Performance requirements for textiles
Input on EU sustainable design criteria for
textiles
July 24, 2023

Our reference

R001-1288851BUM-V03-los-NL

Responsibility
Title

Performance requirements for textiles
Input on EU sustainable design criteria for textiles

Client

Ministry of Infrastructure and Watermanagement

Project leader

Walter Tobé

Author(s)

Milou van de Burgt, Joanne van ‘t Zelfde, Jurgen Ooms, Walter Tobé
(TAUW)
Britt Zandbergen (Rebel), Michiel Kort (Rebel)

Second reader

Jan Mahy, Anton Luiken (Saxion)

Reference

R001-1288851BUM-V03-los-NL

Number of pages

61 (including attachment)

Date

24 July 2023

Signature

This document was released with the explicit approval of authorized
project management.

Colophon
TAUW bv
Australiëlaan 5
P.O. Box 3015
3502 GA Utrecht
T +31 30 28 24 82 4
E info.utrecht@tauw.com

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Table of contents
Executive summary .......................................................................................................................... 5
Glossary............................................................................................................................................ 8
1

Introduction ................................................................................................................................ 9
1.1

Scope of this project ......................................................................................................... 10

1.2

Purpose of this report ....................................................................................................... 12

1.3

Target audience ............................................................................................................... 12

1.4

Reading guide .................................................................................................................. 12

2

Approach ................................................................................................................................. 13

3

Dutch and EU circularity and textile policy .............................................................................. 15

4

5

6

3.1

Circularity and textile policies in the Netherlands ............................................................. 15

3.2

European circularity and textile policies ........................................................................... 17

3.3

Design requirements and Dutch and EU policies ............................................................. 20

3.4

Conclusion ....................................................................................................................... 22

Environmental impacts in the textile value chain ..................................................................... 23
4.1

Overall view of textile supply chain in The Netherlands ................................................... 23

4.2

Overview of the environmental impacts in the textile supply chain .................................. 24

4.3

In depth analysis of supply chain ..................................................................................... 28

4.4

Conclusion ....................................................................................................................... 38

Textiles key issues and the complexity of the textile market ................................................... 41
5.1

Key issues of consumer textiles ....................................................................................... 41

5.2

Key issues textiles for household textiles ......................................................................... 43

5.3

Key issues textiles for workwear textiles .......................................................................... 44

5.4

Best practices and initiatives that work towards a sustainable value chain ..................... 45

Performance requirements ...................................................................................................... 46
6.1

A. Durability ...................................................................................................................... 47

6.2

C. Reusability ................................................................................................................... 49

6.3

E. Repairability ................................................................................................................. 49

6.4

G. Presence of substances of concern ............................................................................ 50

6.5

I. Resource use or resource efficiency ............................................................................. 51

6.6

J. Recycled content .......................................................................................................... 51

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6.7

K. Possibility of remanufacturing and recycling ................................................................ 52

6.8

M. Environmental impact (Emission of Microplastics) ...................................................... 53

Recommended performance requirements ............................................................................. 55
7.1

General performance requirements ................................................................................. 55

7.2

Performance requirements for household textiles ............................................................ 56

7.3

Consumer clothing - short cycle ....................................................................................... 57

7.4

Consumer clothing - long cycle ........................................................................................ 57

7.5

Non-protective workwear - short cycle ............................................................................. 58

7.6

Non-protective workwear - long cycle .............................................................................. 59

7.7

Suggested information requirements ............................................................................... 59

Appendix 1 Organizations that have contributed to this project ................................................... 61

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Executive summary
Textiles are an essential part of our day to day lives. Clothing keeps us warm, protects us from
hazards and allows us to express ourselves. However, the production, maintenance and disposal
of clothing comes with a high environmental burden. Therefore, the European Commission has
presented its strategy for sustainable and circular textiles. One of the measures under the strategy
is to regulate textiles through the Ecodesign for Sustainable Products Regulation (ESPR). Under
the ESPR performance requirements and information requirements can be made mandatory for
products to be put on the European market. In collaboration with member states, experts, and
stakeholders, the commission will develop a proposal outlining performance and information
requirements for the upcoming years. This study, which was commissioned by the Dutch Ministry
for Infrastructure and Water management, provides input for the proposal on performance
requirements. While this study is not directly aimed at information requirements, the knowledge
gathered on information requirements is given in this report as well. However, the information
requirements are not fully developed.
ESPR
The ESPR initiative has two main objectives: to reduce the negative environmental impacts of
products throughout their lifecycle, and to improve the functioning of the internal market. The
ESPR aims to improve several aspects of a products’ life cycle to address relevant environmental
impacts. These aspects are listed in table 0.1.
Categories
The focus of this report is on three types of textile products: consumer clothing, workwear, and
household. These categories correspond to the circular textile policy program of the Netherlands,
as well as to the Dutch textile Extended Producer Responsibility scheme. The aim is to extend the
use phase of textiles, but this cannot be achieved through performance requirements alone.
Overengineering textiles within the current situation of fast fashion will lead to an increased
environmental impact by extending the technical durability of the textile product beyond its social
and aesthetic lifespan. To address this, we propose the following differentiation as subcategories:
textiles intended for a long cycle (longer than 2 years) and textiles for a short cycle (up to 2 years).



