  production  (acrylic,  nylon,  polyamide,  polypropylene):  The  climate 
change  and  ecotoxicity  impact  of  energy  and  raw  materials  used  to  manufacture 
the fibres are of high significance. Nylon and acrylic are the most energy intensive 
fibres  to  produce  and  are  technically  the  most  difficult  to  recycle.  The  LCA  case 
studies  reviewed  highlighted  how  the  energy  required  to  produce  garments  is,  to 
some extent, influenced by fibre blends. 

  Man-made cellulose fibres (viscose): The climate change and ecotoxicity impact of 
energy use to manufacture the fibres are of high significance. The LCA case studies 
reviewed highlighted viscose, which was used as the reference fibre, as being the 
most energy intensive fibre to produce. 

  Raw  material  and  feedstocks  required  to  manufacture  cellulose  fibre,  soaping 
agents  and  softeners:  Timber  and  bamboo  are  the  predominant  sources  of  raw 
material  for  cellulose  fibre  manufacturing.  Viscose  appeared  to  have  significantly 
higher impacts associated with soaping agent and softener use. 

  Process  energy  and  ecotoxicity  associated  with  the fabric  formation, finishing  and 
printing  and  dyeing  stages  of  production:  There  was  conflicting  evidence  in  this 
area, with another LCA study reaching the conclusion that the effect on ecotoxicity 
from  the  production  phase  for  traditional  cotton  was  less  significant  overall.  The 
scouring stage was highlighted in relation to wool. Dye carriers were highlighted in 
relation to polyester. 

  Energy  and  ecotoxicity  associated  with  the  use  phase  of  textile  products:  These 
impacts related primarily to washing energy and detergents, and can be influenced 
by fibre choice and blends. Comparative studies of industrial and domestic washing 
and drying were also identified, with more efficient industrial laundries having the 
potential to reduce use phase impacts. 

The report also highlighted the potential benefits of more sustainable systems of resource 
use  associated  with  the  disposal  (end-of-life)  phase.  Environmental  benefits  can  be 
allocated as a result of re-use, recycling and energy recovery activities. 

A  number  of  environmental  issues  addressed  by  the  EU  Ecolabel  criteria  were  not 
specifically  highlighted  by  the  LCA  findings  as  being  significant  overall.  These  included 
flame retardants, dyes and plasticizers. There may be a number of reasons for this: 

  An  incomplete  Bill  of  Materials  (e.g.  missing  inventory  of  materials  containing 

hazardous substances) in the LCA analysis; 

  The products analysed were already representative of the best on the market, with 
their  production  already  including  improvement  options  and  hazardous  substance 
substitution; 

18 ibid 16 

16 

 
 
                                                        
  The cut-off limit for substances used in the LCA was set too high, hence hazardous 
substances that are present at lower concentrations will not have been captured by 
the impact assessment. 

Evidence  suggests,  however,  that  a  precautionary  approach  is  justified  for  some  specific 
chemicals where LCA does not currently provide a full picture of their impacts. This will be 
explored  in  later  sections  of  this  report  in  the  criteria  area  addressing  hazardous 
substances. 

The EU Product Environmental Footprint Category Rules (PEFCR) pilot screening report for t-
shirt products also identifies hot spots along the life cycle of a textile product 19.   The pilot 
analysed the life cycle of a consumer t-shirt made of 77% cotton and 16% polyester, with 
the  balance  made  up  of  other  common  fibres.  The  life  cycle  stages  and  associated 
processes  cumulatively  contributing  at  least  50%  to  any  impact  category  before 
normalisation and weighting were identified as being:  

  Raw materials production (in particular the production of cotton fibres);  

  T-shirt production (in particular dyeing and transport between production sites); 

  The use phase (in particular washing and ironing). 

A  sensitivity  analysis  was  used  to  identify  the  environmental  hotspots  along  the  supply 
chain  for  different  types  of  fibres.  The  results  were  also  sensitive  to  the  weight  and 
composition of the t-shirt. For a workwear t-shirt assumptions relating to the use phase are 
likely to vary because industrial laundries may be used.  The weight and fibre composition 
of the product could also vary in order to meet different functional specifications.     

The  findings  from  this  Section  have  been  used  to  propose  revisions  to  the  key  life  cycle 
environmental  impacts  that  will  be  addressed  by  the  criteria  and  the  proposed  GPP 
approach. The proposed revised text is presented in Figure 2. 

19 Product Environmental Footprint (PEF) Category Rules (PEFCR) Pilot - T-shirts, October 2015 

17 

 
 
 
 
                                                        
Key life cycle environmental impacts: 

  Hazardous  effects  on  the  aquatic  environment  due  to  the  use  of  hazardous  fertilisers 

and pesticides during the cultivation of natural fibres. 

  Hazardous  effects  on  the  aquatic  environment  due  to  substances  used  during  the 

processing of intermediate and final textile products. 

  The  use  of  biotic  and  abiotic  resources  from  forestry,  petroleum  and  natural  gas  to 

manufacture fertilisers and fibres. 

  Greenhouse  gas  emissions,  acidification  and  smog  resulting  from  the  production  and 
use of electricity and natural gas used to manufacture synthetic fibres and to wash, dry 
and iron textiles. 

  Early  product  failure  which  can  result  in  the  consequent  waste  of  biotic  and  abiotic 
resources, and their landfilling or burning with potential for hazardous emissions to air 
and water. 

EU GPP Textiles approach 

  Purchase  textiles  made  from  fibres  which  are  produced  using  fewer  fertilisers, 

hazardous pesticides and production chemicals. 

  Purchase textiles that contain recycled materials and fibres. 

  Purchase  textiles  with  a  reduced  use  of  environmentally  harmful  and  hazardous 

substances in their production. 

  Purchase textiles that require less energy for drying and ironing. 

  Purchase  colour-fast  fabrics  that  do  not  shrink  during  use,  that  are  constructed  to  be 

more durable in use and which have longer-lasting functional coatings. 

  Contract services that minimise the energy used to wash, dry and iron textiles. 

  Contract services that maintain textiles in order to extend their lifetime. 

  Contract services that reuse maximise the potential for reuse and recycling of textiles at 

the end of their service life. 

Figure 2. Key environmental areas and impacts in a textile products' life cycle and the GPP 
Textiles approach 

18 

 
 
 
 
 
 
 
2. GPP CRITERIA PROPOSALS 
It is proposed to split the criteria proposals into two broad areas. The first area addresses 
textile  products  directly  procured  by  a  contracting  authority.  In  these  criteria  the  subject 
matter is therefore the textile product. The criteria proposals are based as far as possible 
on  the  EU  Ecolabel  for  textile  products,  with  the  ambition  level  and  type  of  GPP  criteria 
selected to reflect the ease of compliance and verification, as well as market conditions.   

The second area addresses services which may be procured, including the rental of textiles, 
asset management, laundry and end-of-life take back. In these criteria the subject matter 
is therefore the nature of the service provided.  These criteria are mostly beyond the scope 
of the EU Ecolabel for textile products, and so are based on additional research.  

2.1 Textile product related criteria 
It is proposed that this group of criteria focuses exclusively on the textile product, whether 
it  is  an  item  of  workwear  or  an  interior  textile  such  as  curtains  or  bed  linen.  The  subject 
matter for the procurement of textile products is proposed to be: 'purchase of textiles with 
a reduced environmental impact'. 

2.1.1 Selection criteria for tenderers 

From  the  background  research  in  support  of  revision  of  both  the  EU  Ecolabel  and  GPP 
criteria  two  broad  areas  of  focus  for  environmental  improvement  can  be  identified  and 
related to the subject matter and criteria areas: 

  Textile fibre origin: Designers and manufacturers of textile products are increasingly 
focussing on the sourcing and origin of the fibres from which the product is made.  
As  we  have  already  identified  this  can  range  from  agriculture  and  forestry  (e.g. 
cotton,  viscose)  to  the  chemical  industry  (e.g.  polyester,  nylon).    In  both  cases 
traceability  systems  for  tracking  and  verifying  the  origin  of  the  fibres  have  to  be 
operated. 

  Chemical  use:  In  order  to  implement  restrictions  on  the  use  of  chemicals  in 
manufacturing a textile product their use needs to be traced to different production 
stages and, ultimately, production sites. The degree of confidence that restrictions 
are  being  implemented  will  depend  to  a  great  extent  on  the  level  of  control  over 
their  supply  chain.    Manufacturers  may  exercise  or  being  able  to  demonstrate 
different  levels  of  control  over  their  supply  chain,  ranging  from  direct  control  of 
their  own  production  sites  to  the  outsourcing  of  production  stages  via 
intermediates.   

It is therefore proposed that these two areas of progress by manufacturers are reflected in 
the  Selection  Criteria,  together  with  an  additional  request  for  relevant  examples  of  how 
these  aspects  have  been  managed  on  previous  contracts.  Given  that  these  capabilities 
might tend to reflect those of the leading manufacturers in the market, it is proposed that 
the Selection Criteria are used as a comprehensive level of ambition.  

19 

 
 
 
 
 
 
 
 
 
Final criterion  

Core criteria 

SC1. SELECTION CRITERIA 

Comprehensive criteria 

Tenderers  must  be  able  to  demonstrate  the 
resources,  expertise,  documented  procedures  and 
management  systems  they  have  in  place  to 
address the following aspects of the product and 
its supply chain:  

Textile  fibre  origin:  systems  that  allow  for  the 
traceability of the source, content and production 
systems  of  natural  and  man-made  fibres  for 
which  environmental  criteria  will  apply.  This 
includes 
that  allow  for 
verification and traceability from the origin of the 
raw  material  or  feedstock  to  manufacturing  and 
processing  of  yarn  and  greige  fabric.    This  may 
include  the  use  of  third  party  certifications  of 
origin and traceability. 

transaction 

records 

list, 

Chemical  management:  the  implementation  of  a 
restricted  chemical  substance 
including 
communication  of  the  list  to  dyeing,  printing  and 
finishing  sites,  monitoring  of  the  compliance  of 
production sites (as relevant to criteria P3. 2) and 
monitoring of the compliance of final products (as 
relevant  to  criteria  P3.  1),  including  laboratory 
testing.  The  use  of  auditors  for  site  visits,  textile 
compliance schemes and laboratories for product 
testing 
international 
standards (e.g. ISO 17025, ISO 17065, ISO 19011 
or equivalent) will also be required. 

that  are  accredited 

to 

Verification: 

textile 

Tenderers  must  describe 
the  systems  and 
capabilities that they have in place to monitor and 
chemical 
verify 
management.  Moreover,  they  will  describe  the 
systems  of  documentation,  auditing  and  analysis 
used  to  monitor  compliance  of  suppliers  and  the 
final product. 

origin 

fibre 

and 

The resourcing and expertise that  will be used to 
manage compliance must be confirmed. Relevant 
examples  must  be  provided  from  previous 
contracts  to  supply  textile  products  showing  how 
these  two  aspects  have  been  managed  and 
verified. 

20 

 
 
 
 
 
 
2.1.2 Fibre sourcing 

2.1.2.1 Cotton fibres 

Technical background to the criteria proposal 

Cotton  was  identified  by  JRC-IPTS's  IMPRO  Textiles  study  as  the  textile  fibre  associated 
with the most significant environmental  impacts20 –  both in  absolute  terms  based on  the 
quantity  consumed  in  the  EU  and  in  terms  of  the  nature  of  the  environmental  impacts 
associated with its cultivation as a global commodity crop. 

Cotton cultivation requires approximately 2.5% of the world's cultivated land yet uses 16% 
of  the  world's  total  use  of  pesticides,  accounting  for  more  than  any  other  single  major 
crop21.  The  major  environmental  impacts  are  associated  with  the  manufacturing  of 
fertilisers and pesticides, pollutant loading of water courses by the run-off from the land of 
fertilisers  and  pesticides,  land  degradation  from  intensive  cultivation  and  water  use  for 
irrigation22. 

Globally two major improvement options for reducing the environmental impacts of cotton 
production can be identified: 

Integrated  farming:  IPM  (Integrated  Pest  Management)  and  the  broader  approach 
known as Integrated Crop Management (ICM), which incorporates IPM, are a means 
of  improving  the  cotton  yield  whilst  improving  land  management  and  reducing 
exposure of humans and the environment to hazardous pesticides. 

   Organic  farming:  As  defined  by  organic  production  Regulation  834/200723  is  a 

system that avoids the use of industrial fertilisers and pesticides. 

These two systems are, since 2014, options for applicants for the EU Ecolabel. An overview 
of data on the global availability of certified cotton from these two forms of production is 
provided in Table 4.  The table shows that certified cotton grown according to IPM principles 
accounts  for  a  greater  market  share  than  certified  organic  production.  It  is  to  be  noted, 
however,  that  these  estimates  do  not  include  uncertified  IPM  and  organic  cotton,  for 
example from the USA, Pakistan, Egypt and Turkey. 

In the case of IPM it has been estimated that this form of production may account for more 
than 19% of global cotton production. However, the proportion that is certified is increasing 
rapidly,  with  the  Better  Cotton  Initiative  (BCI)  being  the  fastest  growing  scheme  in  the 
market. 

As  can  be  seen  from  Error!  Not  a  valid  bookmark  self-reference.  certified  cotton 
grown  according  to  IPM  principles  accounts  for  a  greater  market  share  than  certified 
organic  production.  It  is  to  be  noted,  however,  that  these  estimates  do  not  include 
uncertified IPM and organic cotton, for example from the USA, Pakistan, Egypt and Turkey. 

In the case of IPM it has been estimated that this form of production may account for more 
than 19% of global cotton production. However, the proportion that is certified is increasing 
rapidly,  with  the  Better  Cotton  Initiative  (BCI)  being  the  fastest  growing  scheme  in  the 
market. 

Table 4. Estimates of Organic and IPM cotton production and market share for 2013 

20 See footnote 17 
21  Environmental  Justice  Foundation  (2007).  The  deadly  chemicals  in  cotton.  Environmental  Justice  Foundation  in 
collaboration with Pesticide Action Network UK: London, UK. ISBN No. 1-904523-10-2 
22 Kooistra.K.J, Mancini.F and A.J.Termorshuizen, Environmental Impact Assessment of Cotton Cultivation in Central 
India in Mancini.F, Impact of Integrated Pest Management Farmer Field Schools on health, farming systems, the 
environment, and livelihoods of cotton growers in Southern India (2006) Biological Farming Systems 
Group, Wageningen University, The Netherlands. 
23  European  Parliament  and  the  Council  of  the  European  Union,  Council  Regulation  (EC)  No  834/2007of  28  June 
2007 on organic production and labelling of organic products and repealing Regulation (EEC) No 2092/91 

21 

 
 
  
                                                        
Production system 

Fibre  production 
(Tonnes) 

Share  of  world 
production  

Estimated  Share 
of EU market 

Global cotton production 

26,800,000 

100% 

Certified organic production 

109,676 1 

0.4% 

Certified IPM production 
1. BMP (Australia) 
2. Better Cotton Initiative 
3. Cotton Made in Africa 
4. Fair Trade 

11,2522 
820,000 
85,000 
17,7803 

Total certified IPM production 

934,032 

Notes: 

0.04% 
3.1% 
0.3% 
0.07% 

3.5% 

- 

1.3% 

0.1% 
10.0% 
1.0% 
0.2% 

11.4% 

1.  Estimated based on a 21% decline in production in 2013 according to the Textile Exchange. 
2.  The  quantity  of  uncertified BMP cotton  is considerably  greater,  having been  estimated  at  60%  of  Australia's total 
production, which was 885,960 tonnes in 2013.  With BMP joining the Better Cotton Initiative in 2014 the quantity 
of certified BMP cotton is anticipated to grow significantly. 

3.  Estimated based on a 3% decline in production in 2013 according to Fair Trade. 

Source: Textile Exchange (2014), Better Cotton Initiative (2014), Cotton Made in Africa (2014) 

For uncertified organic production there is limited data on what the latent potential may be. 
Organic cotton is understood to be produced by overseas aid and NGO funded projects in 
countries  including  Tanzania,  Benin,  Colombia  and  Kyrgyzstan.  However,  the  barriers  to 
obtaining  certification  and  lack  of  market  signals  are  cited  as  preventing  this  cotton 
meeting  formal  criteria24.  Sponsors  and  investors  in  such  projects  include  organisations 
such as Helvetas and Biosustain. Taking the latter as an example, production has reached 
8,000 tonnes/year of cotton lint for processing  25.  Public procurement could play a role in 
bringing  this  cotton  into  the  market  by  providing  certainty  of  demand,  particularly  given 
that  a  number  of  large  multinational  high  street  clothes  retailers  are  cited  as  being 
reluctant to use cotton from specific sources. 

The  comparative  benefits  of  the  two  systems  and  the  forms  of  verification  that  can  be 
used are briefly summarised in the next two sections: 

Organic cotton production systems 

Organic cotton is often cited as the most environmentally preferable form of cotton. This is 
because  the  requirements  for  certification  set  strict  rules  restricting  the  use  of 
agrochemicals  such  as  industrial  pesticides  and  fertilisers.    For  example,  Article  12  of 
Regulation (EC) No 834/2007 (the 'Organic Regulation') states that: 

'the prevention of damage caused by pests, diseases and weeds shall rely primarily 
on  the  protection  by  natural  enemies,  the  choice  of  species  and  varieties,  crop 
rotation, cultivation techniques and thermal processes;' 

LCA studies comparing organic and conventional cotton production illustrate the significant 
potential  for  improvement  across  a  number  of  impact  categories  of  relevance  to  cotton 
production, including Global Warming Potential, acidification and eutrophication 26, 27. 

24 Personal communication with Jens Soth, Helvetas (2015) 
25 Solidaridad, Improving productivity and marketing of cotton through strengthening selected producer organisations 
in Eastern Africa, Project final report – period December 2011 to December 2013. 
26 ibid 22 

22 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
Wageningen University made  a comparison of conventional,  organic and IPM cotton. They 
concluded that while organic cotton production has significant benefits in terms of reducing 
harmful pesticide use, the differences between conventional, IPM and organic methods may 
not  be  as  clear  on  the  ground  because  significant  impacts  can  still  arise  from  land 
clearance, 'natural' pesticide use and, depending on the location, unsustainable water use. 
In  some  developing  countries  it  should  also  be  noted  that  the  cost  of  agrochemicals  is 
prohibitive to the extent of some farmers using little or no pesticides 28. 

Production  of  organic  cotton  has  expanded  rapidly  over  the  last  decade  as  a  result  of 
demand  created  by  large  multinational  high  street  clothes  retailers  ,  specialist  national 
retailers,  specialist  organic  mail  order  retailers  and  niche  US  brands  with  an  EU  market 
presence. However, with a slump in global cotton prices, production has fallen again. Data 
for  2012  compiled  by  the  Textile  Exchange  and  presented  in  Figure  2  highlights  a  dip  in 
production to less than 1.0% of global cotton production29. This is despite publicly reported 
increases  in  demand  from  leading  retailers,  highlighting  potential  problems  with  data 
collection  and  systems  of  traceability.    Data  from  2014  suggests  there  was  a  further 
decline during the period 2012-2014 to 116,794 mt 30.  

Figure 2. Global certified organic cotton production trend 2004-2012. 
Source: Textile Exchange (2013) 

Organic cotton production is generally certified by national control bodies recognised by the 
EU  or  the  USA  or  by  the  independent  body  IFOAM.  The  status  of  these  certifiers  as  EU 
organic  control  bodies  may  be  problematic  because  cotton  is  not  formally  covered  by 
Europe’s organic production Regulation 834/2007, although it is understood that in many 
cases they tend to already be recognised because they certify other products. A number of 
private certification schemes also exist that provide traceability systems to support organic 
content claims.  

27 PE International, Life Cycle Assessment (LCA) of organic cotton: A global average, Textile Exchange, November 
2014 
28  Kooistra.K  and  A.Termorshuizen,  The  sustainability  of  cotton  -  Consequences  for  man  and  environment, 
Wageningen University, Report 223, April 2003. 
29  Textile Exchange (2013) Organic farm and fibre report 2011-12 
30 Textile Exchange (2014) Organic farm and fibre report 2013-14, Press release 

23 

 
 
 
 
                                                                                                                                                               
Feedback  from  public  procurement  exercises  in  France,  Spain  and  Austria,  as  well  as 
industry  stakeholders,  suggests  that  prices  can  vary  considerably  in  comparison  to 
conventional cotton. Variations of between 10% and 100% are reported. Where specified it 
has tended to be as an award criterion in order to gauge the market's response and ensure 
that  there  are  enough  bidders.  To  take  one  example,  a  procurement  exercise  in  France 
which required organic cotton as a technical specification resulted in only two tenders, with 
the cheapest tender incurring a price premium of +22%. 

IPM cotton production systems 

IPM, sometimes also referred to in conjunction with ICM (Integrated Crop Management), is a 
system  of  cultivation  that  is  intended  to  minimise  the  application  of  pesticides  by  the 
careful observation and management of crops. The UN FAO defines IPM as: 

A site-specific strategy  for managing insect, weed, disease  and other pests in the 
most cost effective, environmentally sound and socially acceptable way 

The training of farmers to apply IPM techniques is a critical factor in their success. FAO has 
promoted  Farmer  Field  Schools  in  Asia  and  Africa.  In  the  USA  and  Australia  both 
Government  and  industry-led  programmes  are  understood  to  have  achieved  over  70% 
coverage. 

Monitoring evidence from FAO programmes suggests that IPM cotton can reduce pesticide 
use  by  between  30%  and  90%  whilst  also  being  associated  with  the  highest  yield  for 
cotton crops, with increases of between +11% and +47% in comparison with conventional 
cultivation,  and  the  lowest  proportional  impacts  associated  with  fertiliser  use  (whether 
artificial  or  organic).  Overall  it  has  been  reported  that  IPM  production  can  achieve  on 
average  the  highest  yields  for  cotton  crops,  with  conventional  growing  intermediate  and 
organic presenting the lowest yields 31. 

Whilst  the  level  of  environmental  improvement  associated  with  IPM  cannot  therefore  be 
specified  or  guaranteed  once  a  farmer  has  been  trained,  the  evidence  suggests  that 
improvements within these ranges, both in terms of reductions in agrochemical use and in 
terms of improvements in yield, could be expected in the majority of cases. 

