Opinion of the European Committee of the Regions on the EU Strategy for Sustainable and Circular Textiles
Date: 2022-11-30
Institutions: Commission for the Environment, Climate Change and Energy, European Committee of the Regions
Subjects: EU strategy, circular economy, clothing industry, environmental impact, product life, sustainable product, textile product, value chain, waste, waste recycling








C_2023079EN.01001701.xml










2.3.2023   


EN


Official Journal of the European Union


C 79/17






Opinion of the European Committee of the Regions on the EU Strategy for Sustainable and Circular Textiles
(2023/C 79/04)












Rapporteur:


Luca MENESINI (IT/PES), President of the Province of Lucca (Tuscany)





Reference document:


Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions — EU Strategy for Sustainable and Circular Textiles
COM(2022) 141









POLICY RECOMMENDATIONS

THE EUROPEAN COMMITTEE OF THE REGIONS,








1.


welcomes the cross-cutting approach of the EU Strategy for Sustainable and Circular Textiles, which aims to create a coherent framework and vision for the textile sector’s transition, in line with the objectives of the European Green Deal, the Circular Economy Action Plan and the European Industrial Strategy;












2.


looks forward to the finalisation and publication of the roadmap for the green and digital transition of the entire textile ecosystem;












3.


acknowledges the urgency of ensuring that textile products placed on the EU market are long-lived and recyclable and, to a great extent made of recycled fibres, free of hazardous substances and produced in respect of social rights and the environment; calls for a paradigm shift in the fashion industry to end overproduction and the excessive consumption of clothing;












4.


draws attention to data from the European Environment Agency (EEA) showing that, from a consumption point of view, over their life cycle, textiles have on average the fourth highest negative impact on the climate and the environment, after food, housing and mobility (1). In 2020, textiles were responsible for the third highest impact on water and land use and the fifth highest for the use of raw materials and greenhouse gas emissions;












5.


underlines the importance of the textile, fashion, leather and footwear sector in European industry, which employs more than two million workers and is a driver for employment, economic development and innovation in the regional ecosystems in which it is present; considers it a priority to move from an extractive, linear production system to a regenerative, circular model; believes the role of local and regional authorities to be crucial in this transition, in particular of (a) municipalities and local actors such as social enterprises, collectors and civil society organisations with regard to collection, repair and reuse systems, (b) regions through their support to municipalities in their tasks, and (c) the public and private sectors as a driver for research and innovation processes;












6.


recognises that extended producer responsibility (EPR) has proved effective in improving the separate collection of waste and its subsequent management in line with the waste hierarchy; calls on the co-legislators to determine which textile products fall within the scope of application of the Directive and EPR system at EU level, targeting the high costs of disposing of ‘fast fashion’;












7.


welcomes the fact that the separate collection of textiles will be mandatory for all waste producers by January 2025. Also expects that the revision of the Waste Framework Directive planned for 2024 will consider specific targets for textile waste prevention, and textile reuse and recycling, and that the key role of local and regional authorities will be taken into consideration;





Rethinking consumption patterns









8.


points out that global textile production almost doubled between 2000 and 2015. As clothing comprises the largest share of EU textile consumption (81 %), the trend of using garments for ever shorter periods before throwing them away is the biggest contributor to unsustainable patterns of overproduction and overconsumption;












9.


would like to see the ever wider roll-out of methods for promoting the conscious and sustainable use of textile materials, particularly with regard to specific types of clothing, such as coats or children’s clothes, which are more likely to be discarded by consumers before the end of their useful life. Such initiatives, such as swap schemes, fashion libraries and awareness-raising campaigns, face different barriers linked to prejudices surrounding used clothing, in terms of quality, hygiene or the diversity of products;












10.


highlights the need to step up the search for innovative solutions (machines, equipment, digital platforms) for sorting, reusing and recycling collected textile waste, and for optimising the behaviour of materials;












11.