For short cycle textiles the focus will be on recycled content and recyclability.
For long cycle textiles the focus will be on durability and repairability.

For workwear we differentiate between protective and non-protective workwear. Protective
workwear already has high standards, specific norms, and regulations to safeguard the end-user.
As protective gear is usually leased in a business-to-business setting, longevity is part of the
business case. Therefore, this report focusses only on non-protective workwear which is again
divided in long and short cycle clothing. For household textiles we found that these textile items
are long lived and are generally relatively easily recyclable as they are mostly made from mono
materials and contain a minimum of components that hamper recycling.

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Table 0.1 lists the ESPR aspects and describes the focus of the potential performance
requirements for each category.
Table 0.1
ESPR aspects

Focus

Note

A.

Durability

X

Most relevant for categories with long cycle and household textiles

B.

Reliability

-

Not relevant, except for safety wear which has its own regulations.

C.

Reusability

X

Most relevant for categories in the long cycle and household
textiles

D.

Upgradability

-

Not relevant

E.

Repairability

X

Most relevant for categories with long cycle and household textiles

F.

Refurbishment

-

Not relevant

Presence harmful

X

Relevant for all categories

-

Not relevant, however energy usage in production or care is. This

G.

substances
H.

Energy use or efficiency

should be addressed by care instructions (M.)
I.

Resource use or resource

-

Best through other regulations

efficiency
J.

Recycled content

X

Relevant for all categories

K.

Remanufacturing or recycling

X

Most relevant for categories with short cycle and household
textiles

L.

Recovery of materials

-

Is lower step in the waste hierarchy than recycling. Therefore, we
focus on recycling (K.)

M.

Environmental impacts

X

Relevant for all categories

N.

Expected generation of

-

Best through other regulations

waste

Performance requirements
The three general recommendations for performance requirements for all categories are
repairability, substances of concern, and environmental impact. For long cycle clothing, spare
components must be readily available on the market, and bespoke items must have orderable
spare parts. According to the proposal for the ESPR, chemical hazards cannot be regulated
through performance requirements, as this would interfere with chemicals regulation. However,
performance requirements can be made on substances of concern as their presence or use in the
supply chain impacts sustainability. Therefore, we suggest banning all additional substances listed
in the MRSL issued by the Zero Discharge of Hazardous Chemicals Foundation, which are not
regulated through REACH. This list aims at protecting protect workers, local communities, and the
environment from the possible impacts of harmful chemicals This list should be reviewed regularly.
To minimize environmental impact, we advise to wash all plastic containing cloth before it is
brought to the market, using laundry facilities equipped with filters that capture released
microplastics.

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The other performance requirements, based on the ESPR aspects, vary according to each
category, and are presented in figure 0.1.

Figure 0.1 An overview of performance requirements on each (sub) category

Provide additional information to increase transparency
There are alternative measures to mitigate the environmental impact of textiles, beyond extending
of textile lifespan or design for recycling. A key approach is to increase transparency on the
environmental impact of textile products and allow consumers to make conscious decisions. This
can be achieved through an (digital) information label to each textile product. Although this study
wasn’t aimed at information requirements, we suggest considering the aspects in table 0.2 when
designing information requirements.
Table 0.2. An overview of essential information needed in the label.
Aspects of information label

Note

Resource efficiency

Make it mandatory to disclose the resource efficiency of the product passport.
At a minimum report the following:


The amount of energy used to produce the product, specifying the
percentage of renewable and non-renewable sources



The amount of resources required to produce the product, which can be
determined through a mass balance

Environmental impact of an item

It should be mandatory to disclose the environmental impacts of the product’s
production. This should be done according to the PEF textile standard that is
currently scheduled to be released in 2024