A  definition  of  IPM  has  also  been  developed  by  the  European  Commission32  and  forms  a 
key part of the European Union’s agricultural  policy, with Member States now required to 
take all necessary measures to introduce low-pesticide input pest management.  Although 
this is understood to have led to improved EU cotton production, with producers in Greece 
and  Spain  adopting  IPM  and  ICM  practices  33,  this  only  represents  only  a  very  small 
proportion of global production.. IPM was initially defined by Directive 91/414/EEC as:  

The  rational  application  of  a  combination  of  biological,  biotechnical,  chemical, 
cultural or plant-breeding measures, whereby the use of plant protection products is 
limited  to  the  strict minimum  necessary  to maintain  the  pest  population  at levels 
below those causing economically unacceptable damage or loss”. 

Directive 91/414/EEC encouraged Member States to take the principles of IPM into account. 
In  2006,  the  EU  authorities  published  a  “Thematic  Strategy  on  the  Sustainable  Use  of 
Pesticides”  and  this  was  followed  up by Directive  2009/128/EC  Establishing a  community 

31 Kooistra K,J , Mancini F and A,J. Termorshuizen, Environmental impact assessment of cotton cultivation in India, 
p-53-68 in Mancini,F (2006) Impact of IPM Farmer Field Schools on the environment, health and livelihoods of cotton 
growers in Southern India, Wageningan University, The Netherlands 
32 European Commission, Development of guidance for establishing IPM principles, BIPRO, 24th April 2009 
33  EuropaBio,  Baseline  information  on  agricultural  practices  in  the  EU:  Cotton  (Gossypium  hirsutum  L.), 
http://www.europabio.org/sites/default/files/120526_report_eu_farming_practices_cotton.pdf 

24 

 
 
                                                        
framework  to  achieve  the  sustainable  use  of  pesticides34.  The  Directive  introduced  a 
definition of the principles of IPM (see Box 2).  

Box 2. General principles of IPM as defined by Annex III of Directive 2009/128/EC 

The prevention and/or suppression of harmful organisms should be achieved or supported 
among other options especially by: 

  crop rotation; 
  use of adequate cultivation techniques (e.g. stale seedbed technique, sowing dates 

and densities, under-sowing, conservation tillage, pruning and direct sowing); 

  use,  where  appropriate,  of  resistant/tolerant  cultivars  and  standard/certified  seed 

and planting material; 

  use of balanced fertilisation, liming and irrigation/drainage practices; 
  preventing  the  spreading  of  harmful  organisms  by  hygiene  measures  (e.g.  by 

regular cleansing of machinery and equipment); 

  protection  and  enhancement  of  important  beneficial  organisms,  e.g.  by  adequate 
plant protection measures or the utilisation of ecological infrastructures inside and 
outside production sites. 

Harmful  organisms  must  be  monitored  by  adequate  methods  and  tools,  where  available. 
Such adequate tools should include observations in the field as well as scientifically sound 
warning,  forecasting  and  early  diagnosis  systems,  where  feasible,  as  well  as  the  use  of 
advice from professionally qualified advisors. 

Based  on  the  results  of  the  monitoring  the  professional  user  has  to  decide  whether  and 
when to apply plant protection measures. Robust and scientifically sound threshold values 
are  essential  components  for  decision  making.  For  harmful  organisms  threshold  levels 
defined for the region, specific areas, crops and particular climatic conditions must be taken 
into account before treatments, where feasible. 

Sustainable  biological,  physical  and  other  non-chemical  methods  must  be  preferred  to 
chemical methods if they provide satisfactory pest control. 

The  pesticides  applied  shall  be  as  specific  as  possible  for  the  target  and  shall  have  the 
least side effects on human health, non-target organisms and the environment. 

The professional user should keep the use of pesticides and other forms of intervention to 
levels  that  are  necessary,  e.g.  by  reduced  doses,  reduced  application  frequency  or  partial 
applications, considering that the level of risk in vegetation is acceptable and they do not 
increase the risk for development of resistance in populations of harmful organisms. 

Where  the  risk  of  resistance  against  a  plant  protection  measure  is  known  and  where  the 
level  of  harmful  organisms  requires  repeated  application  of  pesticides  to  the  crops, 
available anti-resistance strategies should be applied to maintain the effectiveness of the 
products. This may include the use of multiple pesticides with different modes of action. 

Based on the records on the use of pesticides and on the monitoring of harmful organisms 
the professional user should check the success of the applied plant protection measures. 

The principles of IPM and the learning from educational programmes worldwide promoted 
by  the  FAO  now  form  the  basis  for  a  number  of  cotton  IPM  certification  schemes.  These 
schemes  aim  to  bring  low-pesticide  input  cotton  to  the  textile  market  and  allow  for 
traceability from the farm. As was highlighted in table 4 the most significant certification 

34 European Parliament and the Council of the European Union, Directive 2009/128/EC of 21 October 2009 
establishing a framework for Community action to achieve the sustainable use of pesticides, 24th November 2009 

25 

 
 
 
                                                        
schemes are the  Better Cotton Initiative35, Cotton Made in Africa36 , Fair Trade37 and BMP 
(Australia)38. BMP will, from 2014, form part of the Better Cotton Initiative. These schemes 
tend to combine IPM principles which the farmers must follow with restrictions on the use 
of hazardous pesticides. The EU has also recently launched the SPRING initiative to develop 
a scheme for Pakistan in conjunction with WWF-Pakistan. 

The availability of certified cotton via these schemes is increasingly rapidly in response to 
demand from large retailers and clothing manufacturers, with some evidence of a shift in 
focus from organic to IPM cotton.  These certifications include traceability either based on 
the cotton bales or bulk purchasing and resale by a 'demand alliance' to its members. 

Feedback  from  public  procurement  exercises  in  France  and  Spain  suggests  that  IPM  has 
only  been  specified  in  the  form  of  the  'Fair  Trade'  certification  –  suggesting  that  social 
criteria  rather  than  IPM  were  the  main  consideration.  Their  experience,  together  with 
feedback from industry stakeholders, suggests a price premium over 'conventional' cotton 
of between +5% and +40%. 

Genetically Modified cotton 

Genetic modification (GM) is an issue of particular relevance to cotton because GM varieties 
are now commonly used to improve yield worldwide. EU policy does not specifically prohibit 
GM  production.  The  use  of  specific  GM  plant  breeds  in  the  EU  is,  instead,  subject  to  an 
authorisation  process  and  to  date  the  cultivation  of  GM  varieties  of  cotton  has  not  been 
authorised within EU territory.  

Given  that  EU  cotton  production  amounted  to  300,000  tonnes  in  2013,  the  majority  of 
cotton  likely  to  be  used  to  fulfill  public  contracts  can  be  expected  to  be  imported  from 
outside of the EU. Data for worldwide cotton production shows that the proportion of the 
area under cultivation that is planted with GMO  cotton varieties ranges from 40% (Brazil) 
to 99.5% (Australia), with approximately 81% of global production estimated to be based 
on GMO varieties39. 

Of the IPM schemes reviewed only Fair Trade and Cotton Made in Africa restrict GM cotton. 
These two schemes supply significantly less volume into the market than BCI and BMP. The 
combined  global  market  share  of  Fair  Trade  and  Cotton  Made  in  Africa  in  2012  is 
estimated  to  be  0.4%  which,  assuming  a  higher  proportion  of  IPM  consumption,  may  be 
1.2% in the EU. On this basis it can be seen that a GM cotton restriction would be likely to 
constrain a public authority's access to IPM cotton. 

Organic cotton is a different case in point. The EU Organic Regulation (EC) 834/2007 states 
that: 

’Genetically  modified  organisms  (GMOs)  and  products  produced  from  or  by  GMOs 
are incompatible with the concept of organic production and consumers' perception 
of organic products. They should therefore not be used in organic farming or in the 
processing of organic products.’ 

During revision of the EU Ecolabel  and for sake of consistency with the principles used in 
the Organic Regulation the cotton criteria was revised to reflect the Organic Regulation (EC) 
834/2007 by stating that where conventional and/or IPM cotton are combined or blended 
with  organic  cotton  that  this  cotton  shall  not  be  genetically  modified.  A  corresponding 

35 Better Cotton Initiative, Production principles and criteria v2.0, December 2009 
36 Aid by Trade Foundation, Cotton Made in Africa - Criteria matrix Version 2.0, January 2011 
37 Fairtrade International, Fair trade standard for small producer organisations, Version 1.1, May 2011 
38 CRC (2005) Integrated pesticide management guidelines for cotton production systems in Australia,  
39 International Service for the Acquisition of Agri-Biotech Applications, http://www.isaaa.org/default.asp 

26 

 
 
                                                        
clause was therefore also added to the assessment and verification referring to Regulation 
(EC) No 1830/2003 on the traceability and labelling of GMOs in food and feed products40. 

In  the  discussions  on  the  EU  Ecolabel  criteria,  a  concern  was  raised  by  EU  Ecolabel 
Competent Bodies and applicants about the availability of non-GM cotton and the ability to 
verify  it.  Consultation  with  the  Bremen  Cotton  Exchange  41,  who  are  an  important  EU 
clearing  house  for  the  trade  of  cotton  on  the  world  market,  has  confirmed that  although 
there  are  still  countries  which  do  not  use  GM  cotton,  their  number  is  decreasing  due  the 
economic advantages of increased yields and reduced chemical use. 

Based  on  current  evidence,  three  possible  routes  can  be  identified  to  obtain  non-GM 
conventional cotton on the world market: 

  EU producers: The growing of GM cotton fibre is not currently licensed in the EU. 

Cotton is mainly grown in Greece and Spain, although production is limited (quoted 
at 300,000 tonnes in 2011/12, 1% of global production); 

  Non-EU producers: In small number of countries GM cotton is not permitted and is 
strictly controlled. This includes Turkey (2.8% of global production in 2013) and 
certain countries in central Asia (specifically Uzbekistan and Turkmenistan – 
estimated at 4.5% global production in 2011/12); 

  Certified non-GM cotton: Bilateral purchase of cotton grown under the Fair Trade or 
Cotton Made in Africa certification schemes.  These schemes specifically restrict the 
use of GM varieties but availability is currently very limited, as illustrated in Table 4. 
With regards to verification of the non-GM origin of the cotton, this can be obtained in the 
EU Ecolabel by carrying out a PCR (Polymerase Chain Reaction) screening test for the most 
common  genetic  modifications.    This  test  shall  be  carried  out  on  raw  cotton  before  wet 
processing, thereby ensuring that the DNA present is undamaged, and an accuracy of 96% 
is  quoted  42.  The  testing  cost  is  indicatively  €200-300/sample,  falling  to  approximately 
€100 for further samples tested. 

It is not clear the extent to which Control Bodies exist in countries such as Turkey to provide 
certification  and  traceability  for  non-GMO  cotton,  for  example  according  to  the  broad 
traceability provisions of Article 4, Part A of Regulation No 1830/2003. 

40 Regulation (EC) No 1830/2003 of the European Parliament and the Council of 22 September 2003 concerning the 
traceability and labelling of genetically modified organisms and the traceability of food and feed products produced 
from genetically modified organisms and amending Directive 2001/18/EC 
41 The Bremen Cotton Exchange, http://baumwollboerse.de/en/ 
42  Based  on  the  results  of  screening  trials  carried  out  by  the  Joint  Research  Centre's  Institute  for  Health  and 
Consumer Protection (IHCP) 

27 

 
 
 
 
                                                        
Summary of stakeholder feedback 

Stakeholder comments on the proposals 

The  ambition  level  of  the  minimum  content  requirement  of  60%  was  questioned,  with  a 
number  of  stakeholders  asking  either  for  clearer  confirmation  of  market  availability  to 
support this level or for a higher minimum percentage content, with for example 60% IPM 
for the core criterion and 100% organic for the comprehensive criterion.  Alternatively the 
greater market availability of IPM cotton could justify an increase from 60% to 80%. 

The criteria should make reference to specific certification schemes that are of significance 
in the market, for example the Global Organic Textile Standard (GOTS). 

The  market  data  for  the  worldwide  availability  of  organic  cotton  does  not  present  a 
complete picture. There are a number of countries where organic cotton is being grown as 
part of agricultural projects supported by overseas aid projects. For example, in Tanzania by 
Solidaridad. GPP criteria could play a role in providing 'planning certainty' in order to bring 
this cotton to the market. 

An  LCA  study  comparing  organic  cotton  with  conventional  cotton  production  was  cited  as 
evidence  for  the  improvement  potential  of  organic  cotton.    The  study  was  recently 
completed for the Textile Exchange by PE International.  

Final criteria  

Core criteria 

TECHNICAL SPECIFICATIONS 

Comprehensive criteria 

TS1. Cotton fibres 

TS1. Cotton fibres 

A  minimum  of  20 %  of  the  content  of  cotton 
goods used to fulfil the contract must be either: 

A  minimum  of  60  %  of  the  content  of  cotton 
goods used to fulfil the contract must be either: 

to 

1.  Organic:  grown  according 

the 
requirements  laid  down  in  Regulation 
(EC)  No 834/2007,43  the  US  National 
Programme 
Organic 
or 
equivalent 
legal  obligations  set  by 
trade partners of the EU; or 

(NOP) 

2. 

(IPM): 
Integrated  Pest  Management 
grown  according  to  IPM  principles  as 
Food  and 
defined  by 
the  UN 
IPM 
Agricultural  Organisation 
(FAO) 
programme44 
Directive 
EU 
2009/128/EC45 

or 

If  the  contracting  authority  wishes  to  further 
support  growth  of  the  organic  cotton  market 
and/or  identifies  a  shortage  in  the  supply  of 
certified 
or 
transitional  organic  cotton46  may  be  permitted 

uncertified 

organic 

cotton, 

1.  Organic:  Grown  according 

to 

the 
requirements  laid  down  in  Regulation 
(EC)  No  834/200743,  the  US  National 
Organic  Programme  (NOP)  or  equivalent 
legal obligations set by trade partners of 
the EU, or 
Integrated  Pest  Management 
(IPM): 
Grown  according  to  the  principles  as 
defined  by  the  UN  Food  and  Agricultural 
Organisation  (FAO)  IPM  programme44  or 
EU Directive 2009/128/EC45 

2. 

If  the  contracting  authority  wishes  to  further 
support  growth  of  the  organic  cotton  market 
and/or  identifies  a  shortage  in  the  supply  of 
certified organic cotton, uncertified or transitional 
(see 
organic 
explanatory  note  ‘Supporting  the  market  for 

cotton46  may  be  permitted 

43 Council Regulation (EC) No 834/2007of 28 June 2007 on organic production and labelling of organic products and 
repealing Regulation (EEC) No 2092/91 (OJ L 189, 20.7.2007, p. 1). 
44 More about IPM, The Food Agriculture Organisation (FAO) of the United Nations, 
http://www.fao.org/agriculture/crops/thematic-sitemap/theme/pests/ipm/more-ipm/en/. 
45  See  Annex  I  to  Directive  2009/128/EC  of  21 October  2009  of  the  European  Parliament  and  of  the  Council, 
establishing a framework for Community action to achieve the sustainable use of pesticides. 
46  The  Organic  Regulation  (EC)  No 834/2007  defines  ‘in-conversion’  as  ‘the  transition  from  non-organic  to  organic 
farming  within  a  given  period  of  time,  during  which  the  provisions  concerning  the  organic  production  have  been 
applied’.   Written  confirmation  from  an  organic  competent  authority  of  a  country,  or  an  organic  control  body,  that 

28 

 
 
                                                        
(see explanatory note ‘Supporting the market for 
organic cotton’ below). 

If  the  contracting  authority  wishes  to  support 
organic labelling for the products used then the 
organic  cotton  used  to  fulfil  the  requirements 
must  not  be  blended  with  genetically  modified 
cotton. Proof may be requested if other sources 
of  cotton  used  in  the  product(s)  are  obtained 
from countries where GM cotton is approved for 
use.47 

Verification: 

The  cotton  origin  and  content  of  the  goods  will 
be  verified  upon  delivery  by  means  of  a  third 
party  certification  scheme  for  IPM  or  organic 
cotton  production  together  with  documented 
transaction  records  that  allow  for  the  cotton 
content of individual items or batches of goods 
to  be  verified  and  traced  back  to  the  point  of 
certification. 

This  includes  valid  certification  for  organic  or 
IPM  production,48  as  well  as  documentation  of 
transactions  that  demonstrate  the  purchase  of 
the  claimed  cotton  content  and  provide 
traceability. 

If  relevant,  a  screening  test49  to  verify  non-
genetically  modified  cotton  will  be  provided 
upon request if conventional and IPM cotton are 
blended with organic cotton. 

organic cotton’ below). 

If  the  contracting  authority  wishes  to  support 
organic  labelling  for  the  products  used  then  the 
organic  cotton  used  to  fulfil  the  requirements 
must  not  be  blended  with  genetically  modified 
cotton.  Proof  may  be  requested  if  other  sources 
of cotton used in the product(s) are obtained from 
countries where GM cotton is approved for use 47. 

Verification: 

The cotton origin and content of the goods will be 
verified  upon  delivery  by  means  of  a  third  party 
certification  scheme  for  IPM  or  organic  cotton 
production  together  with  documented  transaction 
records  that  allow  for  the  cotton  content  of 
individual items or batches of goods to be verified 
and traced back to the point of certification. 

This  include  valid  certification  for  organic  or  IPM 
production48,  as  well  as  documentation  of 
transactions  that  demonstrate  the  purchase  of 
content  and  provide 
the 
traceability. 

claimed 

cotton 

If  relevant,  a  screening  test49  to  verify  non-
genetically modified cotton  will be provided  upon 
IPM  cotton  are 
request 
blended with organic cotton. 

if  conventional  and 

AWARD CRITERIA 
AC1. Cotton fibres 

AC1. Cotton fibres 

Points  shall  be  awarded  in  proportion  to  each 
10% improvement  upon the minimum technical 
specification  of  certified  IPM  or  organic  cotton 
content. 

Points  shall  be  awarded  in  proportion  to  each 
10%  improvement  upon  the  minimum  technical 
specification  of  certified  IPM  or  organic  cotton 
content. 

Verification: 

See criterion TS1 

Verification: 

See criterion TS1 

Supporting the market for organic cotton 

The  limited  availability  of  organic  cotton  on  the  world  market  can  pose  a  challenge  for  public 
contracts.  On  the  other  hand,  public  contracts  can  play  an  important  role  in  creating  demand.  To 
address  this  challenge  it  is  therefore  recommended  that  early  market  consultations  and/or  prior 
information notices are used to notify potential bidders of upcoming contracts and the likely volumes 
of cotton textiles required. 

growers have given notice of the conversion and subjected their farm(s) to an organic control system would provide 
formal proof of in-conversion status. 
47 See http://www.isaaa.org/gmapprovaldatabase/countrylist/default.asp. 
48 At the time of writing the following schemes are considered to provide sufficient assurance: IPM: the Better Cotton 
Initiative (BCI), AGRO 2 (Greece), Cotton Made in Africa, Fair Trade, the Australian Better Management Programme 
(BMP); Organic: EU recognised organic control bodies, US organic programme, IFOAM. 
49 A qualitative screening test for common genetic modifications carried out according to ‘EU Reference Methods for 
GMO Analysis’ is the recommended form of verification (see http://gmo-crl.jrc.ec.europa.eu/gmomethods). Tests are 
be  to  be  made  on  samples  of  raw  cotton  from  each  country  of  origin  and  before  it  has  passed  through  any  wet 
treatment. Certification of IPM cotton by schemes that exclude genetically modified cotton will be accepted as proof 
of compliance. 

29 

 
 
 
                                                                                                                                                               
Bidders  could  also  be  encouraged  to  source  cotton  through  collaborations  with  agricultural 
development  projects.  These  type  of  projects,  which  in  some  case  may  have  their own  certification 
schemes  (e.g.  Cotton  Made  in  Africa),  have  the  potential  to  support  new  certification  schemes  for 
organic  or  IPM  production.  It  is  also  the  case  that  certification  can  be  costly.  Because  of  this  cost, 
uncertified organic cotton can be obtained from a number of countries where development projects 
have promoted low input agriculture or where specific agricultural policies have been adopted. 

In order to bring more organic cotton into the market, contracting authorities can support the market 
in two ways: 

1.  By accepting certification provided by organic  control bodies, government  control bodies or 
third  party  schemes  upon  award  of  the  contract  and/or  purchase  of  the  cotton.  Combining 
this approach with early market consultations would give producers and growers more time 
and also send a clear signal to the market that there is demand to formally certify cotton. 
2.  Accepting cotton from farmers that are in the transitional conversion period as they move to 
organic  production  as  laid  down  in  Article  17  of  the  Organic  Regulation.  This  would 
incentivise  growers  and  projects  based  on  low-input  techniques  to  look  at  the  options  for 
marketing their cotton, as well as the future potential for certifying their production. 

The  latter  would  recognise  the  investment  and  changes  required  to  move  from  conventional  to 
organic systems, providing greater certainty that there will be a market for the cotton. 