points out that market demand for circular products and services is still insufficient and constitutes a major obstacle to the implementation of circular business models; encourages national, regional and local authorities to spur on a shift in patterns here by rolling out tools to support the adoption of business models based on a culture of use rather than ownership, establishing rules on the transport and trade of textile products (including waste streams) and promoting regulatory incentives (for example VAT reductions or applying the EPR principle) to encourage renting rather than purchasing, sharing platforms, take-back services, resale and second-hand shops, while promoting a renewed enthusiasm for repair, upcycling and maintenance; recognises, moreover, that these business models can have a positive impact on environmental sustainability performance in the health, tourism, construction and other key public service sectors;












12.


welcomes the initiative on empowering consumers for the green transition (2) and the resulting EU rules which will ensure that consumers receive information at the point of sale on a commercial guarantee of durability for textile products, as well as relevant information on their repairability; encourages the Commission to continue working on minimum criteria for all types of environmental claims in the context of the Green Claims initiative (3);





Making design for circularity a widespread reality









13.


recognises that design for greater durability can extend the life cycle of textiles, clothing, leather and footwear (TCLF sector), thus reducing textile waste and the overall use of virgin materials and chemicals; welcomes the Commission’s work on developing binding product-specific ecodesign requirements to increase the performance of TCLF-sector products in terms of durability, reusability, repairability, fibre-to-fibre recyclability and mandatory recycled fibre content;












14.


strongly advocates the need for common sustainability standards, which are considered essential for involving brands in the assessment of the environmental impacts of their products;












15.


welcomes the aspects of the Strategy on clearer information on the circularity of the TCLF sector and on a digital product passport based on mandatory information requirements on circulatory and other environmental aspects; calls on the Commission to make the Digital Product Passport (DPP) available to all stakeholders and consumers, and to include information on labour conditions and on how to repair and reuse the products;












16.


considers that the following principles should be followed when establishing minimum requirements for TCLF products, and that the aim should be to improve overall environmental performance throughout the life cycle:






a)



guarantees on the minimum durability of the product and on compliance with minimum durability requirements, and clear, ambitious and mandatory targets for reuse and preparation for reuse;










b)



guarantees on repairability and modularity, including specific metrics to assess ease of non-destructive disassembly and to verify that the essential parts of the products are easily replaceable and repairable;










c)



guarantees on recyclability, including restrictions on combinations of different materials, chemicals, dyes and finishes that are not compatible with recycling, and the possibility to promote products for which a mature recycling technology already exists;










d)



guarantees on sustainably and ethically sourced materials, provided that they are used for a longer lifespan and are recyclable, in order to reduce the volume of virgin synthetic fibres produced from fossil fuels;










e)



guarantees on maximum microplastic release levels during production, in the ‘use’ phase and at end of life;










f)


guarantees that new TCLF products are made from a certain percentage of post-consumer textile content;
















17.


calls for a higher degree of harmonisation of the REACH Regulation (4) with the principles of circularity concerning the specific features of the TCLF sector, in order to prioritise efforts to reduce the use of hazardous chemicals, disclose information on the chemicals used in finished products and to ensure traceability;





Boosting the role of local authorities for a circular transition









18.


considers that regions and municipalities play a key role in promoting research and innovation in this sector, and in creating synergies and interconnections with other sectors and regions affected by the same challenges; calls on the Commission to foster the creation, upscaling and interconnection of regional innovation clusters in the field of circular textiles across the EU;












19.


welcomes the initiatives developed in some European regions and industrial districts such as the Local Green Deal and the Circular Fashion Pact, based on voluntary multi-stakeholder agreements to facilitate the transition of the TCLF sector to a circular model. These models set general targets for the sector and specific targets for each link in the value chain. They respond to the environmental, social and economic challenges facing the sector by setting specific commitments for producers, waste managers, local governments, collection organisations, NGOs and civil society organisations, as well as research and technology centres;












20.


acknowledges that the promotion of social enterprises active in the reuse sector is particularly important for the creation of local, sustainable and inclusive jobs (5) since social enterprises develop local reuse practices while creating tangible social and economic benefits for communities around them; nevertheless underlines that the social enterprise sector must face many challenges in order to be able to be competitive and to provide services on a continuous basis;