Microplastics

Make it mandatory to disclose the potential for the product to release
microplastics. Differentiate between products that release many microplastics
and those that release less microplastics

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Aspects of information label

Note

Repairability

Information about the correct replacement component must be and
accessible for both the user/consumer and the tailor/repair professional

Glossary
Term

Definition

Textile industry

All organizations who work on textiles, e.g., yarn, cloth, and clothing, from
designing, production till the end-of-life manufactures, and all in between

Textile supply chain

A network of facilities that produce raw materials, transform them into
intermediate goods and then final products and deliver the products to
end users through a distribution system

Ecodesign directive

Ecodesign Directive 2009/125/EC,
Current legislation for Ecodesign, aimed at energy usage of electronic
equipment

Ecodesign for Sustainable Products

Proposal for Ecodesign for Sustainable Products Regulation (europa.eu)

Regulation (ESPR)

Upcoming legislation for Ecodesign with a wider scope of products and
looking at the whole life cycle. The revision of the Ecodesign Directive
which is currently being negotiated at the EU-level. With the revision, the
Ecodesign legislation will cover a wider scope of physical products.
Ecodesign requirements consist of sustainability and circularity aspects
and cover the entire life cycle of a product

Extended Producer Responsibilities

An instrument for encouraging more sustainable products on the market

(EPR)

and for improving the treatment of waste streams of products

Environmental footprint

The overarching purpose of Product Environmental Footprint information
is to enable to reduce the environmental impacts of goods considering
supply chain activities (from extraction of raw materials, through
production and use to final waste management). This purpose is
achieved through the provision of detailed requirements for modelling the
environmental impacts of the flows of material/energy and the emissions
and waste streams associated with a product throughout the life cycle.
(adapted from European Platform on LCA | EPLCA (europa.eu))

Closed loop recycling

Collecting and sorting recycled materials, extracting resources from the
materials, and using those resources as inputs in the manufacturing of
products identical to the original

Open loop recycling

Collecting and sorting recycled materials, extracting resources from the
materials, and using those for new raw materials in products that are
different from the original

Pre-consumer waste

Waste materials that were created during the process of manufacturing or
delivering goods prior to their delivery to a consumer

Post-consumer waste

Waste materials that were created during the end of the use phase

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Term

Definition

REACH

A European regulation on the Registration, valuation, Authorisation and
Restriction of Chemicals Reach regulation consolidated text (europa.eu)

ECHA

European Chemicals Agency

ZDHC

Zero Discharge Hazardous Chemicals

MRSL

Manufacturing Restricted Substances List

Cradle to gate

Impact of a product from the moment it is produced to the moment it
enters the store

Water usage

The aggregate sum of water extracted from its source to be utilized

1 Introduction
Textiles are an essential aspect of our daily lives. Europeans consume on average 21 kg of
textiles per person per year and discard about 11 kg of textiles per person per year1 and the textile
consumption in the EU is increasing2. The textile industry is on a global scale contributing to global
greenhouse gas emissions, water pollution, poor working conditions, and overflowing landfills3.
The European commission has set an ambitious goal to create a fully circular economy by 2050.
Therefore, the textile industry should also be circular by 20504. This implies a transformative
change for the textile supply chain specifically. As part of the European Green deal and the
circular economy action plan, the European commission has developed a new strategy for
sustainable and circular textiles. As a part of this new strategy, textiles will be regulated with the
Ecodesign for Sustainable Products Regulation (ESPR). Under this Regulation, design
requirements will be set for textiles. The Commission is expected to start developing these
measures in 2024. The design requirements can include binding targets for material use, and
production (performance requirements) as well as information requirements. The design
requirements should incentivise a more circular business model and increasing closed-loop
recycling methods.
The Netherlands has set the goal to transform its economy to fully circularity by 2050. So, textiles
must become circular, to be a part of this Dutch circular economy. Therefore, The Netherlands has
developed a policy program for circular textiles5. The Dutch governments wants to contribute to the
transition for textiles; therefore, the Dutch Ministry of Infrastructure and Water management has
commissioned this study. The aim of this study is to provide relevant insights on potential
performance requirements to be covered under the Ecodesign Directive for textiles and their
feasibility, given the state of art in the sector. The results discussed in this report.