Summary rationale for the requirements and verification: 

o  There  are  two  improvement  options  available  for  cotton  fibres:  organic  and  IPM 

production systems. 

o  Organic  cotton  has  the  benefit  of  avoiding  the  use  of  synthetic  fertilisers  and 
pesticides and requiring more sustainable forms of land management, but the yield 
is lower by 20-50% and, if grown in areas where there is stress on water resources, 
water use may not always be lower. 

o 

IPM cotton has the benefit of reducing the use of synthetic fertilisers and pesticides 
as well as producing a higher yield, but does not  completely  eliminate the use of 
potentially  hazardous  pesticides  or,  depending  on  the  system,  lead  to  more 
sustainable forms of land or water management. 

o  Whilst  organic  cotton  is  still  a  niche  product  on  the  global  market,  demand  from 
major  retailers  and  specialist  clothing  companies  has  driven  its  growth,  and  it 
currently accounts for an EU market share of around 1.3%. 

o  Although  it  has  been  estimated  to  account  for  around  20%  or  more  of  global 
production, IPM cotton could not, until recently, be  clearly  identified in the market 
because  it  was  not  possible  to  certify  its  origin.  Estimates  for  the  four  main 
certification schemes suggest that it currently accounts for an EU market share of 
around 11.4%. 

o  The greater market availability and,  potentially, lower price premium suggest that 
IPM is better suited than organic cotton as a Core criterion. It is therefore proposed 
to  mirror  the  minimum  content  requirement  from  the  EU  Ecolabel  of  20%.  
However, it is considered that bidders able to offer organic cotton on a competitive 
basis should not be locked out, so it is therefore proposed that organic cotton shall 
also be included, but on an optional basis. 

o  Whilst  it  is  considered  important  to  stimulate  demand  for  organic  cotton  the 
tendency towards a greater price premium and its greater market scarcity suggest 
that it is better suited as an option for bidders alongside IPM cotton – reflecting the 
approach  in  the  EU  Ecolabel  –  or  as  part  of  an  award  criterion  to  encourage  the 

30 

 
 
 
market to bring forward products with a higher content than the minimum Core or 
Comprehensive requirements at competitive prices. 

o 

It is therefore proposed to have a flexible overall Comprehensive criterion target of 
60%  for  environmentally  improved  cotton  –  allowing  bidders  to  comply  by 
supplying  either  IPM  or  organic  cotton.  The  threshold  of  60%  reflects  the  higher  
level of IPM ambition which applies to specific products in the EU Ecolabel.    

o  An award criterion could be used to encourage tenderers to bring forward products 
with  higher  contents  of  organic  and/or  IPM  cotton,  given  the  potential  risk  of  a 
reduced number of bidders and price premiums. 

o 

In accordance with the principles of organic production laid down in the EU Organic 
Regulation,  organic  cotton  shall  not  be  blended  with  cotton  that  originates  from 
GMOs.  This  could  include  conventional  and/or  IPM  cotton  of  genetically  modified 
varieties. Verification should therefore be requested in these circumstances. 

o  A  guidance  note  has  been  added  to  highlight  the  role  that  public  authorities  can 

play in supporting the market for organic cotton. 

2.1.2.2 Wool fibres 

Technical background to the criteria proposal 

Revision  of  the  wool  criteria  for  the  EU  Ecolabel  focused  on  four  main  areas  of 
environmental improvement, taking a life cycle approach: 

o  Ectoparasiticides  in  wool:  Wool  cleaning  (scouring)  effluent  tends  to  contain  large 
amounts of pesticides as a result of their use to treat sheep. The most hazardous 
ectoparasiticides may be minimised at source by restricting and testing for specific 
substances before the wool is scoured or by specifying organic wool. 

o  Water pollution by wool scourers: The dirt, grease and sint that must be washed out 
of  wool  before  it  can  be  processed  by  the  textile  industry  can  result  in  a  heavily 
loaded  wastewater  which  may  be  discharged  to  the  environment.  This  potential 
pollutant  load  can  be  reduced  significantly  by  removing  these  wastes  at  source, 
with  the  additional  resource  efficiency  benefit  of  maximising  their  value  as  by-
products. 

o  Energy use by wool scourers: Cleaning wool of dirt, grease and sint requires energy 
to  heat  hot  water  and  to  power  the  operation  of  by-product  and  wastewater 
treatment plant. 

From a life cycle perspective energy use is significant but no agreement could be reached 
between  stakeholders  on  a  benchmark  for  the  performance  of  wool  scourers. 
Ectoparasiticide testing is contained within the final criteria but requires relatively complex 
sampling and testing of wool consignments from farmers to ensure that it is meaningful. 

This leaves water pollution control as a potential focus for GPP as it is comparatively easy 
to  verify,  albeit  still  requiring  data  to  be  obtained  by  manufacturers  from  wool  scouring 
sites. 

Determining water pollution thresholds for wool scourers 

The wastewater treatment strategies of wool scourers in Australia, New Zealand, China and 
the  EU  were  compared  in  order  to  determine  limit  values  for  Chemical  Oxygen  Demand 
(COD)  of  wastewater  discharged  to  the  environment.  The  practices  of  the  wool  scourers 
were cross-referenced with the BAT (Best Available Techniques) in the EU textile BREF. 

Grease  is  understood  to  contribute  to  approximately  48-71%  of  the  COD  from  wool 
scouring and therefore its removal is a critical factor in COD reduction. Dirt is understood to 

31 

 
 
contribute  to  approximately  17-31%  of  the  COD.  The  comparison  of  wool  scourers 
highlighted the importance of minimising COD by removal at source of dirt and grease. The 
benefit  to  COD  levels  will,  however,  vary  depending  on  the  type  of  wool  with  fine  wool 
carrying more grease and therefore requiring more cleaning to lower COD levels. 

Wool  scourers can be  seen to pursue different strategies for COD  removal  from effluent. 
Whilst  major  scourers  have  implemented  BAT  technologies  as  specified  in  the  BREF  for 
Textiles their overall approach differs. Two examples of wool scouring are described below 
to illustrate the differences. 

In  the  first  example  dirt  and  grease  removal  is  maximised  at  source.  Multi-stage  grease 
recovery is combined with the pre-cleaning of wool to remove dirt before scouring in order 
to  minimise  COD  at  source.  Dirt  and  grease  removal  has  the  benefit  of  improving  the 
product,  increasing  the  amount  of  valuable  by-products  recovered  from  the  wool  and 
minimising energy use and the need  for detergents and advanced wastewater treatment. 
The  effluent  is  then  sent  for  off-site  treatment  by  a  modern  municipal  wastewater 
treatment  plant.  This  combination  of  treatment  stages  enables  COD  to  be  reduced  from 
180 g/kg following grease removal down to below 45 g/kg. 

In the second example residual dirt and grease is treated by advanced on-site wastewater 
treatment  plant.  Basic  grease  recovery  is  followed  by  a  multi-stage  effluent  treatment 
works  including  chemical  flocculation,  activated  sludge  and  evaporation.  The  combination 
represents BAT. This combination of treatment stages enables COD to be reduced from 100 
g/kg following grease removal to below 25 g/kg. 

Summary of stakeholder feedback 

Stakeholder comments on the proposals 

It should be clarified whether the COD requirement applies to direct or indirect wastewater 
discharges from a wool scouring site. 

A stakeholder recommended that EU Ecolabel and Nordic Swan requirements on pesticides 
should be reflected in the criterion. 

Final criteria 

Core criteria 

TECHNICAL SPECIFICATIONS 
TS2. Wool fibres 

(Same for core and comprehensive criteria) 

Comprehensive criteria 

It is recommended to use this criterion only where the wool content of the textile products is greater 
than 50 %. 

The  wastewater  discharges  from  wool  scouring,  either  directly  from  treatment  on-site  or  indirectly 
from off-site wastewater treatment, measured in g COD (chemical oxygen demand)/kg greasy wool 
must be ≤25 g for coarse wool and lamb's wool and ≤45 g for fine wool.  

Verification: 

The  tenderer  will  upon  delivery  of  the  goods  provide  compliant  monitoring  data  for  the  processing 
lots from which wool used in the contract comes from. 

COD calculations will relate to the wool throughput in kg to the wastewater flow in litres from each 
processed lot of wool. Monitoring data must be obtained by third party testing according to ISO 6060 
or equivalent wastewater from each wool scouring site that wool is purchased from. 

Transaction  records  will  be  provided  that  verify  the  wool  scouring  site  for  the  wool  used  to 
manufacture the products. 

32 

 
 
Summary rationale for the requirements and verification: 

o  A  number  of  different  aspects  of  sheep  farming  and  wool  scouring  require 
addressing in order to minimise the environmental impacts of wool production. 
o  The  complexity  of  verification  for  the  EU  Ecolabel  criteria  on  pesticides  suggests 
that the simpler criteria on wastewater treatment could instead be included within 
the  GPP  criteria.  This  would  have  the  dual  benefit  of  removing  pesticide  residues 
from  wastewater  and  encouraging  resource  efficient  scouring  (see  the  points 
below). 

o  The  requirement  for  wastewater  treatment  has been  simplified  into  final  point  of 
discharge  COD  limits  of  45  g/kg  and  25  g/kg  for  fine  and  coarse  wool  scours 
respectively.  These  limits  will  reduce  the  organic  loading  of  effluent  as  well  as 
removing residual pesticides. 

o  These  limits  are  based  on  reductions  in  COD  of  75%  by  coarse  and  fine  wool 
scourers.  This  reduction  in  COD  also  supports  greater  resource  efficiency  as  the 
residues removed from the wool are valuable by-products. 

o  These  limits  can  be  achieved  by  modern  wool  scours  using  a  combination  of  dirt 
and  grease  removal  at  source  together  with  on  or  off  site  (direct  or  indirect) 
wastewater  treatment.  The  45  g/kg  threshold  would  permit  scourers  achieving  a 
high level of dirt and grease removal to comply. 

o  The  verification  reference  to  an  ISO  standard  ensures  that  the  test  results  are 
comparable. Flexibility is ensured by allowing for compliance based on test results 
from  either  on-  or  off-site  treatment  plant.  Compliant  monitoring  data  shall  be 
requested for wool processing lots supplied for use in execution of the contract. 

2.1.2.3 Man-made cellulose fibres (e.g. viscose, modal, lyocell) 

Technical background to the criteria proposal 

Man-made  cellulose  fibres  (also  referred  to  as  rayon)  are  manufactured  at  an  industrial 
scale from cellulose pulp. This cellulose may be derived from a range of different sources, 
including  timber,  bamboo  and,  increasingly  in  China,  cotton  pulp.  Over  the  last  decade, 
production  of  viscose  fibres  stabilised  at  approximately  2.6  million  tonnes  world-wide 
(Europe:  600  thousand  tons)  but  has  recently  risen  sharply  again  to  5.5  million  tonnes, 
reflecting renewed interest and a market perception that it is a more sustainable fibre than 
cotton50. Fibre types are viscose, modal and lyocell. 

A  peer  reviewed  LCA  study  carried  out  by  Utrecht  University  and  commissioned  by  the 
manufacturer Lenzing (2010) was critically reviewed in order to compare the environmental 
performance of viscose, modal and lyocell fibres51. Of the potential improvement measures 
that can be identified from the study two are addressed by the EU Ecolabel criteria, namely: 

  Moving  to  a  biorefinery  approach,  with  black  liquor  and  other  by-products  being 
used  either  as  fuel  to  generate  steam  for  pulp  production  processes  (thereby 
offsetting  on-site  emissions)  or  as  co-products  for  use  as  feedstock  to  produce 
other products e.g. acetic acid, turpentines, soap; 

  Minimisation  of  carbon  disulphide  solvent  emissions  to  air  and  water  from  the 
viscose  and modal  fibre  production  stage.  These  emissions  are  avoided  in Lyocell 
fibre production because a safer, biodegradable solvent is used. 

An  environmental  issue  addressed  in  the  EU  Ecolabel  criteria  but  not  highlighted  as 
significant  by  the  LCA  study  are  halogenated  emissions  to  water  from  pulp  production. 

50 Asia Paper Markets, Commodities to watch – dissolving pulp, Market briefing paper, February 2001 
51 Shen, L and M.K.Patel, Life cycle assessment of man-made cellulose fibres, Utrecht University, Lenzinger Berighte 
88 (2010) 1-59 

33 

 
 
 
                                                        
Although the form of verification is familiar – being similar to that for paper products – it is 
considered that sulphur emissions are more significant and have the benefit of allowing for 
differentiation of the cleaner Lyocell production process. 

A  further  environmental  issue  highlighted  by  the  LCA  study  but  that  is  more  difficult  to 
quantify  because  it  is  regionally  specific  and  is  not  yet  well  addressed  by  LCA  impact 
category  indicators  is  the  impact  of  deforestation52.  Hardwood  pulp  is  required  to 
manufacture  the  fibres  and  the  sourcing  of  this  feedstock  has  been  cited  as  being 
associated  with  deforestation  in  developing  countries53.  Given  the  policy  significance  of 
illegal  and sustainable sourcing at  International  and  EU  level it is therefore considered to 
address this issue within the criteria. 

BAT limit values for sulphur emissions 

Benchmark  emissions  levels  are  provided  in  the  EU  BREF  for  polymer  production.  Three 
viscose  fibre  production  technologies  are  addressed  –  staple  fibre  production  and  two 
forms of filament fibre production, batch and integrated washing. The emissions levels are 
presented as ranges: 

o  Filament fibre, integrated washing 170-220 kg/tonne fibre 

o  Filament fibre, batch washing 40-60 kg/tonne fibre 

o  Staple fibres, 12.5-30 kg/tonne fibre 

From dialogue with industry it was identified during the EU  Ecolabel revision process that 
for  filament  fibres  170kg/t  and  40kg/t  are  achievable  for  the  best  integrated  and  batch 
washing  processes  respectively,  whereas  12.5kg/t  for  staple  fibres  requires  multiple 
pollution control technologies that are not yet implemented by manufacturers of fibres for 
textiles. For staple fibres a threshold of 30 kg/tonne of fibre was therefore retained based 
on the performance of EU market leaders. 

Reducing the formation of dioxins and halogenated compounds 

The  use  of  chlorine  as  a  bleaching  agent  for  pulp  can  lead  to  the  formation  of  dioxins, 
chlorophenols,  chloroform  and  other  halogenated  compounds.  The  pulp  and  paper  BREF 
states that a shift from the use of elemental chlorine to the use of chlorine dioxide gas in 
combination with hydrogen peroxide during selected bleaching stages – so called Elemental 
Chlorine Free (ECF) bleaching - is effective in reducing the potential for dioxin formation to 
non-detectable levels54. 

The  BREF  highlights  that  Elemental  Chlorine  Free  (ECF)  processes  are  increasingly  being 
replaced  by  Total  Chlorine  Free  (TCF)  processes  in  order  to  further  reduce/eliminate  AOX 
emissions and dioxin formation 55. However, for viscose fibres ECF pulp still dominates the 
market, with TCF mainly  only used for specialist  applications,  such as medical devices.  At 
the  fibre  production  stage  sodium  hypochlorite  (NaClO)  bleach  is  still  required  to  meet 
customer  requirements  for  the  uniform  whiteness  of  the  fibres.  Hydrogen  peroxide 
bleaching is used, but only for medical applications where chlorine cannot be present. 

During  revision  of  the  EU  Ecolabel  textile  criteria  a  proposal  was  made  to  replace  the 
organically  bound  chlorine  (OX)  limit  value  for  fibres  with  a  simpler  requirement  for 
Elemental  Chlorine  Free  (ECF)  pulp  or  low  halogenated  wastewater  discharges  from  pulp 

52  This  methodological  issue  is  discussed  in  Allacker.K,  Souza.D  and  Sala.S,  Land  use  impact  assessment  in  the 
construction sector: an analysis of LCIA models and case study application, The International Journal of Life Cycle 
Assessment, November 2014, Volume 19, Issue 11, pp 1799-1809. 
53 NRDC, Not all bamboo is created equal, August 2011 
http://www.nrdc.org/international/cleanbydesign/files/CBD_FiberFacts_Bamboo.pdf see also Patagonia, On bamboo 
and rayon, April 2009 
54  European  Commission,  Best  Available  Techniques  reference  document  for  production  of  pulp,  paper  and  board, 
IPPC Bureau, Draft May 2012. 
55 ibid 54 

34 

 
 
                                                        
production.  There  is,  however,  no  definitive  form  of  ECF  pulp  production  and  establishing 
equivalence between fibre and pulp is not straightforward. 

The  pulp  and  paper  BREF  suggests  that  for  modern  plant  halogenated  emissions  (AOX) 
levels in wastewater can vary in a range between 0.03 and 0.40 g/t pulp. The term ‘ECF-
light’  has  been  used  to  describe  bleaching  sequences  at  the  lower  end  of  this  range. 
Moreover,  it  is  understood  from  discussions  with  a  leading  viscose  manufacturer  that 
meeting a limit value of 150g/t air dried pulp for OX in fibres would also require 'ECF-light' 
pulp production. 

An  indicative  comparison of  bleaching  sequences  published  by  METSO  suggests  that  only 
bleaching sequences with AOX emissions of <0.15-0.17 kg/t of air dried pulp would permit 
an  OX  in  fibres  of  <150g/tonne  air  dried  pulp  to  be  achieved  (allowing  for  a  contribution 
from bleaching of the final fibre)56. This is illustrated in Figure 3. On this basis a threshold 
of  0.17  kg/ADT  pulp  was  proposed  for  the  EU  Ecolabel  and  is  also  proposed  as  a 
Comprehensive GPP criterion. 

Figure 3. Comparison of AOX and OX arising from bleaching sequences 

a) AOX emissions from example ECF bleaching sequences 

b) OX levels in pulp bleached with example bleaching sequences 

Source: Metso (2009) Bleaching of chemical pulp 

Sourcing of legal wood pulp 

Dissolving  pulp  is  required  to  manufacture  regenerated  cellulose  fibres.  It  is  a  specialist 
pulp  grade  because  it  requires  longer  fibres,  a  higher  level  of  quality  control  and  more 

56 Metso (2009) Bleaching of chemical pulp 

35 

 
 
 
 
                                                        
feedstock  to  produce,  than  paper  pulp57.  It  is  understood  to  be  largely  produced  using 
eucalyptus, a tree grown in regions that may be of concern in terms of legal sourcing, as 
well as beech and bamboo pulp grown in Western Europe and China respectively. 

Tackling illegal logging and associated trade is a policy objective for Europe in accordance 
with  its  2003  Forest  Governance,  Law  Enforcement  and  Trade  (FLEGT)  Action  Plan.  The 
Timber Regulation (EC) 995/201058 introduced new requirements for the sourcing of timber 
products  from  2013,  which  includes  wood  pulp.  It  prohibits  illegally  harvested  timber 
(domestic or imported) from being placed on the EU market and introduces requirements 
for ’due diligence’, which it defines as comprising: 

(a)  measures  and  procedures  providing  access  to  the  [origin  of]  the  operator’s 
supply of timber or timber products placed on the market; 

(b) risk assessment procedures enabling the operator to analyse and evaluate the 
risk of illegally harvested timber or timber products derived from such timber being 
placed on the market; 

(c)  except  where  the  risk  identified  in  course  of  the  risk  assessment  procedures 
referred to in point (b) is negligible, risk mitigation procedures which consist of a set 
of  measures  and  procedures  that  are  adequate  and  proportionate  to  minimise 
effectively  that  risk  and  which  may  include  requiring  additional  information  or 
documents and/or requiring third party verification. 

The  Regulation  defines  'legally  harvested'  as  wood  and  wood-based  materials  (excluding 
packaging and recycled wood) that has been 'harvested in accordance with the applicable 
legislation in the country of harvest'. 'Applicable legislation' means the legislation in force in 
the country of harvest covering the following matters: 

  Rights to harvest timber within legally gazetted boundaries; 

  Payments for harvest rights and timber including duties related to timber harvesting; 

  Timber  harvesting,  including  environmental  and  forest  legislation  including  forest 
management and biodiversity conservation, where directly related to timber harvesting; 

  Third  parties’  legal  rights  concerning  use  and  tenure  that  are  affected  by  timber 

harvesting; and 

  Trade and customs, in so far as the forest sector is concerned. 

Europe is in the process of introducing the FLEGT (Forest Law Enforcement Governance and 
Trade)  licensing  scheme.  FLEGT  is  based  on  bilateral  agreements  between  the  EU  and 
timber producing countries. Valid EU FLEGT and UN CITES licenses are deemed to provide 
assurance of legality. 

Third  party  forest  and  forest  products  certification  systems  that  meet  the  due  diligence 
criteria  set  out  in  Article  6  of  the  Regulation  can  be  used  as  a  valuable  tool  in  the  due 
diligence system. These could, for example, include FSC 'Controlled sources' or verification 
by organisations such as SGS, Bureau Veritas and Control Union. These can be used as long 
as they can meet the due diligence criteria set out in Article 6 of the Regulation, and Article 
4 of the Commission implementing Regulation (EU) No 607/201259. 

Despite the obligations from the Timber Regulation, there is still a risk that timber used to 
manufacture pulp  may originate from non-legal sources. Public authorities, which wish to 

57  European  Commission,  Best Available  Techniques  reference  document  for  production  of  pulp,  paper  and  board, 
IPPC Bureau, Draft May 2012. 
58 Regulation (EU) No 995/2010 of the European Parliament and of the Council of 20 October 2010 laying down the 
obligations of operators who place timber and timber products on the market 
59 Further information available in the "Guidance Document for the EU Timber Regulation" available at: 
http://ec.europa.eu/environment/eutr2013/_static/files/guidance/guidance-document-5-feb-13_en.pdf 

36 

 
 
                                                        
have a higher degree of reassurance that the timber is actually legally sourced, can include 
a contract performance clause requiring that the wood pulp supplied under the contract has 
been legally harvested. 

Sourcing of sustainable wood pulp 

European sustainable forestry policy 60 and certification schemes for sustainable forestry 61 
find their basis in the UNEP and FAO principles of Sustainable Forestry Management (SFM) 
established  at the  Rio  Earth  Summit  in  1992  62.  These  principles,  although  not defined in 
specific detail in UNEP or FAO literature, provide an internationally agreed reference point 
which 
level,  Sustainable  Forestry 
Management  (SFM)  is  now  defined  in  more  detail  by  Forest  Europe's  SFM  criteria,  which 
have  been  endorsed  by  ministers  from  European  countries  63.    The  conformance  of 
certification  schemes  with  ISO/IEC  17065  is  also  relevant  in  relation  to  the  quality  and 
assurance provided by the verification systems used 64.  

is  used  by  certification  schemes.  At  European 

In terms of market share the two most significant certification schemes are those operated 
by  the  Forestry  Stewardship  Council  (FSC)  65  and  the Programme  for  the  Endorsement  of 
Forestry Certification (PEFC)66.  In 2009 these schemes accounted for 9% of global forestry 
and 26% of industrial timber supplies  67. PEFC is the most significant scheme, accounting 
for  over  two  thirds  of  certified  timber  on  the  world  market.  The  majority  (over  90%)  of 
certified timber originates from Europe and North America.  