21.


urges the Commission to adopt guidelines on how to support the implementation of and partnerships for the circular economy between social enterprises and other players, including service and commercial enterprises, which explore in particular the opportunities offered by the reuse and repair of textiles, as part of the recently adopted EU Action Plan for the Social Economy (6);












22.


recognises that the effectiveness of local systems for the collection of TCLF waste remains a key challenge and points out that the total cost of collecting, separating and recycling this waste must be less than the costs relating to managing household waste, in order to encourage an effective circular transition of the sector;












23.


calls on the Commission to draw up guidance templates for the development of local TCLF waste collection and management systems that take into consideration:






a)


public consultation before designing measures to achieve targets;










b)


tools to promote collaboration between the different stakeholders to improve collection, further processing and sale;










c)


mechanisms to promote the economic sustainability of collection and processing for all stakeholders in the value chain (this includes the principles of extended producer responsibility);










d)


mechanisms to preserve and promote existing reuse and repair best practices put forward by local players;









Supporting sustainable production models









24.


urges the Commission to include in the EU’s Sustainable Products Initiative measures aimed at banning the destruction of unsold articles (i.e. excess inventory, deadstock, and returned items, with a particular focus on returns through e-commerce), and to establish targets for the production phase to help prevent production waste and disincentivise overproduction;












25.


calls for the introduction of mandatory minimum Green Public Procurement criteria (7), the scope of which should be determined following an impact assessment, as well as requirements concerning Member States’ incentives for textile products; also proposes that the Commission develop guidance on incentives and criteria to guide public and other contracts promoting sustainable development;












26.


calls on the Member States to regulate Green Public Procurement by means of action plans or national strategies, ensuring greater harmonisation of national criteria with the EU’s guiding principles (8); also considers exchanges of local and regional knowledge and good practices necessary in order to promote and facilitate their more comprehensive and widespread implementation;












27.


calls on the EU, as a major importer and exporter (9) in the global value chain of the TCLF sector, to become a global trailblazer in promoting sustainable and circular TCLF value chains and in innovative technological solutions and business models, thus ensuring the green and digital transition, addressing social challenges and ensuring compliance with sustainability obligations, and by making manufacturing SMEs competitive in the global framework;












28.


calls on the Commission to prepare a new legislative initiative to effectively ban the placing on the EU market of products made by forced labour, including child labour; calls for the inclusion of textiles, clothing, leather and footwear (TCLF sector) in legislation on corporate sustainability due diligence. The sustainability regulatory framework should apply not only to the EU manufacturers in question, but to all marketing companies, regardless of where they manufacture;












29.


believes that it is important to be aware of the need to involve and support both small and large farms producing natural materials (such as wool), which play a major role in the production of recyclable textiles, in the production/manufacture/reuse processes;












30.


urges the Commission to provide specific support for technological investment in the value chain and specific R & D&I measures needed to achieve a real production transformation from a linear to a more circular model in the textile, leather and footwear sectors, and encourages the study and production of new materials that can be obtained by marrying different production and recycling sectors;












31.


recommends adopting at EU level a clear definition and scope of application for Extended Producer Responsibility (EPR) with eco-modulated fees for products in the TCLF sector in order to identify, prevent, mitigate, bring to an end to and account for actual and potential adverse impacts on human rights, including labour rights, and on the environment in companies’ own operations and across their global value chains;












32.


points out that the TCLF ecosystem requires a highly skilled workforce to unlock the job-creation potential offered by the digital and green transitions, as only 13 % of the workforce has high-level qualifications (10). SMEs’ competitiveness needs to be increased in order to retain and generate new talent, and working conditions and productivity need to be improved in the production of sustainable raw materials and the manufacture of textile products in our industry. In order to attract skilled young talent and enrich SMEs’ skills, the Committee encourages the establishment of a large-scale skills partnership for the textiles ecosystem to promote upskilling, reskilling and the acquisition and transfer of green and digital skills, including knowledge on life-cycle and value-chain assessment; calls on the Commission to take into account the expected increasing quantities of collected TCLF products due to the mandatory separate collection of waste, when designing support instruments for jobs in the sector’s post-consumer management;