1

Steeds meer textiel in Nederland (cbs.nl)
EU strategy for Sustainable and Circular Textiles
3
The impact of textile production and waste on the environment (infographic) | News | European Parliament (europa.eu)
4
Textiles strategy (europa.eu)
5
Bijlage beleidsprogramma circulair textiel 2020 - 2025 | Rapport | Rijksoverheid.nl
2

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Scope of this project

Textiles have many functions, they are used in apparel, household textile, but also in products
such as medical and protective equipment, buildings, and vehicles. In addition to this, textiles are
made of many types of materials such as cotton, polyester, polyamide, wool, synthetic celluloses
(viscose, lyocell), hemp or acryl.

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Textile products
Consumer clothes such as:
• Trousers and shorts
• Skirts
• Jackets
• Coats/raincoats
• Pyjamas and nightwear
• Shirts, dresses and blouses
• Lingerie and underwear
• Swimwear
Household textiles such as:
• Bath towels
• Kitchen towels
• Bedding
Workwear such as:
• Casual workwear
• Promotional clothes
Figure 1.1 Overview of textile products

The focus of this report is on the following types of textile products, see figure 1.1. These
categories correspond to the circular textile policy program of the Netherlands, as well as the
Dutch textile Extended Producer Responsibilities (EPR)4.
Textile types
Aside from product types this report focuses on the following textile materials.


Cotton
A cellulose based textile. Other cellulose based textiles are e.g., hemp, linen ‘Viscose,’
‘Lyocell’ and ‘Modal’



Polyester
A synthetic textile made of oil. Other synthetic fibres are polyamide, polyacrylic,
polypropene, aramid and elastane

These two types of fibres are the most common types of fibres. In addition, these two fibres can
be seen as representatives of the largest textile groups, the synthetic fibres, and the cellulose
fibres. Within this report animal-based fibres (approximate less than 1 % of the market) have been
left out of the scope, see figure 1.2.

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Figure 1.2 The composition of materials in consumer, household textiles (left) and workwear (right)6

Because of workers safety, using disposable textiles is common in the industry. These
disposables are commonly made of synthetic nonwoven materials. A type of fabric made of
plastics that mimics the properties of paper. Because of these different properties these
disposables are excluded from the development of performance requirements.

1.2

Purpose of this report

This research aims to come to realistic and ambitious performance requirements for textiles, in
line with the Dutch government's position on circular and sustainable textiles, to obtain a more
circular textile supply chain. This report intends to answer the following questions:
 How could textile performance requirements be defined?
 Which minimum ambition level is required to achieve a footprint reduction of the textiles
sector?
What are realistic performance requirements given the current state of technology and
anticipated technology developments and innovations?



1.3

Target audience

The final report targets the readers who work in the textile supply chain and are interested in the
upcoming process of drafting EU design requirements for textiles. This report will be made publicly
available by the Dutch ministry of Infrastructure and Water management and will be presented to
the relevant stakeholders including the European Commission.

1.4

Reading guide

The structure of this report is as follows. Chapter 2 gives the approach of this project. Chapter 3
gives an overview of the European Commission’s aim for the textile sector as well as the circular
economy policy regarding textiles in the Netherlands. Chapter 4 entails the current textile supply
chain and the environmental impact of the textile supply chain. Followed by key issues and the
complexity of the textile market in chapter 5. The performance requirements are described in
chapter 6. Lastly, the recommended performance requirements are shown in chapter 7.

6

Monitoring beleidsprogramma circulair textiel (overheid.nl)

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2 Approach
The goal of this report is to present performance requirements as an input for the EU wide
comitology procedure on design requirements for textile products. The performance requirements
are aimed at the same textile categories that fall under in the Dutch EPR-scheme and the circular
textile policy program of the Netherlands. These textile categories are (1) consumer textiles, (2)
workwear and (3) household textiles. Figure 2.1 shows the approach used in this project to
develop design requirements.

Figure 2.1 The approach to develop design requirements

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Through literature review different key facts were gathered from (1) the Dutch and EU policies, (2)
the textile value chain and (3) the environmental impact of the textile value chain. The information
gathered through the literature review was assessed through an ESPR lens.
The result of this research showed current difficulties in manufacturing (e.g., deficit of materials in
recycling), the policy instruments used to reach a circular economy for textiles and the complexity
of the textile supply chain. Chapter 3 and 4 give the information gathered in this step.
Based on the gathered information independent specialists were consulted on practical and
feasible performance requirements. This consultation round helped the project team to formulate a
pencil sketch of the performance requirements. In the next phase these preliminary performance
requirements were tested in interviews with market parties. This helped improving the
performance requirements to a level where they could be evaluated through a wider written review
round with stakeholders. The review round was mostly with progressive stakeholders, so the
requirements are deemed to be ambitious.