No  reliable  market  data  is  currently  available  for  the  quantity  of  certified dissolving pulp 
that  is  available,  however,  a  review  of  publicly  available  information  from  the  major 
producers suggests that at least 14.5% of capacity may be certified to either FSC or PEFC. 
Consultation  with  a  current  EU  Ecolabel  license  holder  confirmed  that  certified  market 
dissolving pulp can be obtained but that the maximum they could practically achieve would 
be 50% certified fibre content. Wider consultation by Europe’s man-made fibre association, 
CIRFS, suggested 25%. 

Belgium68, Denmark,  Germany69, UK70 and the Netherlands71 are notable for their detailed 
monitoring  and  evaluation  of  forestry  certification  schemes  in  support  of  Green  Public 
Procurement (GPP)72. These Member States use their own adapted criteria and processes to 
determine  whether  certification  schemes  provide  sufficient  assurance.  They  currently 
coincide in recognising that FSC and PEFC provide sufficient levels of assurance based on 
their  national  criteria.    Denmark,  Germany,  the  Netherlands  and  the  UK  are  currently 
working  together  to  identify  the  common  ground  between  their  respective  timber 
procurement policies.  

60 European Commission, EU forests and forest related products, 
http://ec.europa.eu/environment/forests/home_en.htm  
61 Rametsteiner, E and M, Simula, Forest  certiﬁcation—an instrument to promote sustainable forest management? 
Journal of Environmental Management 67 (2003) 87–98 
62 Castaneda, F. Criteria and indicators for sustainable forestry management. UN FAO, 
http://www.fao.org/docrep/x8080e/x8080e06.htm#TopOfPage   
63 Forest Europe, Sustainable Forestry Management criteria and indicators, accessed August 2016, 
http://www.foresteurope.org/sfm_criteria/criteria 
64 ISO/IEC 17065: 2012, Conformity assessment – requirements for bodies certifying products, processes or services.  
65 Programme for the Endorsement of Forestry Certification, http://www.pefc.org/ 
66 Forestry Stewardship Council, http://www.fsc.org/ 
67 UNECE and FAO (2010)  Forest products annual market review 2009-2010 
68 UK Central Point of Expertise on Timber, Government procurement of timber in Belgium, http://www.cpet.org.uk/uk-
government-timber-procurement-policy/international-context/international-policies-1/belgium 
69 
paper 

Policy,  Wood 

Procurement 

Government 

products, 

Germany 

based 

and 

http://www.sustainableforestprods.org/tools/german_government_procurement_policy 
70 UK Central Point of Expertise on Timber (2008) Review of forestry certification schemes results 
71 Timber Procurement Assessment Committee, Netherlands, http://www.tpac.smk.nl/ 
72  UK  Central  Point  of  Expertise  on  Timber  (2008)A  comparative  study  of  the  national  criteria  for  ‘legal  and 
‘sustainable’  timber  and  assessment  of  certification  schemes  in  Denmark,  UK,  Netherlands  and  Belgium 
http://www.cpet.org.uk/uk-government-timber-procurement-policy/international-context/international-policies-
1/comparative-study-of-danish-uk-dutch-and-belgium-national-criteria 

37 

 
 
                                                        
Summary of stakeholder feedback 

Stakeholder comments on the proposals 

The sulphur emissions threshold for staple fibres should be lowered to 20 g/kg, in order to 
reflect the lower threshold in the polymer BREF, which was published in 2003. 

A  stakeholder  recommended  focussing  only  on  chlorine  emissions  from  pulp  and  not  the 
fibre. Moreover, they recommended lowering the OX level in fibres to 100ppm. 

Recognising  the  problems  raised  in  relation  to  sustainable  forestry  certification,  a 
stakeholder called for 'deeper harmonisation' of certification schemes across the EU, with 
specific reference made to FSC and PEFC schemes as having the potential to form the basis 
for a common approach to timber policies in GPP criteria. 

Final criteria  

Core criteria 

Comprehensive criteria 

TECHNICAL SPECIFICATIONS 
TS3. Man-made cellulose fibre (e.g. viscose, modal, lyocell) 

(Same for core and comprehensive criteria) 

This  type  of  fibre  may  be  used  instead  of  cotton  in  a  variety  of  clothing  items  or  interior  textiles 
requiring a softer handle. It may also be blended with synthetic fibres to improve wear and make it 
easier to dry. It is recommended to use this criterion only where the man-made cellulose fibre content 
of the textile products is greater than 50 %. 

TS3.1 Sulphur emissions to air 
For viscose and modal fibres, the sulphur content of the emissions of sulphur compounds to air from 
the  fibre  production  process,  expressed  as an  annual  average, must  not  exceed  the  values in  table 
(a). 

Table a. Viscose and modal sulphur emissions values 

Fibre type 

Staple fibre 
Filament fibre 
- Batch washing 
- Integrated washing 

Performance 
value 
(g S/kg) 
30 g/kg 

40 g/kg 
170 g/kg 

Verification: 
The  tenderer  will  upon  award  provide  monitoring  data,  transaction  records  and  batch  production 
records  demonstrating  the  compliance  of  supplier(s)  and  associated  production  sites  used  to 
manufacture the fibres used in the contract. 

Compliant monitoring data will be provided for those production sites used to make the specific fibre 
product to be used in execution of the contract. 

38 

 
 
 
 
 
 
TS3.2 Halogenated emission from pulp 

Pulp  used  to  manufacture  the  fibre  product  used 
in the contract shall be bleached without the use 
of elemental chlorine. 

The  resulting  total  amount  of  chlorine  and 
organically  bound  chlorine  in  the  finished  fibres 
(OX)  shall  not  exceed  150  ppm  or  in  the 
wastewater from pulp manufacturing (AOX) shall 
not exceed 0.170 kg/t air dried pulp. 

Verification: 

The tenderer shall upon award provide a test 
report for the specific fibre product and its 
production line demonstrating compliance with 
either the OX or the AOX requirement, using the 
appropriate test method or equivalent: 

-  OX: ISO 11480 (controlled combustion 

and microcoulometry). 

-  AOX: ISO 9562. 

Sustainable Sourcing of wood pulp  

These GPP criteria do not include a proposal on the sourcing of wood pulp derived from sustainable 
forestry, for the following reasons: 

Several Member States are using their own green or sustainable public procurement criteria to define 
sustainable  forest  management  and  have  different  processes  in  place  to  determine  whether 
certification or other third party verified schemes provide sufficient assurance. In this situation, it was 
not  possible,  within  the  framework  of  this  criteria  development  process,  to  provide  a  harmonised 
definition of sustainable managed forestry. 

The current consensus of the Member States with an active sustainable timber procurement policy is 
that,  in  general,  proprietary  certification  schemes,  such  as  those  of  the  Forest  Stewardship  Council 
(FSC) and the Programme for the Endorsement of Forest Certification (PEFC) provide sufficient levels 
of assurance for compliance with their national criteria.   

Summary rationale for the requirements and verification: 

o  Cellulose fibres such as viscose, modal and lyocell are manufactured from cellulose 

feedstock derived from timber, bamboo or cotton. 

o  Manufacturing these fibres results in wide ranging environmental impacts including 

natural resource use, habitat loss, energy use, air and water pollution. 

o  LCA evidence together with EU policy priorities suggest that criteria should focus on 
raw material (wood pulp) sourcing and emissions at the fibre production stage. 
o  Emissions  to  air  of  hydrogen  sulphide  are  of  concern  during  fibre  production  and 

are directly possible to verify and control by suppliers. 

o  A  criterion  is  therefore  proposed  with  limit  values  for  emissions  to  air  of  sulphur 
from  fibre  production  sites,  with  the  criteria  being  aligned  with  the  revised 
thresholds  adopted  in  the  EU  Ecolabel  for  textiles,  which  reflects  industrial  best 
practice  which  is  applicable  as  both  a  Core  and  Comprehensive  technical 
specification. 

o  Halogenated emissions from pulp manufacturing are proposed as a more ambitious 
Comprehensive  criterion  because  it  requires  verification  from  further  along  the 
supply chain. The thresholds are aligned with the EU Ecolabel. 

o  The  sourcing  of  wood  from  legal  forestry  is  a  policy  objective  of  the  EU  and  a 
number of Member States. The raw material used to make this type of fibre raises 

39 

 
 
 
particular concerns given that it may be sourced from regions such as Asia where 
there is greater concern about deforestation. 

o  For the moment, in view of the differences in national timber procurement and on-
going work aimed at identifying the communalities between different schemes, no 
requirements or definitions addressing the sustainability of wood pulp are currently 
proposed. 

2.1.2.4 Polyester and Polyamide (nylon) fibres 

Technical background to the criteria proposal 

The market analysis suggested that polyester and nylon are amongst the most frequently 
specified synthetic fibres in public procurement. Analysis of the life cycle of both fibres for 
the EU Ecolabel revision highlighted recycled content as the most significant environmental 
improvement  option  to  reduce  the  raw  material  and  process  energy  use  associated  with 
fibre manufacturing. 

The environmental improvement potential of recycled polyester 

Polyester  with  a  recycled  content  is  largely  made  from  waste  plastic  PET  bottles.  A 
comparative LCA study of virgin PET and R-PET carried out by Shen et al (2010) quantified 
the environmental improvement potential of mechanical and chemical recycling options for 
seven out of eight of the Life Cycle indicators used, as illustrated in Figure 4 73. 

However,  the  study  also  notes  that  recycling  does  introduce  new  impacts,  such  as  those 
related to the washing of waste PET, and that there are differences in the performance of 
different recycling routes, with the overall conclusion being that mechanical recycling has a 
lower  impact,  and  therefore  a  better  overall  improvement  potential,  than  chemical 
recycling. 

Figure 4  Normalised results for 1 ton of PET fibre using a “cut-off” approach with cradle-
to-factory gate for second life. Source: Shen et al (2010) 

Polyester  staple  fibre  is  used  to  manufacture  non-woven  fabrics  such  as  fleece.  CIRFS 
suggest that 70% of EU staple polyester production, which was 600,000 tonnes in 200974, 
is  currently  manufactured  using  100%  recycled  PET  feedstock.  EU  manufacturers  include 
Wellman, Advansa, Miroglio, Greenfiber and Radici75. 

73  Shen  L,  Warrell  E  and  Patel  M.K.  Open  loop  recycling,  an  LCA  case  study  of  PET  bottle  to  fibre  recycling, 
Resources, Conservation and Recycling Journal,  55 (p-34-52) 
74 Oerlikon, The fibre year 2009/10 – A world survey on textiles and non-wovens industry, May 2010 
75 CIRFS full members, http://www.cirfs.org/MEMBERSHIP/CIRFSMembers/FullMembers.aspx 

40 

 
 
 
 
                                                        
The technical specifications of staple fibre are close to the specifications required for PET 
bottles,  so  with  adequate  sorting,  cleaning  and  drying  of  the  R-PET  feedstock  it  is 
understood that manufacturers’ quality specifications can be met. Certain applications are, 
however,  excluded  such  as  medical  devices,  because  of  hygiene  restrictions  on  recycled 
content. 

Polyester  filament  fibre  is  used  to  manufacturer  woven  fabrics.  It  is  a  higher  quality 
product  than  staple  fibre  requiring  higher  technical  specifications  than  staple  fibre  and 
careful  control  of  manufacturing  processes  in  order  to  ensure  qualities  such  as  colour, 
tenacity, tensile strength and dyeability are within manufacturers' quality specifications. 

The heterogenous nature of the R-PET feedstock means that consistency cannot always be 
assured76. Feedback during the EU Ecolabel revision process highlighted that quality issues 
such as reduced fibre strength and abrasion resistance, as well as problems with dyeability 
and  achieving  colour  consistency,  are  challenges  when  using  fibres  with  recycled  content. 
This is potentially problematic in meeting the higher quality specifications required in public 
contracts – for example, very detailed camouflage patterns for the military or for uniforms, 
where colour matching of tops and trousers is important. In the case of office upholstery 
fabrics  sufficient  abrasion  resistance  may  only  be  possible  to  achieve  by  using  pre-
consumer waste polyester. 

The availability of polyester with a recycled content 

As already noted staple polyester fibre is already likely to contain a high recycled content 
and so is a relatively mature specification in the market. Filament fibre is understood to be 
more  challenging  as  quality  requirements  are  more  exacting.  In  order  to  understand  the 
availability  and  quality  specifications  of  filament  fibre  with  a  recycled  content,  EU  and 
global manufacturers of polyester filament fibre were identified and investigated: 

o  Mechanically  recycled  content:  Two  EU  manufacturers  are  understood  to 
manufacture  filament  fibre  products  –  Filature  Miroglio  and  Radici,  both  in  Italy. 
Both  claim  to  manufacture  fibre  products  that  are  suitable  for  a  wide  variety  of 
clothing applications, including technical wear and sportswear. 

- 

Filature Miroglio: The filament is manufactured with 100% recycled content 
and  is  solution  dyed  –  a  form  of  dyeing  whereby  the  dye  is  incorporated 
into the fibre when it is manufactured  77. Production capacity is quoted at 
3,000 tonnes/annum. The post-consumer origin of their ‘Newlife’ product is 
second party certified by the Italia Plastics Institute’s Plastic Seconda Vita 
scheme. 

-  Radici Group: The filament is manufactured with 70% recycled content and 
is solution dyed78. Data on the production capacity has been requested. The 
post-consumer  origin  of  their  r-Starlight  (POY  and  drawn  yarn)  and  r-
Radyarn product is third party certified. 

- 

The US manufacturer Unifi is also understood to be used by major outdoor 
manufacturer Polartec who supplies fabric to brands such as Patagonia and 
the  North  Face.  Their  filament  fibre  content  is  manufactured  with  20% 

76  Thiele,  U.K.    Conversion  of  PET  bottle  flakes  to  added  value  products  –  quality  and  processing  criteria, 
Presentation made in Charlotte, USA, May 2003, http://www.polyester-technology.com/ 
77 Filature Miraglio, Newlife product, Accessed 2012, http://www.filaturemiroglio.com/eng/newlife.php 
78 Radici Group, r-Starlight – Post-consumer recycled polyester, Accessed 2012, 
http://www.radicigroup.com/starlightfibres/En/Products/Products_05.aspx 

41 

 
 
                                                        
recycled content and is third party certified79. Production capacity is quoted 
as approximately 14,000 tonnes/annum80. 

o  Chemically recycled content: As of 2013/14 and based on the available information 
and  stakeholder  input,  it  is  understood  that  there  are  only  two  manufacturers 
globally  –  Teijin  in  Japan  which  has  pioneered  the  technology  and  Hyosung  in 
Korea. The capacity of Teijin’s plant is 10,000 tonnes. Commentators suggest that 
investment  in  new  capacity  has  been  constrained  because  of  the  economies  of 
scale required to operate plant (>20-50,000 tonnes/annum). 

- 

Teijin’s  Eco  Circle  products  contain  100%  recycled  content  product 
manufactured from PET bottles and recovered polyester fibres81. 

-  Hyosung’s MIPAN Regen product is a 100% recycled content product and is 

third party certified by the Global Recycled Standard (GRS)82. 

Certification  systems  for  recycled  content  were  also  explored.  The  most  significant 
identified  was  the  Global  Recycle  Standard.  Their  list  of  certified  companies  as  of  June 
2012  included  18  manufacturers  of  polyester  filament  together  with  fabric  containing 
filament with a recycled content83. Locations include China, India and Taiwan. The recycled 
content  ranges  between  10  and  100%.  An  example  is  Libolon  in  Taiwan  which  has  a 
production capacity of 15,000 tonnes/annum84. Data obtained from GRS for the spread of 
recycled contents for GRS certified product is presented in Table 5. 

Table 5  Indicative recycled content 01/12 – 04/12 for GRS certified fibres 

Recycled content 

Proportion 
certified fibres 

of 

GRS 

100% 

75 – 99% 

50 – 74% 

26 – 49% 

5 – 24% 

74.1% 

2.1% 

6.7% 

12.6% 

4.5% 

Source: Control Union (2012) 

Other examples of certification include schemes established in EU Member States such as 
the  Seconda  Vita  scheme  in  Italy  85  and  the  Belgian  QA-CER  scheme86  as  well  as  private 
schemes  established  by  testing  bodies  such  as  Intertek’s  R-PET  management  system 
certification87.  The  organic  natural  fibre  certification  scheme  GOTS  also  includes  a 
requirement that any polyester fibre shall be of recycled origin88. 

Whilst the EN standard 15343 'Plastics recycling traceability and assessment of conformity 
and  recycled  content'  has  the  potential  to  provide  a  traceability  system  for  recyclate, 

79 Unifi, REPREVE product line, http://unifi.com/pdf/utsc_repreve_eng.pdf 
80 Textile News, UNIFI opens REPREVE recycling centre, May 2011 
HTTP://WWW.TEXTILEWORLD.COM/ARTICLES/2011/MAY/UNIFI_OPENS_REPREVE_RECYCLING_CENTER.H
TML 
81 Teijin Fibres Ltd, Eco Circle, http://www.teijinfiber.com/english/products/specifics/eco-circle.html 
82 Textile News, Hyosung’s Mipan Regen yarns net GRS certification, May 2009 
http://www.textileworld.com/Articles/2009/May/FW/Hyosung_Awarded_GRS_Certificate_For_Mipanx_regenx_Nylon_
And_Polyester_Yarns.html 
83 Textile Exchange, Companies certified to the Global Recycled Standard, Current as of June 2012. 
84  Libolon,  Polyester  chips  –  using  recycled  polyester 
http://www.libolon.com/polyester.php 
85 Italian Plastics Institute, Plastic seconda vita, http://www.ippr.it/il-marchio-psv 
86 QA-CER, QA-CER certification of the quality management system for recycling and production companies, Version 
1, January 2013 
87 Intertek, R-PET management system certification system, www.intertek.com 
88 Global Organic Textile Standard, http://www.global-standard.org/ 

to  create  new  polyester  yarn,  Accessed  2012 

42 

 
 
                                                        
consultation  with  EU  fibre  manufacturers  suggests  that  it  is  only  used  by  raw  material 
suppliers. Instead it is understood that many EU manufacturers of recycled polyester fibres 
verify  traceability  via  production management  and  raw  material  control using  ISO  14021 
and/or ISO 9000. This reflects the approach taken by QA-CER which is based on ISO 9000 
and EN 15343. 

The environmental improvement potential of recycled nylon 

Nylon  is  more  energy  intensive  to  manufacture  than  polyester.  This  energy  use  can  be 
traced  to  the  production  of  the  feedstock  caprolactam  (an  amine),  adipic  acid  and 
cyclohexanone  which  account  for  89.4%  -  92.4%  of  the  primary  energy  inputs  required, 
excluding feedstock energy. 

Recycling of nylon was pioneered by the carpet industry as part of a closed loop recycling 
services.  Nylon  can  be  recycled  by  mechanical  or  chemical  recycling  of  nylon  waste.  A 
comparative LCA study of virgin nylon and recycled nylon for carpet manufacturing carried 
out  for Shaw Carpets (2010)  and reviewed  by LBP-GaBi  University of Stuttgart  highlights 
the  significant  environmental  improvement  potential  of  recycled  nylon89.  This  is  because 
the production of the feedstock is avoided. 

The availability of nylon with a recycled content 

In order to understand the possible availability and quality specifications of nylon fibre with 
recycled content an attempt was made to identify EU and global manufacturers. Based on 
the best available information and input from stakeholders it can be seen that the number 
of  manufacturers  is  currently  limited.  The  following  fibre  products  have  been  used  in 
clothing products available on the EU market: 

o  Aquafil (Italy and Slovenia): The Econyl nylon 6 product is a 100% recycled content 
product90.  Pre  (70%)  and  post  (30%)  consumer  waste  is  used  as  feedstock.  The 
production capacity is understood to be 9,000 tons/annum, although the proportion 
of  recycled  product  is  unspecified.  In  2011  the  company  launched  a  nylon  textile 
take-back system. Feedstock includes used fishing nets. 

o  Hyosung  (Taiwan):  The  MIPAN  Regen  nylon  6  product  is  a  100%  recycled  content 
product and is third party certified by the Global Recycled Standard (GRS)91. Pre and 
post-consumer waste is used as feedstock. Data on production capacity  could not 
be obtained. 

o  Unifi  (USA):  The  REPREVE  nylon  6,6  product  is  manufactured  with  100%  recycled 
content and is solution dyed92. Pre and post-consumer waste is used as feedstock. 
Data on production capacity could not be obtained. The recycled content of the fibre 
is  third  party  certified.    In  2011  the  company  launched  a  nylon  textile  take-back 
option for industry production waste93. 

Consultation with a stakeholder who has experience specifying recycled nylon confirmed its 
limited  availability  and  higher  price.  Quality  issues  that  may  arise  from  the  use  of  nylon 
with a recycled content are not well documented and limited information could be obtained 
from stakeholders. An US review suggests that recycled nylon is available in a wider range 
of  deniers  than  recycled  polyester  and  that  dyeability  is  comparable94.  Information  on 
comparative mechanical strength and abrasion resistance could not be obtained. 

89 Binder, M, Albrecht, S, Marincovic, C, Flanigan, L and D,McGavis (2010) Life Cycle Assessment of Caprolactam 
production from Nylon 6 carpet recycling, http://www.lbp-gabi.de/refbase/files/49_Binder_etal2010.pdf 
90 Aquafil, The Econyl project, Accessed January 2013, http://www.aquafil.com/en/sustainability/the-econyl-project 
91 Hyosung, MIPAN Regen product, http://www.mipan.com/eng/products/regen.html 
92 Unifi, REPREVE product line, http://unifi.com/pdf/utsc_repreve_eng.pdf 
93 Unifi, Unifi Launches the REPREVE® Textile Takeback Program- Polartec to team up with Unifi in a first of its kind 
recycling program, http://unifi.com/un_news_pr.aspx?id=43 
94 Thiry, M.C. (2010) Everything old is new again – Recycling, recycled and recyclable fibres, AATCC review, USA 

43 

 
 
                                                        
Summary of stakeholder feedback 

Stakeholder comments on the proposals 

A  stakeholder  commented  that  tenderers  should  have  the  option  to  demonstrate  other 
environmental improvement activities, as is the case with the EU Ecolabel criteria. It is also 
not clear why other man-made fibres are not included. 