33.


regrets the data that shows that women make up the majority of the low-waged and unskilled TCLF workforce; firmly believes that improving the sustainability of the supply chain also has an important gender equality dimension and calls for agreed actions to significantly increase women’s access to higher positions;












34.


also encourages the targeted use of Erasmus+ programme resources for pilot and experimental initiatives in the field of vocational training and higher education that help people acquire the green and digital skills required in the textile, fashion, leather and footwear sector, to make it more appealing to young people and to encourage worker mobility;












35.


welcomes the EU’s Pact for Skills (11), which aims to maximise the impact of investments in the upskilling and reskilling of workers in the entire TCLF ecosystem, including the fashion and retail segment of the sector;





Turning Waste into Value









36.


notes that with the implementation of the EU Regulation on the separate collection of textile waste by 2025 and the positive effects on the collection and management of waste resulting from the producer responsibility organisations (PROs) established in the Member States, it is expected that a lower share of items collected will probably be suitable for resale in Europe, and that the share of post-consumption household TCLF waste that becomes available for recycling will increase significantly (12). With regard to the increase of the EU’s recycling capacity, the Committee suggests taking into account, in the investment planning, the impact on the generally more labour-intensive upcycling and reuse sectors, and the resulting employment and social inclusion dynamics;












37.


believes that the local production of recycled fibres can play a key role in strengthening the European textile value chain. Although, once it has matured and expanded, the textile recycling industry could become autonomous and profitable, funding for the short-term transition will be needed, including potentially through EPR schemes and other support to adapt the existing industry to increase capacities with recycled products for different sectors: fashion, automotive, household textiles, technical fabrics, etc.;












38.


welcomes the inclusion of (a) clothes and other textiles collected separately and prepared for reuse, (b) cellulosic fibres recovered/recycled from TCLF waste and (c) blended fibres recovered/recycled from TCLF waste in the priority list of waste streams for the development of further end-of-waste criteria in the EU, as a way to increase the capacity of the EU recycling industry in this sector.





Brussels, 30 November 2022.


The President of the European Committee of the Regions

Vasco ALVES CORDEIRO




(1)  Textiles and the environment: the role of design in Europe’s circular economy (EEA, 2022).

(2)  COM(2022) 143 — Proposal for a Directive as regards empowering consumers for the green transition through better protection against unfair practices and better information.

(3)  Initiative on substantiating green claims — Environment – European Commission (europa.eu).

(4)  Registration, Evaluation, Authorisation and Restriction of Chemicals.

(5)  On average, a social enterprise creates 20-35 jobs per 1 000 tonnes of textiles collected with a view to reuse. Source: OECD/European Commission (2022), Policy brief on making the most of the social economy’s contribution to the circular economy and RREUSE (2021), Job creation in the reuse sector: Data insights from social enterprises.

(6)  COM(2021) 778 final.

(7)  Green Public Procurement not only addresses the impacts of TCLF consumption associated with the public sector, but also has the potential to send strong signals into the market in general that are aimed at the development and growth of innovative, sustainable and more circular solutions in TCLF production and service provision which can be adopted by the private sector.

(8)  JRC Technical Report (2020), EU Green Public Procurement (GPP) Criteria for Textile Products and Services Guidance Document.

(9)  In 2020, 8,7 million tonnes of finished textile products worth EUR 125 million were imported into the EU. Clothing accounts for 45 % of imports in terms of volume, followed by household textiles, other textiles and footwear (source: Eurostat, 2021).

(10)  Eurostat (2019), Labour Force Survey.

(11)  https://ec.europa.eu/social/main.jsp?catId=1517&langId=en.

(12)  Up to around 1,7 million tonnes by 2030, according to the report Scaling textile recycling in Europe — turning waste into value, McKinsey (2021).