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3 Dutch and EU circularity and textile policy
This chapter describes (paragraph 3.1 and 3.2) and compares (paragraph 3.3) relevant Dutch and
EU policies.

3.1

Circularity and textile policies in the Netherlands

In September 2016, the Dutch government launched the Government wide program for a Dutch
Circular Economy. The aim of the program is to be completely circular by 2050. By 2030 the
consumption of primary raw materials must be reduced by half. To reach these goals for the textile
supply chain the Circular textile policy has been established in 2020. In this policy document, the
Dutch government describes the transition towards a fully circular textile industry in 2050. Several
intermediate goals are set for 2025, 2030 and 2035. These goals are presented in table 3.1.
Table 3.1 Government circular textile policy 2020
Policy transitions towards a fully circular economy7
2025



Share of recycled (post-consumer) / sustainable material in textile products is 25 %



30 % of all resources, materials and products put on the Dutch market, will be - if direct
reuse is not possible anymore- recycled


2030

A minimum of 10 % of the disposed textile products will be reused on the Dutch market

By 2030, the transition towards a fully circular economy will be halfway complete, which means
that:


All textile products put on the Dutch market will contain 50 % sustainable material.
From that 50 %, 30 % will be recycled material and 20 % sustainable materials



After collection and when re-use is no longer possible, 50 % of resources, materials, and
products put on the Dutch market should be recycled


2035

A minimum of 15 % of the disposed textile products will be reused on the Dutch market

The ambition is to cut the ecological footprint of subjects such as emissions, water use,
chemicals, and microplastics by half

2050

Fully circular economy

The Dutch circular textile policy contains several policy measures related to the eco-design of
textile products:
 In October 2020, several parties from the denim supply chain signed the Green Deal Circular
Denim (Denim Deal). The aim of this agreement is to further encourage the use of
post- consumer recycled (PCR) cotton in the production of new denim garments. Local
producers, next to societal- and environmental parties are involved to achieve sustainable
impact in production countries. Progress on the targets is annually monitored. In 2021 a
baseline study was executed with 2020 as a base year. This provides insight into the starting
point from which the member parties worked towards the agreed objectives. The baseline
measurement shows that in 2020, 8 percent of denim garments put on the Dutch market by
the affiliated parties contained the targeted 5 percent PCR cotton.
7

Beleidsprogramma circulair textiel 2020-2025

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For the global market, this applies for 12 percent of the denim garments they produce. The
2022 report on the year 2021 shows that the target of 5 percent PCR is met for 26 % of all the
denim garments put on the Dutch market by signatories of the Denim Deal. Of the 1.1 million
jeans put on the market by the signatories of the Denim deal 36 % contained more than 20 %


PCR
In 2016, a broad coalition of businesses and other organizations signed the Dutch
Agreement on Sustainable Garments and Textile. During a period of 5,5 years, they
worked together to improve working conditions, prevent pollution, and promote animal welfare
in production countries. This covenant has been reviewed, next to the other ‘International
Responsible Business Conduct (IRBC)’ covenants. The review of this policy was presented in
the paper ‘Van Voorlichten tot Verplichten’8. As mentioned in the coalition agreement
2021-20259 the Netherlands is promoting IRBC legislation in the EU and will introduce
national IRBC legislation that considers a level playing field between neighbouring countries



and the implementation of possible EU regulations
Microplastics can be released into the environment during production, use or recycling of
clothing. When washing synthetic or coated cotton clothing, thousands of microplastics end up
in the sewage system. While sewage treatment plants remove much of this from wastewater,
a substantive volume is discharged into surface waters. As a result, synthetic fibres contribute
to the amount of plastic in the sea10. To minimize the spread of microplastic fibres the
government takes a collective approach with all stakeholders in the supply chain: textile and
clothing manufacturers, retailers, consumers, washing machine manufacturers, detergent
manufacturers, sewage treatment companies and local governments. A concrete example is
the research of TNO commissioned by the ministry to define a measurement method for
microplastics from textiles11. The Dutch government would like to work together with other
countries on microplastics abatement as this is most effective. The European Union already
initiated the ‘measures aiming to reduce the presence in the environment of unintentionally
released microplastics from textiles’ to reduce the impact of microplastics. The Dutch
government will urge the European Commission to tackle the removal of microplastics from