A requirement for antimony-free polyester was proposed by one stakeholder in addition to 
recycled  content.  The  availability  of  this  specification  should  be  checked.  It  was  claimed 
that  the  longer  timescales  for  procurement  would  give  suppliers  more  time  to  identify 
antimony-free suppliers. 

It  was  noted  that  the  certification  GOTS  includes  a  requirement  that  any  polyester  fibre 
used in a fabric (up to 30% by weight) shall be recycled. It should therefore be mentioned 
as being accepted or as equivalent. 

A  note  of  caution  was  raised  in  relation  to  the  recycling  of  polymers  that  may  contain 
hazardous  chemicals.  The  recyclability  of  synthetic  fibres  should  therefore  be  considered, 
with the US Cradle to Cradle scheme95 being proposed as a possibility.  

Final criteria 

Core criteria 

TECHNICAL SPECIFICATIONS 

Comprehensive criteria 

TS4. Polyester recycled content 

  Polyester  fibre  product(s)  to  be  used  in  fulfilment 
of  the  contract  must  be  manufactured  using  a 
minimum recycled content of 20 %. 

  Note:  Technical  issues  may  be  encountered  in 
meeting  other  quality  specifications  required  in  a 
contract.  This  should  be  taken  into  account  when 
evaluating  tenders  and  could  also  be  addressed 
through  market  enquiries  or  during  competitive 
dialogue (if used). 

  Verification: 

  The tenderer will upon award demonstrate that the 
production 
the  fibre  product  are 
dedicated to production with the minimum recycled 
content. 

line(s)  for 

Third party certification of the recycled content and 
its traceability will be provided for the production 
lines of the products to be delivered and the 
recyclate feedstock. ISO 14021, ISO 9001 or 
equivalent may be used. The verification will 
provide information in accordance with parts 4.4 of 
EN 15343. 

95 Cradle to Cradle products programme, http://www.c2ccertified.org/ 

44 

 
 
 
 
 
 
 
                                                        
AWARD CRITERIA 

AC2. Polyester and polyamide (nylon) recycled 
content 

Points  will  be  awarded  for  polyester  and/or  nylon 
fibre  product(s)  to  be  used  in  fulfilment  of  the 
contract  for  each  additional  increment  of  10  % 
greater than a  minimum recycled content of 20  % 
pre-consumer and/or post-consumer waste. 

Note:  Technical  issues  may  be  encountered  in 
meeting  other  quality  specifications  required  in  a 
contract.  This  should  be  taken  into  account  when 
evaluating  tenders  and  could  also  be  addressed 
through  market  enquiries  or  during  competitive 
dialogue (if used). 

Verification: 

The tenderer will upon award demonstrate that the 
production 
the  fibre  product  are 
dedicated to production with the minimum recycled 
content. 

line(s)  for 

Third party certification of the recycled content and 
its traceability must be provided for the production 
lines of the products to be delivered and the 
recyclate feedstock. ISO 14021, ISO 9001 or 
equivalent may be used. The verification must 
provide information in accordance with parts 4.4 
and 6 of EN 15343. 

AC3. Polyester recycling 

Points  will  be  awarded  to  tenderers  that  can 
demonstrate: 

that  the  design  of  the  final  textile  product 
facilitates ease of separation for polyester 
fabrics  at  the  end  of  a  product’s  service 
life; 
the  provision  of  a  voluntary  take-back 
route  for  the  textile  product  so  that  the 
contracting  authority  can  return  polyester 
fabrics to be recycled or reused. 

Verification: 

The tenderer must upon award: 

-  provide  details  of  the  design  measures  and 
features that will facilitate ease of fabric separation 
for recycling, and/or; 

- provide details of the take-back arrangements and 
a written commitment that extends in time to cover 
the end-of-life of the products. 

Summary rationale for the requirements and verification: 

o  Polyester  and polyamide (nylon)  are  understood  to be  by  far  the  most  commonly 

specified man-made fibres in public contracts. 

45 

 
 
 
 
  
  
 
o  The incorporation of recycled content into polyester and nylon fibres was identified 
during  revision  of  the  EU  Ecolabel  textile  criteria  as  the  measure  with  the  most 
significant  potential  for  life  cycle  environmental  improvement.  This  is  because  it 
avoids the manufacturing of virgin feedstock. 

o  Recycled polyester manufactured from PET drinks bottles is becoming common on 
the global fibre and textile market, although there are still issues relating to quality 
in some end-uses, for example with fibre strength for some applications and with 
military camouflage and uniforms where colour matching is important. Both staple 
and filament fibre can be specified with high recycled content. 

o  Recycled nylon is less common because of a limited supply of feedstock and there 

is less industry experience of its use in textile products. 

o  Given that recycled polyester fibre is more prevalent on the market it is proposed 
that the EU Ecolabel minimum requirement for filament fibre of 20% is used as a 
Comprehensive criterion. Whilst staple fibre with higher content is easier to source, 
it is considered that a 20% threshold would recognise that Contracting Authorities 
may not have prior knowledge as to whether staple of filament fibre will be used in 
products.  An  advisory  note  has  also  been  added  that  quality  issues  may, 
nonetheless, arise. 

o  Given the potential  for issues relating to quality at higher recycled contents –  for 
example, fibre strength, abrasion resistance and colour uniformity  - it is proposed 
that recycled content for higher contents of recycled polyester and for all recycled 
nylon are award criterion, with the 20% threshold used in the EU Ecolabel used as a 
starting  point  for  then  rewarding  further  increments  of  10%.  This  would  also 
recognise that recycled nylon is less prevalent in the market and that pricing may 
be higher. 

o 

It is important to ensure a clear and verifiable link between the subject matter – i.e. 
the textile products to be supplied – and the achievement of the recycled content. 
The  evidence  collected  suggests  that  fibre  manufacturers  produce  specific 
fibre/yarn lines using dedicated production lines. Verification is therefore proposed 
to focus on verification for the specific fibre or yarn product line. 

o  Certification and traceability of recycled feedstock can be achieved for a production 
site and related to a fibre product if there is a dedicated production line. Systems 
modelled  on  EN  15343  and/or  ISO  9000  are  currently  used  by  the  EU  synthetic 
fibre  industry.  Examples  include  Member  State  schemes  in  Italy  and  Belgium  and 
private schemes such as the Global Recycled Standard (GRS) and Intertek’s R-PET 
management system. 

o 

It is therefore proposed that verification is based on EN 15343 and, depending on 
their  availability,  Member  State  or  private  third  party  certification  systems. 
Whichever system is used it shall as a minimum address sections 4.1, 4.3 and 6 of 
EN  15343,  which  describe  the  basic  requirements  for  a  traceability  system  – 
control of input, recyclate characterisation and recycled content. 

o  The  recyclability  of  synthetic  fibres  is  an  important  consideration  for  the 
establishment  of  a  circular  economy.  An  additional  award  criterion  is  therefore 
proposed that would encourage closed loop systems, design for ease of separation 
of  fibres  and  accessories  at  the  end  of  service  life and/or  the  certification  of  the 
recyclability  of  fibres.  Only  polyester  is  proposed  to  be  covered,  as  this  has  been 
the focus of attention by industry. 

o  The  closed  loop  take  back  option  reflects  Teijin's  'Eco-circle'  scheme  to  which  a 

number of EU clothing manufacturers now form partners. 

46 

 
 
2.1.3 Chemical restrictions 

Textile  manufacturing  requires  multiple  production  stages  and  chemical  processes  to 
deliver  finished  products.  As  part  of  the  revision  of  the  EU  Ecolabel  textile  criteria  an 
extensive  review  of  chemical  restrictions  relating  to  different  processes  was  carried  out. 
This  review  sought  to  distinguish  between  hazardous  substances  that  are  of  concern  at 
different points in the product lifecycle: 

  Those that are of concern at production sites because they may be released to the 

air or water, and; 

  Those that are of concern because they may remain on the final product and during 
the use phase may expose the end-user or, as a result of washing, may be released 
into the aquatic environment. 

Substances from earlier processing stages such as oils applied to fibres during spinning and 
weaving  are,  according  to  the  textile  BREF  and  IMPRO  Textiles,  those  of  the  greatest 
significance in terms of the environmental  pollution of wastewater from production sites. 
However, it should be recognised that for GPP these production stages may be particularly 
challenging to verify as they may not be easily controlled by a final product manufacturer 
and may be difficult to trace along the textile supply chain. An indicative overview of the 
textile supply chain is presented in Figure 5. 

Figure 5. Indicative overview of the EU textile supply chain 

Source: AFIRM (2011) 

The  European  Commission's  Reference  document  on  Best  Available  Techniques  for  the 
Textiles industry (2003)96 additionally identifies the following substance groups of concern 
for water pollution: 

o  Akyl phenol ethoxylates (APEO's) surfactants 

o  PBDE and chlorinated paraffin flame retardants 

o  Process auxiliaries including EDTA, DTPA and NTA 

96 Joint Research Centre (IPTS), Reference documents, European Commission, 
http://eippcb.jrc.ec.europa.eu/reference/ 

47 

 
 
 
 
                                                        
o  Metal containing substances such as potassium dichromate 

o  Chlorine and chlorine releasing compounds such as hypochlorite bleach 

o  Potentially carcinogenic substances such as certain azo dyes 

o  Halogenated carriers used in dyeing 

All of these substance groups are addressed by the EU Ecolabel, with the lists of specific 
substances  updated  to  reflect  more  recent  prioritisation  of  substances  for  restriction  or 
authorisation under REACH. Volatile Organic Compounds (VOC's) are additionally identified 
as  being  of  concern  for  air  pollution,  particularly  the  following  which  are  associated  with 
so-called 'finishing' processes: 

o  Pigment printing pastes used in printing processes 

o  Cleaning processes that use organic solvents 

o  Heat treatments where the substances applied degrade or evaporate 

Substances  from  the  bleaching  (optical  brighteners),  dyeing,  printing  and  finishing  stages 
were identified by the EU Ecolabel revision process as being of the greatest significance in 
terms of chemicals that may remain on the final product. 

2.1.3.1 Substances to be tested for on the final product 

Technical background to the criteria proposal 

Substances that may remain on the final product can be readily grouped by their function, 
with  their  presence  on  the  final  product  varying  according  to  the  fabric  and  the 
specification  of  the  final  product.  Indicative  concentrations  for  substances  found  on  final 
textile products are presented by function group in Table 6 . 

Table  6  Indicative  concentrations  of  functional  and  residual  substances  on  final  textile 
products 

Functional group 

Dyes  

Concentration 
finished 
(% w/w) 

0.05 – 3.0% 

Aryl amines 

>30 ppm 

on 
product       

Technical notes 

Carriers 

0.1 – 1.0% 

Surfactants 

5.5 – 26.4 mg/kg 

Optical brighteners 

Up to 0.5% 

Softeners 

up to 3% 

Easy care 

Up to 8% 

Fluorocarbons 

0.3 – 8.0% 

The  concentration  will  depend  on  the 
strength  and  depth  of  colour.  Aryl  amines 
will  only  be  present  as  degradation 
products  of  certain  azo  dyes.  Printed 
patterns,  if  applied,  comprise  dyes  and 
pigments. 

May also include other printing and dyeing 
auxiliaries. 

Residual  concentrations  may  remain  from 
dyeing, washing and finishing. 

Added  during  pre-treatment  process 
stages. 

Added  during  washing  and  rinsing  before 
or after dyeing. 

Mainly  cross  linking  agents.  May  also 
include levelling and fixing agents. 

Coatings 
repellency. 

that  provide  dirt  or  water 

48 

 
 
Flame retardants 

1 – 20% 

Biocides 

5 ppm 

Reactive  coatings bonded  to  fibres.  The  % 
will depend on the weight of the fabric. 

Concentrations vary by application and can 
reach 100 ppm. 

Evidence  from  a  risk  assessment  of  textile  products  in  Germany  concluded  that  the 
concentrations and range of substances commonly found in final textile products generally 
pose  minimal  health  risks  to  the  consumer97.  There  are,  however,  some  combinations  of 
garments and substances that evidence suggests pose higher risks e.g. tight, skin contact 
garments coloured with allergenic disperse dyes. Poorly regulated production outside of the 
EU  can,  however,  result  in  greater  risks  of  exposure  because  substances  restricted  by 
REACH  or  classified  under  CLP  as  carcinogenic,  mutagenic  or  toxic  to  reproduction  (CMR) 
may be used or be present on the final product e.g. APEO surfactants remaining from the 
washing  of  fabrics,  azo  dyes  which  cleave  to  carcinogenic  aryl  amines,  formaldehyde 
remaining from finishing processes. 

There  is  evidence  from  EU  industry  associations  TEGEWA  and  ETAD98  that  in  the  EU  the 
textile  Industry  has  successfully  reduced  the  number  of  hazardous  substances  used  in 
textile formulations and recipes. This is particularly relevant to public procurement because 
in some cases, such as military wear, there may be a tendency to source textiles from EU 
production sites99. 

In  an  attempt  to  control  their  textile  supply  chains  leading  manufacturers  implement 
Restricted  Substance  Lists  (RSL’s).  RSL’s  are  generally  subject  to  due  diligence  which 
requires  a  combination  of  site  visits  and  the  sample  testing  of  final  products.  Sample 
testing tends to be carried out on a risk basis in order to minimise costs i.e. where evidence 
suggests that risk may exist in the supply chain of non-compliance and where the nature of 
the processes or chemistry  means that non-compliance is more likely to occur e.g. poorly 
controlled dyeing or finishing processes. 

A  number  of  Type  I  Ecolabels  include  criteria  that  are  based  on  final  product  testing, 
including  the  EU  Ecolabel  and  the  Blue  Angel.    Private  certifications  also  exist  that  are 
based  on  final  product  testing,  such  as  Oeko  Tex  100100  and  Made  in  Green101,  and  a 
combination of final product testing and production site standards, such as Oeko-Tex 1000 
(now  called  Sustainable  Textile  Production)102,  GOTS  and  Bluesign103.  Limited  data  was 
found  to  be  available  to  indicate  the  market  significance  of  these  private  certification 
schemes. It is understood that 125,000 Oeko-Tex 100 product certifications were awarded 
in  2013.  Feedback  from  stakeholders  underlined  their  significance  in  the  market,  with 
Oeko-Tex 100, for example, providing worldwide access to accredited laboratories that are 
familiar with the test methods used.  

Oeko  Tex  100  is  currently  referred  to  in  the  national  GPP  criteria  of  Austria,  Belgium, 
Denmark,  Netherlands  and  Sweden.  Feedback  from  a  limited  number  of  public  sector 
stakeholders  also  suggests  that  Oeko  Tex  100  is  actively  being  used  as  a  technical 
specification for textiles. This is because it offers a simple verification option, being based 
largely on the testing of the products to be supplied. 

97 Federal Institute for Risk Assessment, Introduction to the problems surrounding garment textiles, BfR Information 
No. 018/2007, 1 June 2007 
98 ibid 96 
99 See footnote 8 
100 Oeko Tex Association, Oeko Tex Standard 100, Accessed 2014, https://www.oeko-tex.com 
101 Aitex, http://www.aitex.es 
102  Oeko-Tex  Association,  Sustainable  Textile  Production 
tex.com/en/manufacturers/concept/sustainable_textile_production_step/step.xhtml 
103 Bluesign, The Bluesign system, Accessed 2014, http://www.bluesign.com/ 

(Step),  Accessed  2014,  https://www.oeko-

49 

 
 
 
                                                        
In the example of a procurement exercise by the French Navy specific limit values were set 
for  the  presence  of  four  chemicals  in  the  final  supplied  product  –  aromatic  amines,  azo 
dyes,  cadmium  and  formaldehyde104.  Oeko  Tex  100  certification  was  accepted  as 
verification, as well as equivalent test results from accredited laboratories. 

Candidate List 'Substances of Very High Concern' 

In the EU Ecolabel criteria a restriction is made on the presence of SVHCs identified under 
the  REACH  system  in  Europe.  A  threshold  of  0.1%  for  the  non-presence  of  SVHCs  is  set, 
reflecting the legal requirements for notification upon request by consumers under Article 
33(2) of the REACH Regulation, which manufacturers and their suppliers are familiar with 
as they are under a legal requirement to provide such declarations. 

A  practical  issue  faced  by  manufacturers  is  that  not  all  Candidate  List  substances  are 
relevant for textiles. Whilst suppliers must, according to the law, provide a notification of 
the presence of SVHC in articles placed on the EU market, it would be prohibitive to verify 
such a notification, because analytical testing would be required for all substances on the 
Candidate List, or at least those identified as being relevant to the product. It is therefore 
considered that at this stage only the act of providing the declaration would be required as 
a technical specification. 

Summary of stakeholder feedback 

Stakeholder comments on the proposals 

The overall stringency of the criteria addressing chemicals in the textiles was questioned by 
one  stakeholder.  They  should  be  stricter  as  they  only  refer  to  compliance  with  regulatory 
requirements.  Reference  was  made  to  the  approach  proposed  by  the  Swedish  Chemical 
Agency, which takes a more precautionary approach. 

The  testing  of  the  product  on  a  risk  basis  should  be  strengthened  by  referring  to  hazard 
classifications  as  used  in  the  EU  Ecolabel.  Moreover,  the  presence  of  SVHCs,  and  more 
specifically  CMRs,  should  be  restricted.  Information  is  available  because  declaration  by 
manufacturers is required under REACH Article 33. 

Dyes  that  are  Carcinogenic,  Mutagenic  or  toxic  for  reproduction  (CMR)  and  sensitising 
should be included within the scope of Annex 1 of the criterion. Metal complex dyes based 
on copper, chromium and nickel should also be added. There are already bans on their use 
in  many  textile  environmental  labels,  including  Bluesign  and  Oeko-Tex.  It  was,  moreover, 
queried why the restrictions are in some cases less strict than Oeko-Tex 100. 

The degradability of used auxiliaries and finishing agents  for fibres, yarns and fabrics, or 
the quality of the wastewater arising from these processes is not addressed. 

The proposed 16 ppm restriction on formaldehyde for skin contact products was considered 
by one workwear manufacturer to be too strict. It would make it technically very difficult to 
meet the requirements in criterion P5.1 for 'smoothness retention'. The lack of durability of 
alternative  resins  at  high  wash  temperatures  required  for  thermal  disinfection  was  also 
cited as a particular problem.  The 75ppm threshold used by  Oeko-Tex 100 was proposed 
instead. 

104 European Commission, Sustainable uniforms for the French Navy, GPP in Practice information sheet 

50 

 
 
 
 
                                                        
Final criteria 

Core criteria 

TECHNICAL SPECIFICATIONS 
(Same for core and comprehensive criteria) 

Comprehensive criteria 

The tenderer must declare the presence of any REACH Candidate List105 substances at a concentration 
of greater than 0.1 % (weight by weight) in the finished product. 

Verification: 

The  tenderer  must  provide  a  valid  REACH  Article  33(2)  declaration  upon  delivery  of  the  finished 
article(s). If Candidate List substances are declared as being present, they must be identified. 

(Same for core and comprehensive criteria) 

The  final  supplied  product  must  not  contain  the  substances  listed  in  Annex  1  at  greater  than  the 
individual  or  sum  total  concentration  limits.  This  must  be  demonstrated  by  laboratory  testing  of  a 
sample of each product type supplied during execution of the contract. The contracting authority will 
reserve the right to also request a further random check. 

Verification: 

Each  product  sample  must  be  analysed  by  a  laboratory  accredited  to  carry  out  the  relevant  tests 
according  to  ISO  17025  or  by  the  accreditation  body  for  a  textile  testing  scheme  that  requires 
product testing. Certificate(s) demonstrating compliance must be provided upon delivery of the goods. 

Where the test methods are the same, test results from valid Type I ecolabels, including the EU 
Ecolabel, as well as third-party textile testing schemes, must be accepted 106. 

Accompanying Annex 1 substance restrictions 

Substance group  Restrictions that shall apply 

1.1 Azo dyes 

Applicability: 

Clothing containing 
acrylic, cotton, 
polyamide and 
wool. 

1.2 
Formaldehyde 

Applicability: 

All clothing and 
interior textiles 
containing natural 
fibres. 

Azo dyes shall not be used that may cleave to 
aromatic amines that are known to be 
carcinogenic (see the listing provided in 
Appendix 2 of the EU Ecolabel 107). A limit 
value for aryl amines shall apply for the 
purpose of testing the final product. 

The following limit values apply to residual 
formaldehyde on the finished product: 

- 

Products for babies and children 
under 3 years old 

-  All other products 

Improved performance for skin contact 
garments could additionally be requested as 
an award criterion 108. 

16 ppm 

75 ppm 

Concentration 
limits 

30 mg/kg for 
each amine 

Test method 

EN 14362-1 
and 3 or 
equivalent. 

EN ISO 
14184-1 or 
equivalent. 

105 The REACH candidate list available at https://echa.europa.eu/regulations/reach/authorisation/the-candidate-list. 
106 At the time of writing the schemes Oeko Tex 100, Bluesign and GOTS are considered to provide a sufficient level 
of assurance. 
107  European  Commission,  EU  Ecolabel  textile  product  group,  http://ec.europa.eu/environment/ecolabel/products-
groups-and-criteria.html 
108 There may be a trade-off in terms of the quality and durability of stay press garments, particularly where garments 
are to be subject to high temperature washing.   

51 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
The following requirement can be applied as 
a Comprehensive criterion for interior 
textiles only: 

- 

Emissions from the final product 

0.1 mg/m3 

1.3 Auxiliaries 

Applicability: 

All products. 

The following substances shall not be present 
on the final product: 

-  Nonylphenol 
-  Octylphenol 

100 mg/kg sum 
total 

EN 16516 
and EN ISO 
14184-1 or 
equivalent 

Solvent 
extraction 
followed by 
HPLC/MS 

1.4 Coatings, 
laminates and 
membranes 

Applicability: 

Where 
incorporated into 
textile structure 

The following substances shall not be present 
on the final product: 

100 mg/kg sum 
total 

ISO 18254 

-  Nonylphenol ethoxylates 
-  Octylphenol ethoxylates 

Coatings, plastisol printing, laminates, 
membranes and plastic accessories shall not 
contain the following phthalates: 

Sum total 
0.10% w/w 

EN ISO 
14389 or 
equivalent. 