textiles at the source
An Extended Producer Responsibility (EPR), in the Netherlands will enter into force on July
1st, 2023. The EPR entails that textile producers and importers are responsible for the
collection, recycling, and reuse of their products. The EPR aims to promote more reuse and
recycling, leading to less waste and pollution. Currently, only 12 percent of the collected
textiles are recycled (not all fibre-to-fibre) and only 2 percent is reused in the Netherlands. The
decision is intended as a financial incentive that will effectively manage textile waste and
minimize the need for new raw materials. In the EPR, several targets are included for the
producers12. These are presented in table 3.2. In addition, producers are also responsible for
informing consumers, providing annual reporting, and publishing an appropriate take-back

8

IMVO maatregelen in perspectief (overheid.nl)
Coalitieakkoord 2021 – 2025: Omzien naar elkaar, vooruitkijken naar de toekomst (overheid.nl)
10
Maatregelen tegen milieubelastende microplastics uit kleding | RIVM
11
Adviesrapport inventarisatie uniforme meetmethode voor microplastic vezels uit textiel
12
Besluit uitgebreide producentenverantwoordelijkheid textiel
9

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system including financing. Producers can jointly start a producer organization to implement
the obligations under the EPR
Table 3.2 Obligations included in the EPR textile
Goals 2025

Goals 2030





50 % of the total textile waste will be reused or
recycled.





At least 20 %-point of the 50 % total textile waste

recycled


will be reused, the other 50 % may be reused or

recycled

recycled

At least 10 %-point of the 20 % reuse will be

At least 25 % of the recycled material must be
fibre-to-fibre recycled

3.2

At least 25 %-point of the 75 % total textile waste

will be reused, the other 30 % may be reused or


reused in the Netherlands


75 % of the total textile waste will be reused or

At least 15 %-point of the 25 % reuse will be
reused in the Netherlands



At least 33 % of the recycled material will be fibreto-fibre recycled

European circularity and textile policies

In December 2015, the European Commission adopted the First Circular Economy Action Plan.
The plan aims to stimulate the development of lead markets for climate-neutral and sustainable
products in the EU and beyond. A revision and adaptation of this plan led to the New Circular
Economy Action Plan (CEAP), which has been adopted in March 2020. The CEAP establishes a
sustainable product policy framework, including measures in three broad areas: fostering
sustainable product design; empowering consumers and public buyers; and promoting circularity
in production processes.
In March 2020, the European Commission adopted the Industrial Strategy for Europe. The policy
sets out the EU’s overarching ambition to foster a transition to climate neutrality and digital
leadership. It echoes the European Green Deal, which was adopted in December 2019, in
highlighting the leading role that Europe’s supply chain must play, by reducing its carbon and
material footprint and embedding circularity across the economy. It underlines the need to move
away from traditional models, and revolutionize the way we design, make, use, and dispose of
products.
As part of the Circular Economy Action Plan and the Industrial Strategy for Europe a proposal for
Ecodesign for Sustainable Products (ESPR) and the EU Strategy for Sustainable and Circular
textiles were presented in March 2022. Building on both documents the European Commission will
develop binding product-specific eco-design requirements to increase textiles’ performance. To
understand the policy context of this initiative this section will describe successively the Ecodesign
for Sustainable Products (ESPR) and the EU Strategy for Sustainable and Circular textiles,
including related other policy measures.

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Ecodesign for Sustainable Products (ESPR)

The objectives of the ESPR initiative are to reduce the negative life cycle environmental impacts of
products and to improve the functioning of the internal market13. It therefore lays down a framework
for setting Ecodesign requirements, such as product durability, reusability, upgradability and
reparability, the presence of substances of concern in products, product energy and resource
efficiency, use of recycled content in products, product remanufacturing and high-quality recycling,
and for reducing products’ carbon and environmental footprints.
The ESPR replaces and builds on the existing Ecodesign Directive of 2009 but expands the scope
of products from energy-related products to most physical products. The European Commission
will prioritise product groups for which ecodesign requirements will be established. This will be
done in the ecodesign working plan. A report, published by the Joint Research Centre, which is
closely affiliated with the European Commission, names the following product groups as potential
priorities: Textiles, furniture, bed mattresses, tires, detergents, paints, lubricants, and chemicals.
Energy-related products for which the measures need to be revised or newly defined and
ICT-products will also be prioritised14.
Although the ESPR is not yet final and still subject to change it now includes the following main
elements:
 All products regulated under the ESPR which are put on the EU internal market will have to
comply with the set eco-design requirements. The ecodesign requirements are expected to
build upon the voluntary EU Ecolabel criteria for Textile Products, which already includes
requirements related to environmental aspects of textile products such as chemical use,
fitness for use (quality) and best production practices. Furthermore, by developing criteria for
safe and sustainable by design for chemicals and materials, the Commission will support the
industry to minimize the substances of concern in textile products, as announced in the
Chemicals Strategy for Sustainability
A Digital Product Passport (DPP) will be developed, helping to allow easy and convenient
access to and sharing of product data. When Ecodesign requirements apply to textiles, it will be
mandatory to make a Digital Product Passport available. The DPP will give supply chain actors,
consumers, and public authorities access to detailed product information. The DPP is a tool which
can include guidance on how to repair or recycle products. The passport can also facilitate
tracking substances of concern along the supply chain.


The General Approach of the member states agreed on in May 2023, contains a direct ban
on the destruction of unsold clothing and clothing accessories. The European
Parliament has also indicated to be supportive of this ban on destruction



Green public procurement. The Commission would be empowered to adopt delegated acts
establishing ecodesign requirements for public contracts, including mandatory technical
specifications and selection criteria. This builds upon the EU GPP criteria for textiles products
and services, prescribing criteria for the purchase of goods, services and works with reduced
environmental impacts

13
14

Ecodesign for sustainable products (europa.eu)
Carriages preview | Legislative Train Schedule (europa.eu)

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European strategy for Sustainable and Circular textiles

The EU Strategy for Sustainable and Circular Textiles15 sets out the vision and concrete actions to
ensure that by 2030 textile products placed on the EU market are long-lived and recyclable, made
as much as possible of recycled fibres, free of hazardous substances and produced in respect of
social rights and the environment. To reach this aim six key actions are proposed:
 Introducing mandatory Ecodesign requirements. Extending the life of textile products is the
most effective way of significantly reducing their impact on the climate and the environment. To
achieve this, product design plays a key role. Increased durability will enable consumers to
use their clothes for longer and at the same time support circular business models. In
addition, material composition, including the fibres used and their blending, or the presence of
chemicals affects the environmental performance of textiles. Whether chemicals are desirable
in textile items is a fine line. Although chemicals might be harmful to the environment, they
add functionalities to textile items, increasing the performance and lifetime16


Stopping the destruction of unsold or returned textiles. The General Approach the
member states have agreed on does already include a direct ban on the destruction of unsold
clothing and clothing accessories. It remains to be seen whether this provision will be included



in the final agreement. In the future, the Commission could introduce a ban for other types of
textiles products
Tackling microplastic pollution. By introducing binding design requirements, being



introduced under the ESPR, the Commission plans to mitigate the shedding of synthetic fibres
in the environment, together with the Microplastic Pollutions Initiative
Introducing information requirements and a Digital Product Passport. Clear, structured,
and accessible information on the environmental sustainability characteristics of products
empowers businesses and consumers to make better choices and improves communication
between actors along value chains for example on substances of concern, on repair or on the
fibre composition. Therefore, as part of the measures under the ESPR, the Commission will
introduce a Digital Product Passport for textiles for textiles, which will contain mandatory
information on circularity and other key environmental aspects. Which information



requirements apply will be determined in the secondary legislation under which textiles are
regulated
Green claims for truly sustainable textiles. Consumers willing to purchase more
sustainable products are often discouraged from buying them by the unreliability of claims: a
recent screening of sustainability claims in the textile, garment and shoe sector suggested
that 39 % could be false or deceptive17. The initiative on Empowering Consumers for the
Green Transition18 will result in a ban on misleading generic claims and in new rules which
ensure that consumers are provided with information at the point of sale about a commercial
guarantee of durability as well as information relevant to repair. To complement the
Empowering Consumers Initiative by setting requirements for the substantiation and
communication of explicit environmental claims, the Commission has presented the

15

Textiles strategy (europa.eu)
Ecodesign for sustainable products (europa.eu)
17
Sweeps (europa.eu)
18
Proposal for a Directive on empowering consumers for the green transition and annex (europa.eu)
16