BBP (Butylbenzylphthalate) 

-  DEHP (Bis-(2-ethylhexyl)-phthalate) 
- 
-  DBP (Dibutylphthalate) 
-  DMEP (Bis2-methoxyethyl) phthalate 
-  DIBP (Diisobutylphthalat) 
-  DIHP (Di-C6-8-branched 

alkyphthalates) 

-  DHNUP (Di-C7-11-branched 

alkylphthalates) 

-  DHP (Di-n-hexylphthalate) 

Summary rationale for the requirements and verification: 

o  The presence of certain hazardous textile chemicals can be tested for on the final 
product,  providing  a  relatively  definitive  basis  for  verification  of  their  presence  or 
non-presence. 

o  EU textile manufacturers and brands are increasingly testing their final products for 
the presence of hazardous chemicals, providing their suppliers with restriction lists 
with  which  they  shall  comply.  These  so-called  Restricted  Substance  Lists  (RSL’s) 
consist  of  a  combination  of  final  product  testing  and  declarations  based  on 
production formulas. 

o  A  number  of  certifications  exists  for  final  product  testing,  with  the  most  widely 
used  being  the  Oeko  Tex  100  scheme.  This  scheme  is  referred  to  in  the  national 
green  procurement  criteria  of  at  least  five  Member  States  and  its  underlying 
substance restrictions are actively being used in tenders. 

o 

It is proposed that given the increasing use of final product testing in procurement 
and the potential ease of verification that a small number of final product tests are 
identified for inclusion as Core and Comprehensive technical specifications. 

52 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
o  Four tests for substances of high concern are proposed having been identified from 
the EU Ecolabel criteria and the EU textile BREF – azo dyes, formaldehyde, APEO’s 
and  phthalates.  These  are  proposed  to  be  listed  in  the  annex  of  the  criteria 
document. Moreover, the requirement relating to azo dyes is reflected in ISO 13688 
Protective clothing – general requirements. 

o  Reflecting current procurement practices Oeko-Tex 100 limits on free formaldehyde 
are proposed for skin contact products. An additional 'safety net' limit on emissions 
from interior products is proposed given the reclassification of formaldehyde as a 
Category 1B carcinogen. 

o  A  restriction  on  the  use  of  CMR  dyes  is  considered  to  be  more  appropriately 
addressed in the award criterion P3.3/Annex 2 because they are not routinely tested 
for by certifications such as the EU Ecolabel or Oeko-Tex 100. 

o  The  possibility  for  a  further  random  check  of  products  supplied  is  noted  in  the 

criterion, reflecting the practice of certifications such as Oeko-Tex 100. 

2.1.3.1 Restrictions on the use of substances to be verified by production sites 

Technical background to the criteria proposal 

As  it  has  already  been  identified  many  production  stages  raise  concerns  relating  to  the 
potential for pollution of air and water resulting from the wide range of textile chemicals 
used. Many of these substances are used in production formulas to pre-treat fabrics and to 
apply colours, coatings and prints, as well as to impart specific finishes and handle to the 
final product as specified by the client. 

In order to control the use of hazardous chemicals at these production stages verification 
invariably  must  take  place  at  the  production  site.  This  is  because  it  is  more  difficult  to 
systematically  trace  the  use  of  these  substances  on  the  final  product  or  to  use  this  to 
determine the extent to which the environment may have been exposed. 

The philosophy of Type I Ecolabels such as the EU Ecolabel and the Blue Angel, as well as 
private  certification  schemes  such  as  Bluesign,  GOTS  and  STeP  (Sustainable  Textile 
Production),  is  to  avoid  their  use  at  source  by  substituting  hazardous  chemicals  in 
production  formulas.  These  schemes  include  site  visits  to  verify  declarations  and 
management  systems  linked  to  compliance  with  Restricted  Substance  Lists.  EU  textile 
manufacturers  are  also  understood  to  regularly  carry  out  site  visits  to  production  sites, 
including those in the Far East, although the extent to which manufacturers are addressing 
environmental management cannot be substantiated. 

Feedback  from  public  sector  stakeholders  is  that  some  form  of  third  party  verification 
would  be  preferable  for  sub-contracted  production  sites  outside  of  the  EU.  In  contrast 
contractors  with  production  sites  located  in  the  EU  could  be  more  readily  visited  if  a 
concern  was  raised  about  compliance.  The  main  requirement  in  this  case  is  therefore  to 
ensure that if required the criteria can be verified by a public authority. 

In the revised EU  Ecolabel a link was made between the use of certain types of coatings 
such  as  repellents  and  flame  retardants  and  durability  of  the  function  they  provide.  This 
was with a view to minimise leaching of the coating to the environment during wash cycles 
and  to  extend  the  useful  life  of  the  product.  A  link  is  therefore  proposed  to  the  product 
criteria on durability. 

53 

 
 
 
 
Final criterion  

Core criteria 

AWARD CRITERIA 

Comprehensive criteria 

AC4.  Restrictions  on  substances  to  be 
verified at production sites 

Points  will  be  awarded  to  tenderers  who  restrict 
use of the substances listed in Annex 2 in dyeing, 
printing and finishing production processes for the 
supplied product(s). 

Verification: 

The  tenderer  must  provide  upon  delivery  of  the 
goods  a  valid  site  audit  report  carried  out  by  a 
third  party  verifying  the  production  formula  used 
at  the  dyeing,  printing  and  finishing  sites  for  the 
product.  The  audit  report  must  be  not  older  than 
two years and must include: 

findings  from  inspections  of  chemical 
stores  and  the  operation  of  production 
processes; 
confirmation  of  the  formulations  used, 
and; 
results  of  analytical  testing  (if  carried 
out) at each site. 

54 

 
 
 
  
  
  
 
 
 
 
Accompanying Annex 2 substance restrictions 

Substance 
group 

Restrictions that shall apply 

2.1 Dyes and 
pigments 

The following dyes and pigments shall not be used in 
textile production: 

Acid  Red  26,  Direct  Black  38,  Disperse  Blue  1,  Basic 
Red 9, Direct Blue 6, Disperse Orange 11, Basic Violet 
14,  Direct  Red  28,    Disperse  Yellow  3,  Pigment  Red 
104, Pigment Yellow 34 

2.2 Auxilliaries 

The following substances shall not be used in textile 
production: 

- 

- 

- 

bis(hydrogenated tallow alkyl) dimethyl 
ammonium chloride (DTDMAC) 
distearyl dimethyl ammonium chloride 
(DSDMAC) 
di(hardened tallow) dimethyl ammonium 
chloride (DHTDMAC) 
ethylene diamine tetra acetate (EDTA) 
diethylene triamine penta acetate (DTPA) 
4-(1,1,3,3-tetramethylbutyl)phenol 
1-Methyl-2-pyrrolidone 

- 
- 
- 
- 
-  Nitrilotriacetic acid (NTA) 

2.3 Bleaching 

Chlorine based bleaches shall not be used for the 
bleaching of any yarns, fabrics or knitted panels. 

2.4 Water, stain 
and oil repellent 
treatments 

Core requirement:  

Long  chain  (≥C5)  perfluoroalkane  sulfonic  acids  or 
sulfonates (PFSA) and (≥C7) perfluoroalkyl carboxylic 
acids or carboxylates (PFCA) substances shall not be 
used. 

Comprehensive requirement:  

Fluorinated water, stain and oil repellent treatments 
shall not be used, unless these functions are required 
in combination. 

In addition, for both Core and Comprehensive criteria 
the garment(s) shall be tested to be durable (see 
Criterion TS7) 

2.5 Waterproof  
membranes 

Fluoropolymer membranes and laminates used for 
outdoor clothing shall not be manufactured using 
PFOA or any longer chain fluorinated surfactants. 

Verification 
requirements 

Site audit at which the 
dyes used are to be 
identified. 

Site audit at which the 
chemical used as 
auxiliaries are to be 
identified. 

Site audit at which the 
bleaches used are to be 
identified. 

Site audit at which the 
repellents used for the 
finishes are to be 
identified. 

Site audit of the 
membrane/laminate 
supplier or 
documentation from a 
government regulatory 
body. 

55 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.6 Flame 
retardants 

Core requirement:  

The following flame retardants shall not be used: 

Site audit at which the 
flame retardants used 
are to be identified. 

HBCDD – Hexabromocyclododecane 

- 
-  DecaBDE – Decabromodiphenyl ether 
- 
TEPA – Tris(aziridinyl) phosphinoxide 
- 
TRIS – Tris (2,3 dibromopropyl) phosphate 
- 
TCEP – Tris (2,chloroethyl)phosphate 
- 
Paraffin, C10-C13, chlorinated (SCCP) 

Comprehensive requirement:  

Where fire protection is required the fabric shall be 
tested to provide a high level of durability (see 
Criterion TS7) 

Summary rationale for the requirements and verification: 

o  Production  formulas  to  achieve  color,  coatings  and  prints  as  well  as  finishes  and 
softness  of  the  fabric  require  a  range  of  textile  chemicals.  These  can  include 
hazardous substances, some of which may be in the process of being restricted or 
authorised under the EU‘s REACH system. 

o  The restriction of their use requires verification at production sites of the formulas 

and recipes used. 

o  Six  restrictions  have  been  identified,  one  related  to  dye  types  which  have  wide 
application,  two  which  can  be  applied  to  all  textile  products  –  auxiliaries  and 
bleaching  –  and  three  which  relate  to  technical  functions  of  fire  protection  and 
repellency (water, stain or oil). 

o  The  restrictions  are  based  on  the  EU  Ecolabel,  although  in  the  case  of  flame 
retardants  only  those  substances  not  yet  subject  to  REACH  restrictions  are  listed, 
and  in  the  case  of  repellents,  a  differentiation  is  proposed  to  be  made  between 
Core  and  Comprehensive,  given  that  non-fluorinated  repellents  would  be  too 
selective at the moment for the Core criteria. 

o  The  EU  Ecolabel  largely  relies  on  self-declarations  on  the  basis  of  Safety  Data 
Sheets  (SDS)  which  detail  the  chemicals  used  and  their  hazardous  properties. 
Concern about the assurance this form of verification would provide of compliance 
by production sites located outside of the EU suggests that third  party site audits 
should be considered. 

o  Whilst third party auditing is understood to be less prevalent in the market at the 
moment  there  are  an  increasing  number  of  certifications  that  require  this  (e.g. 
STeP,  Bluesign,  GOTS)  and  second  party  audits  are  regularly  carried  out  by  some 
major textile manufacturers. A number of the leading EU workwear manufacturers 
still  operate  their  own  production  sites  in  Europe,  potentially  making  audits  more 
affordable. 

o  On this basis it is therefore proposed that this criterion is made an Award criterion. 
This  would  recognise  that  third  party  site  audits  would  incur  additional  costs  and 
are not currently common practice. Only those tenderers offering this higher level 
of  assurance  would  acquire  extra  points.  Moreover,  it  is  proposed  to  link  the  fire 
protection  and  repellency  restrictions  to  a  requirement  for  such  treatments  to  be 
durable, thereby minimising loss to the environment during washing and extending 
the useful life of the product. 

56 

 
 
 
 
 
 
2.1.4 Durability and lifespan extension 

2.1.4.1 Durability standards 

Technical background to the criteria proposal 

JRC-IPTS's IMPRO Textiles LCA study highlighted the importance of extending the lifespan 
of  textiles  in  order  to  minimise  life  cycle  environmental  impacts.  The  importance  of  the 
relative durability and 'rate of use' of a product has also been highlighted by Kalliala and 
Nousiainen (1999). Their LCA analysis of towels and bed linen supplied as textile services 
found that an extended lifespan resulted in a 42% reduction in production-related impacts. 

In the UK a protocol is being developed to support decision-making on how to extend the 
lifespan of textiles109. Developed by WRAP in conjunction with Nottingham Trent University 
the 'longevity protocol'  has been developed based on wash cycle tests and user trials for 
basic  garments.  It  is proposed  as  a  point  of  reference  in  the UK's  draft  new  Government 
Buying  Standards.  The  protocol  includes  a  set  of  Core  test  performance  standards  which 
reflect some of the commonly used performance tests used by clothing manufacturers110. 
The following core tests are specified as result of the background study: 

o  Dimensional stability to washing and dry cleaning 
o  Colour fastness to washing, water/perspiration, light and rubbing 
o  Pilling 
o  Spirality 
o  Seam slippage 
o  Seam strength 
o  Fusible lamination 

Dimensional stability, colour fastness and pilling are already established tests for consumer 
items,  as  reflected  in  the  criteria  of  the  EU  Ecolabel.  Dimensional  stability  and  washing 
colour fastness are relevant for all forms of garments, although in some cases fastness to 
dry  cleaning  is  more  important.  For  uniforms  and  presentational  wear  colour  fastness  to 
perspiration and rubbing are of relevance to maintain their appearance. Tear strength and 
low seam slippage are also identified as being important111. 

ISO  13688  describes  general  requirements  for  workwear.  This  includes  performance 
benchmarks for dimensional change according to ISO 5077 (washing) after domestic and/or 
industrial wash cycles, as well as referring to ISO 3175-1 (dry cleaning). EN 471 describes 
general requirements for high visibility clothing and includes requirements on dimensional 
stability,  colour  fastness,  tensile  strength  (woven  fabrics)  and  bursting  strength  (knitted 
materials).  These  requirements  are  to  a  great  extent  mirrored  by  the  European  Textile 
Services Associations' requirements for workwear fabrics 112, which are focussed on cotton 
polyester blends to be washed under industrial conditions. These requirements additionally 
include crease recovery. 

A review of example tender documents, together with feedback from selected work wear 
manufacturers,  highlighted  the  specification  of  requirements  relating  to  dimensional 
stability,  appearance  after  washing,  abrasion  resistance,  tensile  and  tear  strength,  seam 
strength seam slippage and pilling. 

A literature search to identify technical literature that could inform a prioritisation of these 
additional new tests revealed a number of papers analysing work wear durability, including 
military clothing. Seam efficiency – a combination of fabric and seam strength – is referred 

109 A Clothing Longevity Protocol prepared by WRAP and Nottingham Trent University as part of the UK's Sustainable 
Clothing Action Plan was reviewed in draft form. See also WRAP, Design for longevity, May 2013 
110 Intertek (2012) Textile, apparel and garment testing, http://www.intertek.com/testing/apparel/  
111 See WRAP (2013) 
112 European Textile Services Association, ETSA requirements for work wear fabrics, 19th January 2011. 

57 

 
 
                                                        
to  as  having  been  used  for  many  decades  for  military  clothing.  Crow  and  Dewar  (1986) 
highlight that this may lead to over-specification of clothing, instead recommending seam 
strength based on the stresses to which the clothing is likely to be subjected. Bharani and 
Gowda  (2012)  highlight  the  importance  of  both  the  seam  material  and  the  fabric 
construction. 

The  proposed  coverage  of  the  criteria,  both  in  terms  of  product  types  and  performance 
testing, are specified in Table 7. The proposal is covering a range of different forms of work 
wear, together with bed  linen.  The test  methods and benchmarks are the specified in the 
draft Annex 3 matrix referred to in the criteria (see below). 

The  repellency  and  flame  retardancy  tests  are  understood  to  be  substantially  more 
expensive. These have therefore been made Comprehensive criteria that specialist suppliers 
would be required to meet. An exemption from these testing requirements was also given 
in  the  EU  Ecolabel  requirements  for  fabrics  which demonstrate 'inherent'  repellent  or  fire 
protection properties e.g. a polyester fibre has a phosphorus compound incorporated into its 
structure, giving it inherent flame retardancy113 or densely woven cotton that is as a result 
water repellent114. 

Table 7. Applicability of the textile durability performance requirements 

s
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Product type 

Tests applying to all products     
Towels and bed linen 

   

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r

i

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Uniforms and presentational 
work wear 

Heavy duty work wear and 
PPE for field operations 

       

   

   

Functional outerwear              
i.e. jackets, trousers, PPE 

   

   

Summary of stakeholder feedback 

113  Trevira,  How  Trevira  CS  works,  Accessed  2014,  http://www.trevira.com/en/textiles-made-from-trevira/home-
textiles/flame-retardant-textiles-trevira-cs/how-trevira-cs-works.html 
114 Ventile Fabrics, Accessed 2012, http://www.ventile.co.uk/ 

58 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                        
Stakeholder comments on the proposals 

A number of stakeholders considered the standard for abrasion resistance to be  too high 
based on the specified test method and do not take into account the weight of the fabric. 
Industry standard poly-cotton shirt material would be able to achieve up to 20,000 cycles 
and heavier poly-cotton up to 60,000 cycles. 

A stakeholder considered the number of wash cycles required for flame retardant articles 
to be too high. This will in practice depend on the application for the product. 

Limited  feedback  was  received  as  to  whether  an  award  criterion  could  be  specified  to 
encourage extended lifespans for products, for example to 25-50 wash cycles. 

Final criterion  

Core criteria 

TECHNICAL SPECIFICATIONS 

TS7. Durability standards 

(Same for core and comprehensive criteria) 

Comprehensive criteria 

The textile products must meet the relevant durability requirements identified in Annex 3. 

In the case of functional work wear that can demonstrate inherent performance characteristics that 
negate the need for water, dirt or stain repellents and/or flame retardant treatments to be applied to 
the textile fabric, the product will be exempted from testing requirements 3.7 and/or 3.8 in Annex 3. 

Verification: 

The tenderer will, for each distinct product design or item of work wear to be supplied, provide upon 
delivery of the goods reports from tests carried out in accordance with the standards specified in 
Annex 3. The reports will verify that each product type or model meets the specified durability 
requirements. 

59 

 
 
 
 
Accompanying Annex 3 durability test methods and associated performance benchmarks 

Core level of ambition 

Durability standard 

Performance benchmarks 

Test method(s) 

3.1 Dimensional change  Woven fabrics 

- Cotton and cotton mix +/- 3.0% 
- Wool mix +/- 2.0% 
- Synthetic fibres +/- 2.0% 
- Bed linen and towels +/-8.0% 

3.2  Washing 
fastness 

colour 

3-4 for colour change and staining 

3.3  Perspiration  colour 
fastness 

3-4  for  colour  change  and  staining,  4 
for  dark  colours  (standard  depth  > 
1/1) 

3.4  Wet  rubbing  colour 
fastness 

Level 2-3 

3.5 Tensile strength 

<50% cotton N/(g/m2)  2.0 
50% cotton N/(g/m2)  1.8 
Minimum performance 400 N 

3.6 Seam strength 

100 N at breakdown 

Comprehensive level of ambition 

3.7 Water, dirt and stain 
repellency 

To be applied as Comprehensive 
criteria only: 

The following retention of 
functionality after either 20 domestic 
cycles  at 40oC  or 10 industrial cycles 
at 75oC: 

- Water repellency: 80 out of 90 
- Oil repellency: 3.5 out of 4.0 
- Stain repellency: 3.0 out of 5.0 

Industrial  washing  temperatures  may 
be reduced to 60oC for garments with 
taped seams. 

3.8 Flame retardancy 

To be applied as Comprehensive 
criteria only:  

Washable products shall retain their 
functionality after 50 wash cycles 
(Comprehensive criterion). 

EN ISO 6330 (domestic washing) 
or  equivalent,  or 
ISO  15797 
(industrial 
or 
equivalent  in  combination  with 
EN  ISO  5077  or  equivalent  after 
3 washes. 

laundries) 

ISO  15797  or  equivalent  (where 
applicable)  in  combination  with 
ISO 105 C06 or equivalent 

ISO 15797 or equivalent (where 
applicable) in combination with 
ISO 105 E04 (acid and alkaline 
comparison with multi-fibre 
fabric) or equivalent. 

ISO  15797  or  equivalent  (where 
applicable)  in  combination  with 
ISO 105 X12 or equivalent 

EN  ISO  13934  (Strip  method)  or 
equivalent 

EN  ISO  13935  (Strip  method)  or 
equivalent 

ISO 6330 (domestic) or 
equivalent or ISO 15797 
(industrial) or equivalent in 
combination with: 

- Water  repellents:  ISO  4920  or 

equivalent 

- Oil  repellents:  ISO  14419  or 

equivalent 

- Stain  repellents:  ISO  22958  or 

equivalent 

ISO 6330 (domestic) or 
equivalent, or as relevant to 
the contract requirements EN 
ISO 10528 (industrial) or 
equivalent in combination with 
EN ISO 12138 or equivalent. 

60 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-washable products shall 
retain their functionality after a 
soak test. 

Where the textile is non-
washable and/or non-
removable the test method 
described in BS 5651, Section 4 
or equivalent shall be used 115. 

Summary rationale for the requirements and verification: 

o  Extending  the  lifespan  of  textile  products  is  important  to  minimise  their 
environmental  impact.  This  can  be  achieved  by  specifying  design  and  durability 
standards,  drawing  upon  the  extensive  range  of  textile  ISO  and  EN  standards 
available to support comparability and verification. 

o  Research  into  textile  durability  and  resistance  to  washing  and  drying  cycles 
suggests that standards can be addressed in three broad areas relating to 1) wash 
resistance, 2) physical durability, and 3) durability of function. 

o  A framework of standards has been put together using the EU Ecolabel fitness for 
use  criteria  as  a  starting  point,  cross  referenced  with  Member  State  and  industry 
standards for work wear and flat wear. 

o  Wash resistance has been identified by UK work on longevity standards for clothing 
as  an  important  factor,  with  dimensional  stability  and  colour  fastness  under  a 
range  of  conditions  being  already  having  been  specified  in  industry  guidance,  EN 
13688 and the EU Ecolabel. 

o  Physical durability is a more difficult area to set benchmarks because of the range 
of  different  textiles  products  and  end-uses.  Basic  requirements  relating  to  fabric 
and seam strength, as well as crease resistance, have been identified from industry 
guidance  and  literature.  These  are  only  to  be  applied  to  products  receiving  heavy 
wear. 

o  The durability of flame retardants and water, oil and stain repellent functions can 
be specified in order to extend the life of more costly and mission critical technical 
clothing items. Benchmarks for wash resistance have been set based on the revised 
EU Ecolabel criteria. 

o  Abrasion  resistance  has  been  omitted  because  no  current  industry  consensus 
appears  to  exist  on  benchmarks  for  performance,  which  would  need  to  reflect 
fabric  weight,  blend  and  intensity  of  use,  and  there  are  concerns  related  to  the 
possible choice of test methods. 

2.1.4.2 Availability of spare parts and accessories 

Technical background to the criteria proposal 

The  early  failure  of  closures  such  as  zips,  buttons,  velcro  and  fasteners  can  require 
expensive repairs or lead to the early discard of work wear and uniforms. This can be the 
result of poor quality, with early failure occurring as a result of wear and tear, or as a result 
of laundry conditions 116. For example, metal fasteners may rust, zips may seize up, elastic 
materials may not withstand laundry conditions. Zips in particular are understood to have 
high repair costs. 

115 This test method is based on that described in British Standard 5651: Method for cleansing and wetting 

procedures for use in the assessment of the effect of cleansing and wetting on the flammability of textile fabrics and 
fabric assemblies 

116 European Textile Services Association, ETSA requirements for work wear garments, February 2011 

61 

 
 
 
 
 
 
 
                                                        
No  more  specific  standards  or  guidance  for  the  specification  of  accessories  could  be 
identified,  so  a  focus  could  instead  be  placed  on  the  continued  availability  of  parts.  It  is 
understood  from  research  undertaken  on  the  corporate  work  wear  market  in  the  UK  that 
product planning might typically be based on a 2 year lifespan, with the potential to shift to 
3 years through better specification. 

Final criterion proposal 

Core criteria 

TECHNICAL SPECIFICATIONS 
TS8. Availability of parts and accessories 

(Same for core and comprehensive criteria) 

Comprehensive criteria 

The successful tenderer must make spares available of all parts and accessories (e.g. zips, buttons, 
fasteners) that form part of the products to be supplied for a minimum of two years after product 
delivery or the duration of the supply contract (whichever is the longest). An indicative price list for 
these parts and accessories must also be provided. 

Verification: 

The tenderer will upon award provide a written commitment to fulfil the requirement as part of the 
product warranty and an indicative price list for the inventory of parts. 

Summary rationale for the requirements and verification: 

o  The early failure of accessories can lead to high repair costs or the early discard of 

work wear and uniforms. 

o  Whilst no specific standards or guidance appears to exist it is proposed instead to 
require that spare parts are provided by suppliers for a minimum period of time in 
order  to  facilitate  repairs.  Two  years  is  proposed  for  the  Core  criterion  and  three 
years for the Comprehensive criterion. 

o 

In  addition  it  is  proposed  that  an  indicative  price  list  is  provided  in  order  to 
encourage more competitive pricing for parts and accessories. 

2.1.5 Energy conservation during use 

2.1.5.1 Fabric selection to minimise drying and ironing energy use 

Technical background to the criteria proposal 

Energy  use  for  washing,  drying  and  ironing  were  identified  by  JRC-IPTS's  IMPRO  textiles 
study as being associated with the most significant life cycle impacts of a textile product. 
This finding was based on domestic washing whereas in the public sector work wear and 
linen  may  be  washed  in  industrial  laundries  at  temperatures  greater  than  75oC.  Whilst 
evidence  suggests  that  even  though  industrial  laundries  operate  at  higher  temperatures 
they are still more efficient than domestic washing, the overall life cycle environmental and 
economic significance of industrial laundries is still greater than for product manufacturing. 

Industrial  laundry  surveys  highlight  that  the  processes  of  drying  and  ironing  account  for 
around  85%  of  the  energy  consumption  in industrial  laundry  operations,  as  illustrated  by 
Figure 6 117 The energy consumed in these processes is directly proportional to the amount 
of water remaining absorbed by a fabric after the process of mechanical extraction, usually 

117 The Carbon Trust (2011) Industrial energy efficiency accelerator – guide to the laundries sector, CTG 064, UK 

62 

 
 
 
 
 
                                                        
by  spinning118.  This,  in  turn,  is  a  complex  function  of  the  fibre  selection  and  the  fabric 
construction  and  weaving  process,  which  influence  the  fabric's  water  absorption  capacity 
and  wicking  properties  and,  consequentially,  the  amount  of  water  retained  after  spinning 
and the drying time. 

Figure 7. Sankey diagram of primary energy use in an indicative flatwear laundry 

Source: The Carbon Trust (2011) 

The  potential  to  specify  fabrics  in  order  to  save  energy  use  in  laundries  is  known,  for 
example as documented in the LCA study carried out by Kalliala and Nousiainen (1999) and 
is  actively  pursued  as  a  cost  saving  strategy  in  the  textile  service  sector.  Work  in  the 
laundry  sector  by  the  UK’s  Carbon  Trust  highlighted  the  use  of  energy  saving  fibres  and 
fabrics  as  the  second  most  significant  energy  saving  measure  out  of  the  six  major 
opportunities identified and of these it was the lowest cost measure119. 

The  potential  to  address  this  issue  within  the  GPP  was  therefore  further  explored,  with 
literature  and discussions with industry  stakeholders  suggesting that there  are  options  to 
specify criteria on: 

o  The water absorption of a fabric; 
o  Measure the drying time of a fabric; 
o  The incorporation of hydrophobic synthetic fibres into a fabric; 
o  Residual water in the fabric after spinning. 

Water  absorption  can  be  measured  but  would  prejudice  alternatives  to  cotton  such  as 
viscose which absorb more water but are claimed to have a shorter drying time because of 
the fibre structure. Whilst a shorter drying time is equated to less laundry energy use by 
some  fibre  manufacturers,  a  direct  correlation  could  not  be  identified  from  technical 
literature.  The  incorporation  of  hydrophobic  fibres,  in  particular  polyester,  has  become 
standard  practice  to  reduce  drying  and  ironing  energy,  but  because  the  blending  varies  a 
fibre specific threshold would need to be determined, which may be too prescriptive. 

This  leaves  the  last  and  preferred  option  –  the  water  remaining  after  spinning,  which  is 
specified  in  ISO  15797.  This  may  be  the  simplest  option  as  it  would  leave  the  choice  of 
fibre blend and fabric construction open to the bidder, although there may still be an issue 
for  man-made  cellulosic  fibres  which  are  claimed  to  still  retain  water  after  spinning  but 
because of their greater evaporative surface require less energy to dry than cotton. 

118  Kalliala,  E.M.,  and  P.  Nousiainen.  1999.  Life  cycle  assessment.  Environmental  profile  of  cotton  and  polyester-
cotton fabrics. AUTEX Research J. 1(1):8–20. 
119 See footnote 91 

63 

 
 
 
                                                        
The amount of ironing required to prepare a textile, and therefore the amount of additional 
energy use, will depend on the easy care properties of the fabric. Easy care can be achieved 
through fibre blends – for example, polyester cotton – or the application of a cross linking 
finishing treatments. The resulting smoothness, or retention, of appearance after washing 
and drying can be evaluated according to the EN ISO standard 15487, which establishes a 
rating based on expert comparisons against a reference fabric. 

Final criterion  

Core criteria 

TECHNICAL SPECIFICATIONS 

Comprehensive criteria 

TS9. Fabric selection to minimise energy use for drying and ironing 

(Same for core and comprehensive criteria) 

(For textiles that will be washed on a daily or weekly basis) 

The fabric will be selected to have a moisture retention content after spinning of less than 35 % and 
a  fabric  smoothness  grade  after drying  of  SA3  for  fabrics with  cotton  content  of  50  %  and SA4 
where the cotton content is <50 %. 

Verification: 

The  tenderer  will  upon  delivery  of  the  goods  provide  a  test  report  demonstrating  the  fabric(s) 
performance according to the following methods: 

-  moisture retention content: EN ISO 15797 (or equivalent) washing procedure. 
- 

easy care: EN ISO 15487 (or equivalent) appearance after washing and drying. 

Summary rationale for the requirements and verification: 

o  Energy use for washing, drying and ironing is associated with the most significant 

life cycle impacts of textile products. 

o  The energy required for drying can be minimised by fabric selection. This is because 
different  fibres  and  fabric  constructions  absorb  different  quantities  of  water, 
perform differently after spinning and have different drying times. 

o  Fabric  specification  to  reduce  laundry  energy  use  is  already  understood  to  be 
common in textile services providing work wear, towels and bed linen, with the use 
of polyester cotton blends representing a common practice. 

o  Options for specifying a criterion that is not prescriptive on the fibre or blend to be 
used  include  setting  requirements  on  water  absorption  capacity,  the  drying  time, 
the blending with hydrophobic fibres and residual water after spinning. 

o  The  preferred  approach  is,  based  on  the  laundry  procedures  in  ISO  15797,  to 

specify a maximum residual water content after spinning. 

o  The energy required for ironing can also be minimised by either chemical treatment 
or fabric blending, with the latter being more durable. It is proposed that a rating of 
a  fabric's  crease  free  appearance  after  washing  and  drying  is  specified  based  on 
EN ISO 15487 in order to minimise ironing requirements. 

64 

 
 
 
 
 
 
 
2.1.5.2 Care labelling textile maintenance 

Technical background to the criteria proposal 

As has already been highlighted energy use in the textile use phase is an important focus 
for environmental improvement. Whilst interior textiles and work wear may be washed in 
industrial laundries as part of managed services, particularly where hygiene requirements 
dictate the need for controlled washing conditions, the majority of work wear (95%) is 
understood to be washed, dried and ironed at home by employees in domestic conditions120. 

The JRC-IPTS IMPRO textile study modelled the improvement potential associated with 
measures in a domestic scenario121. 

  Washing:  Washing 

frequency, 

selected 

programme/options, 

programme 

temperature and load size; 

  Drying:  Drying  frequency,  selected  programme/options,  programme  temperature 

and load size; 

 

Ironing: Ironing frequency, ironing time and ironing temperature. 

Three measures were selected for further detailed modelling on the basis of the potential 
highlighted by literature – washing temperature, tumble drying frequency and optimised 
loading of washing machines and tumble dryers. Ironing was considered to be more readily 
influenced by the use of easy-care finishes and the introduction of fibre blends. Running 
full wash loads and reduced washing temperatures were reported to have the greatest 
improvement potential. 

Survey results used to inform the Ecodesign implementing measures for domestic washing 
machines suggests that there exists significant potential to reduce washing temperatures, 
although the potential varies across Europe and is not always consistent with climatic 
variations 122. The estimated average washing temperature in the EU 27 was estimated at 
the time to be 45.8oC, although 60oC was used for 23% of washes.  The average load was 
estimated as being 3.2 kg based on an average of 4.6 wash cycles per household per week. 
Figure 8 summarises temperature-setting choices for selected European countries. 

120 Simplified Life Cycle Assessment: Home washing and industrial washing of blue work wear, LCA report prepared 
for ETSA, 3rd June 2010 
121  JRC-IPTS  European  Commission,  Environment  Improvement  Potential  for  Textiles  (IMPRO),  Publication  draft, 
May 2012 
122 ISIS, Lot 14: Domestic washing machines and dishwashers, Preparatory study for Ecodesign, December 2007 

65 

 
 
 
                                                        
Figure 8 Temperature settings of domestic washing machines in European countries 

Source: ISIS (2007) 

More recently, in 2012, the European Textile Services Association (ETSA) commissioned GfK 
to carry out a survey looking at employee habits when washing work wear at home. This 
revealed the following, reflecting some of the issues highlighted by the 2007 survey: 

o  59% washed clothing in a partly loaded washing machine; 
o  51% did not follow the detergent dosing instructions of the machine 

manufacturers; 

o  35% did measure the amount of powder and/or liquid detergent; 
o  Between 30% and 40% were unaware of the energy class and consumption of 
their washing machine, while 60% to 70% did not know the energy class or 
consumption level of their dryer; 

In some of the countries surveyed, for example Germany, employees noted that their 
employer had provided guidance on work wear washing. In contrast to these general 
findings evidence, ETSA has highlighted that modern industrial laundries operate energy 
efficiently and optimise their use of detergent and water – as confirmed by their published 
member performance results. 

Tumble drying is, according to ISIS (2007), influenced by ownership levels, which on 
average were at the time 35%, and climatic conditions123. With drying being more costly 
because of the associated electricity use there is a greater incentive to make more efficient 
use of the machine and to line dry whenever feasible. Optimisation of washing machine or 
tumble drying loads is, to some extent, also influenced by perceptions of cleanliness and 
convenience. 

Whilst consumer research suggests that habits relating to perceptions of cleanliness are 
difficult to change, and that convenience and cost are also important factors, there is 
evidence that they can be influenced124. 

Final criterion proposal 

Core criteria 

Comprehensive criteria 

TECHNICAL SPECIFICATIONS 
TS10. Care labelling 

(Same for core and comprehensive criteria) 

(For textiles intended to be washed at home) 

The textile care labelling must promote washing at lower temperatures, if possible at 30oC or less 
and  using  the  washing  machine’s  low  energy  programme,  unless  there  is  a  technical  reason 
otherwise (e.g. hygiene, safety, soiling). 

Verification: 

The tenderer must provide examples of the care labelling and additional instructions to the user and 
provide,  if  applicable,  information  on  why  textiles  should  be  washed  at  higher  temperatures  than 
30oC. 

123 Price Waterhouse Coopers, Lot 16 - Ecodesign of dryers, Preparatory studies for Ecodesign requirements, March 
2009 
124  Fisher  T.,  Cooper  T.,  Woodward  S.,  Hiller  A.,  and  Goworek  H.  (2008)  Public  Understanding  of  Sustainable 
Clothing, A report to the Department for Environment, Food and Rural Affairs 

66 

 
 
 
 
 
 
                                                        
Summary rationale for the requirements and verification: 

o  Energy use for washing, drying and ironing is associated with the most significant 

environmental impacts along the life cycle of textile products. 

o  Evidence suggests that measures relating to washing have the greatest 

improvement potential, with running full wash loads and reduced washing 
temperatures identified specifically. 

o  Work wear may be washed at home where the age and efficiency of the washing 
machine and drying equipment may vary considerably. Survey results also suggest 
that  employees,  unless  provided  with  guidance,  may  not  always  follow  care 
instructions. 

o 

It  is  therefore  proposed  that,  where  applicable,  domestic  washing  instructions  on 
the  GINETEX  care  labelling  promote  lower  temperature  washing  unless  there  is  a 
technical  reason  not  to  do  so  –  for  example,  for  hygiene  purposes in  the  case  of 
health services. 

2.1.6 Design for re-use and recycling 

2.1.6.1 Design for re-use 

Technical background to the criteria proposal 

Research  in  the  UK  for  the  organisations  WRAP  and  the  Centre  for  Remanufacturing  and 
Reuse has highlighted that a key barrier to the re-use of uniforms and work wear are logos 
and  distinct  identification  features.  In  some  cases  these  pose  security  issues  if  the 
garments were to be re-used. In order to facilitate re-use these features of the work wear 
must therefore be readily removable without damaging the garment. 

The  variety  of  different  ways  in  which  logos  are  attached  or  imprinted  onto  garments 
makes it difficult to generalise as to the best design strategy. Embroidered and heat sealed 
logos  have  been  identified  as  being  particularly  problematic  because  they  may  require 
overprinting125. 

A case study of the UK Royal Mail Group's system for the preparation of old work wear for 
re-use  and  recycling  illustrates  some  of  the  practical  issues126.  A  team  of  operatives 
working  for  a  specialist  recycling  sub-contractor  remove  logos  by  cutting  them  from  the 
garment. This can result in significant damage to the garment, in which case it is placed in 
the recycling or disposal stream instead of the re-use stream. The unpicking of logos is too 
costly and can also damage the appearance of the garment. 

Final criterion  

Core criteria 

AWARD CRITERIA 
AC5. Design for reuse and recycling 

(Same for core and comprehensive criteria) 

Comprehensive criteria 

Garments  must  be  designed  so  that  any  logos  or  distinctive  identification  features  can  be  easily 
removed or overprinted without damaging the item. 

125 Uniform re-use project, Logo removal in corporate wear to enhance re-use potential, Centre for Remanufacturing 
and Re-use, February 2009 
126 Uniform re-use project, Case study: Royal Mail Group, www.uniform-re-use.co.uk 

67 

 
 
 
 
                                                        
Verification: 

The  tenderer  must  upon  delivery  of  the  goods  provide  clear,  easy  to  understand  instructions  for 
reuse contractors on how to remove or overprint logos or branding. 

Summary rationale for the requirements and verification: 

o  Logos  and  unique  identifiers  on  work  wear  and  uniforms  can  prevent  re-use  of 
garments, either for security reasons or because their design means they cannot be 
removed without damaging the garment. 

o  Overprinting can be a solution but is more costly and implies a planned preparation 
and  rebranding  of  the  garment.  This  option  is,  however,  recommended  as  the 
preferred option based on experience in the UK. 

o  Because  of  the  complexity  of  this  issue  it  is  proposed  that  it  is  addressed  as  an 
award criterion, with tenderers asked to demonstrate ease of removal or efficiency 
of overprinting for logos and/or identifiers. 

2.2 Textile service related criteria 
The procurement of textile services is gaining growing importance in the context of public 
procurement, both where the procurer retains the ownership  of the products,  e.g., laundry 
services, and where the textile products are owned by the service provider, i.e., renting. 

In both cases, significant environmental gains can be achieved  because such services can 
better  enable  the  correct management  of  the  most  relevant  parts  of  the  process.    These 
can include maintenance and repair of the asset stock, energy consumption during cleaning, 
drying and ironing, and end-of-life (with emphasis on collection for reuse and recycling).  

The potential role of textile services has gained increased importance following adoption of 
the European Commission's revised 'Circular Economy' package in December 2015 127. The 
Package  highlights  the  importance  of  addressing  the  whole  materials  cycle,  from  raw 
material  extraction  to  production  and  consumption,  including  product  lifetime  extension, 
through to waste management and the use of recycled (secondary) raw materials, with the 
aim of contributing to ‘closing the loop’ of product lifecycles through greater recycling and 
re-use.   

The following new set of criteria is therefore meant to promote the improvement potential 
of different aspects of textile services.One additional criterion on the environmental impact 
of  the  laundry  detergent  used  has  been  added  for  completeness  and  alignment  with  the 
current set of GPP criteria. 

2.2.1 Scope of the textile service criteria 

From  the  background  research  three  broad  areas  of  focus  regarding  environmental 
improvement can be identified in the context of textile services provision: 

o  For Laundry services: the potential for textile composition and labelling to minimise 
energy  use  was  already  highlighted  in  product  criteria  TS9  and  TS10.  The 
specification of textile composition to minimise laundry energy and detergent use 
and  competencies  in  managing  and  auditing  energy  consumption  at  production 
sites are considered to offer the most significant improvement potential. 

Relevant textile service criteria: TS1, AC1-2 

127  Communication  from  the  Commission  to  the  European  Parliament,  the  Council,  the  European  Economic  and 
Social  Committee  and  the  Committee  of  the  Regions  -  Towards  a  circular  economy:  A  zero  waste  programme  for 
Europe, COM/2014/0398 final 

68 

 
 
 
 
                                                        
o  For  Maintenance  services:  the  importance  of  extending  the  useful  life  of  textile 
products through adequate maintenance of garments and fabrics  was highlighted 
in  product  criteria  TS7  and  TS8.  These  areas  of  focus  remain  equally  valid  when 
textiles  are  managed  (whether  owned  or  not)  by  a  textile  service  provider. 
Therefore  competencies  in  the  field  of  extending  the  lifetime  of  contract  textiles 
and  minimising  waste  by  repairing  worn  or  damaged  products  are  fundamental. 
Tracking systems to manage  the inventory  throughout  its lifecycle  and  to identify 
common reasons for failure of fabrics or garments can be useful in this regard. 

Relevant textile service criteria: TS2 

o  For  Take-back  services:  the  importance  of  a  sound  end-of-Life  management  of 
textile products (namely ensuring either re-use or recycling) was initially highlighted 
in product criterion AC5. Service systems allow for much greater control of the end-
of-life phase for textiles. Competencies in designing tracking and collection systems 
(Take-back),  or  the  membership  of  a  Take-back  scheme,  are  fundamental  for 
facilitating  greater  re-use/recycling  levels  and  establishing  contracts  with  end-
markets. 

Relevant textile service criteria: TS3 

2.2.2 Selection criteria for tenderers 

It  is  proposed  that  competencies  associated  with  the  three  main  areas  of  textile  service 
improvement  potential  identified  in  section  2.2.1  are  reflected  in  the  Selection  Criteria.  
These would then be applied to each potential part of the textile service contract.     

Final criterion  

SC1. SELECTION CRITERIA 

SC1.  Providers of textile services 

SC1.  Providers of textile services 

Tenderers  must  be  able  to  demonstrate  the 
resources,  expertise,  documented  procedures 
and  management  systems  that  they  have  in 
place in order to address the following aspects 
of  the  services  to  be  provided  128:  (to  be 
selected as appropriate to the tender): 

Tenderers  must  be  able  to  demonstrate  the 
resources,  expertise,  documented  procedures 
and  management  systems  that  they  have  in 
place in order to address the following aspects 
of the services to be provided128: (to be selected 
as appropriate to the tender): 

 

For maintenance services: 

 

   The 

systems 

implementation  of  asset 
management 
for 
inventories  of  textiles.  This  will 
allow  for  data  and  feedback  from 
end  users  on  the  condition  and 
lifespan  of  the  textiles  to  be 
collected  on  an  ongoing  basis. 
These  systems  will  have  been 
actively  used 
the 
to 
frequency and causes of fabric and 
garment failure. 

identify 

   The  management  of  services  to 
repair  and  maintain  garments  and 
fabrics  in  order  to  maximise  their 
lifespan. 

implementation 

For  laundry  services:  at  laundry  sites 
the 
energy 
management systems according to ISO 
50001 or equivalent and including: 

of 

   staff 

training  and  awareness 

programmes at each site; 

   equipment and procedures at each 
site  in  order  to  maximise  process 
energy efficiency; 

   sub-metering  that  allows  for  the 
management  and 
reporting  of 
specific  energy  consumption  for 
the laundry processes and type of 
textiles  handled  at  each  site  (i.e. 
electricity,  gaseous  and 
liquid 
fuels  consumed  expressed  in  kWh 

128 The explicit possibility to require supply chain management capabilities was introduced by Part II (d) of Annex XII 
to Directive 2014/24/EU on public procurement, to be transposed into national law at latest by April 2016. 

69 

 
 
 
                                                        
Verification: 

Tenderers  must  confirm  that  they  have  the 
required  systems  and  capabilities.  Relevant 
examples  from  previous  contracts  must  be 
compiled. 

internal 
Moreover  they  must  describe  the 
resourcing,  management 
and 
infrastructure  that  will  be  used  to  manage 
compliance and provide the services. 

systems 

Where it is deemed appropriate, the contracting 
authority  reserves  the  right  to  carry  out  site 
visits  and  inspections,  or  to  request  third  party 
inspections,  in  order  to  confirm  the  tenderer’s 
capabilities. 

of 

kg 

textile 

products 
per 
processed,  assigned  to  processes 
used for flatware or work wear). 

 

For maintenance services: 

   The 

systems 

implementation  of  asset 
management 
for 
inventories  of  textiles.  This  will 
allow  for  data  and  feedback  from 
end  users  on  the  condition  and 
lifespan  of  the  textiles  to  be 
collected  on  an  ongoing  basis. 
These  systems  will  have  been 
the 
to 
actively  used 
frequency  and  causes  of  fabric 
and garment failure. 

identify 

   The  management  of  services  to 
repair and maintain garments and 
fabrics  in  order  to  maximise  their 
lifespan. 

 

For 
management) services: 

take-back 

(end-of-life 

   The 

systems 

implementation  of  asset 
management 
and 
infrastructure  that  support  the 
segregation  into  specific  different 
streams,  storage  and  sale  of 
specific 
textile  products  and 
fabrics  in  order  to  maximise  their 
reuse and recycling. 

   The  provision  of  design  advice  to 
contracting  authorities  in  order  to 
reuse  and 
facilitate  ease  of 
recycling.  The  provision of training 
in  how  to  segregate  end-of-life 
textiles 
the 
contracting authority. 

to  employees  of 

Verification: 

Tenderers  must  confirm  that  they  have  the 
required  systems  and  capabilities.  Relevant 
examples  from  previous  contracts  must  be 
compiled. 

Summary rationale for the requirements and verification: 

o  As  stated  before,  significant  environmental  gains  can  be  achieved  through  the 
correct  management  of the  most  relevant  parts  of  the  process: maintenance  and 
repair of the asset stock, energy consumption during cleaning, drying and ironing, 
and maximising value at the end-of-life (with the emphasis on collection for reuse 
and recycling). 

o 

In  the  absence  of  capabilities  in  process  management  focussing  specifically  on 
these areas, the service providers' ability to implement these measures, or provide 
for verification of implementation, may be impaired. 

70 

 
 
 
o  Therefore, it is requested at the selection stage that the tenderers demonstrate the 

technical capabilities described in the criterion above. 

o  Verification is to be based on a description of the bidder’s capabilities supported by 
the possibility of third party inspections and examples  of previous contracts . 

2.2.3 Asset management systems for textile services 

2.2.3.1 Maintenance of the textile assets  
Technical background to the criteria proposal 

In the context of textile renting services, it has been demonstrated (in LCA based studies, 
e.g., JRC-IPTS's IMPRO study  20 or Kalliala and Nousiainen (1999)  118 that the durability of 
the  products  used  will  have  a  determinant  influence  in  the  final  impact  of  the  service 
provided. In the context of textile services provision, a significant increase in lifespan can be 
obtained  through  basic  maintenance  operations  provided  that  an  asset  management 
system  is  in  place  that  allows  the  service  manager  to  keep  track  of  the  products  that 
require maintenance, e.g., reproofing or retreating of functional coatings. 

This criterion is of fundamental importance in the reduction of environmental impacts and 
understood to be commonly implemented by full service providers, who as a result are able 
to  minimise  replacement  costs.  Therefore,  it  is  suitable  for  both  core  and  comprehensive 
levels of ambition. 

Verification is straightforward, based on a simple description of the maintenance services 
offered, facilities available (with the support of photographic evidence) and description of 
previous track record in this field. 

Summary of stakeholder feedback 

Stakeholder comments on the proposals 

A  stakeholder  commented  that  there  does  not  appear  to  be  a  requirement  of  the  service 
provider  to  assist  contracting  authorities  to  reduce  environmental  impacts  on  an  ongoing 
basis as part of the service delivery. This could include the production of the textiles, their 
durability and associated packaging. 

Final criterion  

Core criteria 

TECHNICAL SPECIFICATION 

TS2. Maintenance of the textile assets 

(Same for core and comprehensive criteria) 

Comprehensive criteria 

This could also be combined with or formulated as an award criterion rewarding the most 
ambitious maintenance approach. 

The  tenderer  of  textile  services,  as  part  of  their  asset  management  plan,  will  extend  the 
useful life of workwear and interior textiles by providing ongoing maintenance and repair 
services. This will, as a minimum, include (as relevant to the textiles to be provided): 

   provision  of  basic  repairs,  including  repairing  seam  splits  and  stitching,  the 
replacement of broken/lost parts and the fixing/replacement of zips and fastenings; 
fabric panel replacement for workwear; 

71 

 
 
 
 
  
the retreating and proofing of functional coatings. 

Verification: 

The  tenderer  will  provide  a  detailed  specification  for  the  maintenance  services  offered 
including,  where  appropriate,  documented  evidence  from  the  maintenance  facilities  that 
they have under operation or under sub-contract arrangements. 

Summary rationale for the requirements and verification: 

o  This criterion intends to promote the increase of the useful life of the products used 

in the provision of the service. 

o  An  increased  longevity  of  the  products  will  reduce  their  replacement  rate  and, 
consequentially, reduce the impacts per annum associated with the provision of the 
service. 

o  As the 'maintenance of the textile assets' is considered to be one single service the 

criterion is the same  for both core and comprehensive part 

o  Verification is proposed as being based on a simple description of the maintenance 
services offered, facilities available (with the support of documented evidence) and 
description of previous track record in this field. 

2.2.3.2 Take-back systems  

Technical background to the criteria proposal 

As  stated  before,  significant  environmental  gains  can  be  achieved  through  the  correct 
management of the end-of-life process. Within this scope, and in the framework of textile 
service  provision,  emphasis  is  best  placed  on  the  collection  process,  either  for  reuse  or 
recycling. In order to implement a solid collection process, a take-back system should be in 
place. 

Indeed,  a  selective  collection  system that enables  a  swift  and  trouble–free  sorting  of the 
textile products that have reached their end of life is fundamental for managing the End-
of-Life environmental impacts of textile services. This will allow for the maximisation of the 
re-use and recycling of the said products. 

It is important to have this system in place both in the case that the contracting authority 
has the ownership of the products, or where the service provider retains ownership of the 
products associated with the service provision. However, it requires substantial investment 
to  put  in  place  such  a  system,  so  this  is  appropriate  only  for  comprehensive  level  of 
ambition. 

Examples of specialist contractors in the market include Berendsen (Denmark), Dimensions 
(UK), Fishers (UK), Iturri (Spain) and Textilian (Sweden). Asset management systems include 
the  use  of  unique  identifiers  and  bar  coding  for  all  items  issued  to  employees  and  the 
management of warehousing for storage, distribution and collection. 

Verification  can  be  based  on  a  simple  description  of  the  take  back  services  offered, 
facilities available (with the support of photographic evidence) and description of previous 
track  record  in  this  field.  Invoices  from  sales  of  recovered  textile  products  and  site 
inspections  can  provide  additional  verification  means.  The  extra  burden  on  the  service 
provider  associated  with  this  verification  is  better  suited  for  the  comprehensive  criteria 
level. 

72 

 
 
  
 
 
 
Final criteria  

Core criteria 

TECHNICAL SPECIFICATION 

Comprehensive criteria 

TS3. Take-back system  

This could also be combined with or formulated 
as  an  award  criterion  rewarding  the  most 
ambitious take-back approach. 

tenderer  as  part  of 

The 
their  asset 
management system must operate a take-back 
system,  or  have  formal  arrangements  with  a 
take-back scheme, for the textiles supplied for 
use within the contract, to include the following 
elements: 

collection  systems  installed  in  the  contracting 
authority’s  own  premises  to  facilitate  (where 
appropriate)  the  sorting  and  classification  of 
textiles; 

training  and  guidance  material  to 
ensure 
the  public 
authority  have  a  clear  understanding 
of how to use the system; 

that  staff  of 

   post-collection  sorting  activities 

in 
order  to  maximise  the  value  obtained 
from reuse or recycling. This will, at a 
minimum,  include  segregation  based 
on  fibre,  colour  and  condition  of 
garment. 

   The tenderer will provide an indication 
of  the  likely  end  markets  for  the 
textiles recovered. 

Verification: 

The tenderer must provide a description of 
including,  where 
the  proposed  system 
relevant, documentation for post-collection 
systems 
including 
specifications  for  sorting  lines  and  site 
photographic evidence. 

operate, 

they 

CONTRACT PERFORMANCE CLAUSE 

CPC2. Take-back system 

The  tenderer  must  report  on  the  performance 
of  their  take-back  system  in  accordance  with 
the following requirements: 

 

Surveys will be carried out of staff at 
the contracting authority’s facilities to 
determine how easy it has been to use 
the  collection/segregation  systems. 
These  will  be  carried  out  within  the 
first  six  months  of  the  services  and 
to 
the 

findings 

used 

73 

 
 
 
 
  
 
 
 

identify/implement 
improvement measures. 

potential 

textiles 

The  proportion  by  weight  of  the 
collected 
that  have  been 
reused or recycled and the associated 
value/kg of textiles obtained  from the 
destination end markets to which they 
are  sent  will  be  determined  and 
recorded on an annual basis. 

The  tenderer  will  provide  a  short  summary  of 
the  staff  survey  findings  and  the  potential 
improvement  measures  identified.  An  annual 
the 
report  providing  a  breakdown  of 
destination  of  the  textiles  and  the  value 
obtained  from  each  end  market  will  be 
provided. 

Summary rationale for the requirements and verification: 

o  Significant environmental gains can be achieved through the correct management 

of the end-of-life process. 

o 

o 

o 

In  the  framework  of  textile  service  provision,  emphasis  is  best  placed  on  the 
collection process, either for reuse or recycling. 

In order to implement a solid collection process, a take-back system should be in 
place. This will allow for the maximization of the re-use and recycling of the said 
products. 

It is important to have this system in place both in case the contracting authority 
has ownership of the products, and where the service provider retains ownership of 
the products associated with the service provision. 

o  Verification can be based on a simple description of the take back services offered, 
facilities  available  (with  the  support  of  photographic  evidence)  and  description  of 
previous track record in this field. 

o  A  contract  performance  clause  is  proposed  focussing  on  two  aspects  of  service 
delivery: 1) surveying of employee's experience of using the collection system and 
identification of potential for improvement, and 2) on the proportion by weight of 
the  textiles  sent  for  disposal,  re-use  or  recycling  and  the  value/kg  obtained  from 
the end-markets to which they are sent. 

74 

 
 
 
 
 
 
2.2.4 Fabric selection to minimise drying and ironing energy use 

Technical background to the criteria proposal 

Please refer to product-related criterion TS7 in Section 2.1.4.1 for the background for this 
criterion proposal. 

Final criterion proposal 

Core criteria 

Comprehensive criteria 

TECHNICAL SPECIFICATION 

TS1.  Fabric  selection  to  minimise  energy 
use for drying and ironing 

TS1.  Fabric  selection  to  minimise  energy 
use for drying and ironing 

(For textiles that will be washed on a daily or 
weekly basis) 

(For textiles that will be washed on a daily or 
weekly basis) 

The textile fabrics shall be selected to have a 
moisture retention content after spinning of 
less than 35% and a fabric smoothness grade 
after drying of SA3 for fabrics with cotton 
content of 50% and SA4 where the cotton 
content is <50%. 

The textile fabrics shall be selected to have a 
moisture retention content after spinning of 
less than 35% and a fabric smoothness grade 
after drying of SA3 for fabrics with cotton 
content of 50% and SA4 where the cotton 
content is <50%. 

Verification: 

Verification: 

The  tenderer  shall  provide  a  test  report  
demonstrating  the  fabric(s)  performance  in 
accordance with the following methods: 

The  tenderer  shall  provide  a  test  report  
demonstrating  the  fabric(s)  performance  in 
accordance with the following methods: 

(or 

  Moisture  retention  content:  EN  ISO 
equivalent)  Washing 

15797 
procedure 
Easy 
(or 
equivalent)  Appearance  after  washing 
and dying 

ISO  15487 

care:  EN 

 

(or 

  Moisture  retention  content:  EN  ISO 
equivalent)  Washing 

15797 
procedure 
Easy 
(or 
equivalent)  Appearance  after  washing 
and dying 

ISO  15487 

care:  EN 

 

Summary rationale for the requirements and verification: 

Please  refer  to  product-related  criterion  TS7  in  Section  2.1.4.1  for  the  rationale  for  this 
criterion proposal. 

2.2.5 Laundry energy and detergents use 
Technical background to the criteria proposal 

Energy consumption in the use phase is a source of major environmental impact in textiles 
life  cycle,  as  was  identified  by  JRC-IPTS's  IMPRO  Textiles  study  20.  When  textiles  services 
are the focus of interest, and whether the service provider owns or not the products, this 
aspect  assumes  a  particular  relevance  since  the  service  provider,  and  by  extension  the 
contracting  authority  for  the  service,  may  be  able  to  exert  direct  control  over  the  energy 
used in the use phase of the product. 

Data  collated by the  Carbon  Trust  as  part  of  an  initiative to  support the laundry  industry 
illustrates how the specific energy consumption difference between laundry sites that are 
streamlined from an energy point of view and others that are not (mainly smaller facilities) 

75 

 
 
 
 
 
 
 
 
 
 
 
can  be  significant  (see  Figure  9),  which,  compounded  with  the  intensity  of  laundering 
operations can result in large variations in overall energy consumption.  The data suggests 
that  there  can  be  up  to  a  factor  of  five  or  six  difference  between  the  best  and  worst 
performing sites.  

The Carbon Trust also illustrate how sub-metering of discrete processes, such as drying, as 
well as associated process machinery lines, such as tunnel finishers, can be readily used to 
accurately  monitor  energy  use.  Moreover,  they  also  highlight  that  sites  tend  to  handle 
laundry  on  an  accurately  sorted  and  weighed  batch  basis  for  specific  types  of  laundry, 
grouping them into flatware (towels and linen), work wear and healthcare. 

Figure 9  Specific Energy Consumption (SEC) of industrial laundry sites 

Source: The Carbon Trust (2011) 

However,  a  large  proportion  of  the  possible  energy  performance  optimisation  measures 
that  can  be  implemented  are  rather  straightforward  to  carry  out.  Equipped  with  nothing 
more than concern for the subject, basic book keeping practices, accurate metering and a 
mind-set focused on continuous improvement, a manager of a laundry site can go a long 
way in terms of energy savings 117. 

The new ISO 50001 standard applies the principles of continuous improvement to energy 
management.  If  an  energy  management  system  along  those  lines  is  implemented, 
significant  energy  savings  could  be  realised.  In  addition  to  that,  half  hourly  metering, 
control systems for laundry equipment and heat recovery are identified as basic measures 
to  achieve  energy  savings  that  should  be  implemented  at  all  sites.  There  are,  however, 
several additional energy saving measures that could also be implemented and that would 
result in a further improvement of the site's energy efficiency 117. 

The  proper  energy  management  of the  site  and  the  use  of  appropriate textile  products  – 
both of which are covered either in the selection criteria or in the technical specifications - 
will,  in  the  end,  be  reflected  in  a  decreased  overall  specific  energy  consumption  of  the 
laundry facility.  Therefore it is reasonable, fair and beneficial  to reward laundries that do 
so. 

There  is  however  a  trade-off  between  energy  consumption  (which  can  be  decreased  by 
lowering the washing temperature of the products) and the amount and aggressiveness of 
detergent use (use more detergent, or a more aggressive detergent, in order to compensate 
the lower washing temperature). Therefore a risk arises that if an award criterion is set on 
energy  consumption  alone  this  could  provide  an  undesirable  incentive  to  increase  the 
environmental  impacts  associated  with  detergent  use  (mainly  aquatic  toxicity  effects, 
according to JRC-IPTS's IMPRO Textiles study 20). 

76 

 
 
 
An  additional  risk  relates  to  the  persistence  of  the  detergent  products  in  the  aquatic 
environment, being desirable that the product degrades in as short an interval of time as 
possible, therefore, it  is  considered  appropriate  to include  criteria  on  both  aquatic toxicity 
and biodegradability. 

Taking into consideration all of the above, we propose a set of three award criteria  and a 
contract  performance  clause  that  are  designed  to  work 
in  tandem,  rewarding 
simultaneously low energy use, low detergent use and the use of environmentally friendly 
detergents.  The  objective  of  this  proposed  approach  is  to  address  the  aforementioned 
trade-off between environmental impacts associated with energy and detergent use. 

The  award  criterion  is  proposed  as  comprising  criteria  addressing  energy  use  and  the 
environmental impact of detergent use. A contract performance clause would then enforce 
compliance with commitments made by bidders. 

Summary of stakeholder feedback 

Stakeholder comments on the proposals 

A stakeholder commented that metering of  water consumption was not addressed within 
the  scope  of  the  criteria.  It  was  proposed  that  attention  should  be  focussed  on  also 
managing and reducing water consumption as part of the processes. 

Final criteria  

Core criteria 

AWARD CRITERIA 

Comprehensive criteria 

Guidance note on laundry energy and detergent use 

It  is  recommended  to  combine  the  criteria  on  energy  consumption  and  detergent  environmental 
impact and to weigh the total points awarded on the following basis: 

   Criterion AC1: Energy consumption, 75% 
   Criterion AC2: Detergent environmental impact, 25% 

 Monitoring shall be carried out according to contract performance clause CPC1. 

AC1. Specific energy consumption 

Tenderers  will  be  awarded  points  according  to 
the  proposed  specific  energy  consumption  in 
kWh  (electricity  plus  gaseous  and  liquid  fuels) 
per kg of flat wear and work wear textile product 
washed, dried and finished (as appropriate) that 
will be achieved during provision of the service. 

The points will be awarded in linear proportion to 
the proposals received, from the lowest (100  % 
available points) to the highest (zero points). 

Verification: 

The  tenderer  will  provide  specifications  for  the 
sub-metering  of  each  washing,  drying  and 
finishing  process  line,  distinguishing  between 
flat  wear  and  work  wear,  that  will  be  used  in 
providing the service. They will also describe the 
arrangements  for  verification  of  the  sub-meter 
readings. 

77 

 
 
 
 
CONTRACT PERFORMANCE CLAUSE 

AC2. Detergent environmental impact 

Tenderers will be awarded points if they commit 
to  the  use  of  detergents  in  execution  of  the 
contract  that  meet  the  aquatic  toxicity  and 
biodegradability  criteria  of  the  EU  Ecolabel  for 
Institutional  Laundry  Detergents  or 
their 
equivalent. The criteria can be found here: 

http://ec.europa.eu/environment/ecolabel/product
s-groups-and-criteria.html 

Tenderers  making  the  commitment  will  be 
awarded the maximum available points. 

Verification: 

The tenderer must provide details of the system 
of  verification  to  be  used  for  the  purchase  of 
compliant  detergents  for  use  in  the  individual 
washing  process  lines  that  will  provide  the 
service. 

CPC1.  For  textile  services  that  include 
laundering 

The  successful  tenderer  must  carry  out  the 
services  according  to  the  proposed  specific 
energy  consumption  and  compliant  detergent 
use which it committed to in its tender. 

The  tenderer  must  provide  the  following  forms 
of verification: 

   monthly  metered  energy  consumption 
data aggregated from the  sub-metered 
process lines at  related  sites,  reflecting 
the  fabric  type/weight  and  divided  by 
the weight of textiles processed; 
copies  of 
for  detergent 
purchases  together  with  proof  that  the 
detergent(s) either: 

invoices 

i. has the EU Ecolabel; or,
ii. has a Type I ecolabel which contains

equivalent criteria; or,

iii. meets  the  specified  EU  Ecolabel

criteria 129.

   Proof  must  comprise  valid  Ecolabel 
licences  and/or  third  party  verified  test 
data for the detergents used. 

The  contracting  authority  reserves  the  right  to 
request  third-party  verification  at  any  point 
during  the  contract  and  the  contractor  will  be 
obliged to provide this at their own expense. 

129 

European 

Commission, 

Industrial 

and 

Institutional 

Laundry 

Detergents, 

http://ec.europa.eu/environment/ecolabel/products-groups-and-criteria.html. 

78 

  
Summary rationale for the requirements and verification: 

o There  can  be  a  factor  of  between  five  and  six  difference  in  the  specific  fuel  and
electricity consumption between laundry sites that are streamlined from an energy
point of view and others that are not.

o A  basic  energy  management  system  developed  along  the  lines  of  a  continuous

improvement strategy can go a long way in terms of energy savings.

o Several energy saving measures can be put in place in addition to the basic ones
that are the subject of technical  specifications (energy management systems and
appropriate  choice  of  textile  products).  These  will  be  later  reflected  in  the  overall
specific energy consumption of the laundry facility.

o Award  criteria  are  proposed  based  on  laundry  energy  use  and  the  environmental

performance of the detergent in terms of aquatic toxicity.

o Verification is proposed as being based on a combination of energy management
system  records,  detergent  purchase  invoices  and  detergent  licenses  and/or  test
data, supplemented by (on request) third party verification of energy and detergent
use at the contractors expense.

o Verification of energy and detergent use would need to be provided at the level of
the  individual  process  lines  at  each  site  used  to  provide  the  textile  service.  This
would  require  sub-metering  and  detergent  records  for  batches  of  laundry  put
through individual process lines.

79 

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ISBN 978-92-79-70109-2 

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