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Green Claims Directive19. The Green Claims Directive sets requirements for the



substantiation and communication of explicit environmental claims on products and traders.
The proposal also presents requirements for environmental labelling schemes
In addition, the Commission will review the EU Ecolabel criteria for textiles and footwear to



support its uptake among producers and offer consumers an easily recognizable and reliable
way to choose eco-friendly textile products
Extended producer responsibility (EPR) and boosting reuse and recycling of textile
waste. Making producers responsible for the waste that their products create is essential to
decouple textile waste generation from the growth of the sector. EPR requirements have
proven to be effective in improving separate collection of waste and its subsequent
management in line with the waste hierarchy. In this context, the Commission will propose
harmonized EU extended producer responsibility rules for textiles with eco-modulation of fees,
as part of the forthcoming revision of the Waste Framework Directive20. The revision is to
monitor the developments in waste generation, composition, and treatment the Commission
has also launched a dedicated study with a view to proposing mandatory targets for preparing
for reuse and recycling of textile waste. The Waste Framework Directive already obliges
municipalities to separately collect textile waste from its inhabitants from 2025 onwards.
A sharp increase in the amount of separate collected textile waste is therefore expected

3.3

Design requirements and Dutch and EU policies

Figure 3.1 shows a timeline, which presents all discussed policy measures regarding textile
ecodesign requirements. The left-hand side presents all Dutch policy measures and the right-hand
side all European policies.

19

https://environment.ec.europa.eu/topics/circular-economy/green-claims_en

20

Expected summer of 2023

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Figure 3.1 Timeline of all discussed policy measures

3.3.1
Comparison between Dutch and EU policies
The timeline and policy study above suggest that, in general, European, and Dutch policies
complement each other on circular textiles. This is understandable due to the international nature of
the textile industry. The Dutch policy focuses on the phases where the government has direct
influence, which are the retail, use, and post-use phases of the textile chain. The Dutch government
demands of the textile retail sector to increase the share of recycled and sustainable content in
textile products that are put on the Dutch market. In the post-use phase, the goal is to reuse and
recycle as many textile products as possible. See also the visualization in figure 3.1.
However, the Dutch circular textile policy program acknowledges that some issues cannot be
regulated at the national level. To address these issues, the Dutch government is actively lobbying at
the European level for a transition to a more circular textile industry.

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In general, the Netherlands takes a leading approach vis-a-vis European circular textile policies.
For example, with the Extended Producer Responsibility (EPR) the Netherlands acts as one of the
frontrunners. As discussed in section 3.2.2 the European Union is developing guidelines for a
mandatory EPR scheme. The Netherlands and involved producers/importers may contribute to the
EU development by sharing their experiences on designing and introducing the EPR and seek for
alignment.
There is a slight difference in focus between current Dutch textile policy and EU policy. Where the
EU focusses more on longevity of the textile products, Dutch policy focusses more on targets for
sustainable and recycled materials. However Dutch policy has a goal of halving the environmental
impact of textiles which is more easily reached through lifetime extension than through sustainable
and recyclable materials. Future textile policy in the Netherlands will probably focus more on
longevity as well21.

3.4

Conclusion

Both the Dutch and European textile policy focus on lowering the environmental impact of the
textile value chain. Setting design requirements will play a significant role in achieving the goals set
by the Dutch government as wells those set by the EU. Voluntary steps by the textile value chain
have shown what is already possible. Now the lessons learned must be put in practice by all
stakeholders in the textile value chain. This means that mandatory design requirements must be set
which help reach the goals of both policies. The design requirements therefore should be aimed at
both the recycled content and recyclability as well as on longevity of the textile products.
Note that although the Dutch and EU policy also focuses on working conditions and income of
workers in the apparel and textile supply chain, this will not be negatively affected by establishing
design requirements as currently proposed. Socioeconomic effects are beyond the scope of the
current eco-design proposal so are left out of scope of this project as well.

21

National+Circular+Economy+Programme+2023+-2030+Summary.pdf

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4 Environmental impacts in the textile value chain
This chapter visualizes and explains the value chain of textiles, starting from raw fibre
materials. Each section of the textile chain will be outlined in more detail in the next
paragraphs and the environmental impact of that section is discussed. Chapter 4 aims to:




Describe the current situation in the Netherlands
Identify key issues in the value chain
Describe the current state of technology now and in the upcoming 5 years, and



Gain insight in the relevant environmental impacts in the textile value chain

The analysis of the textile value chain starts with describing the production of the two fibres, which
represents the largest textile groups. The next paragraphs explain in a more detail how textile
fibres are manufactured into products. And how they are being discarded, collected, and
processed after use. Some steps in the value chain of textiles are the same for household textiles,
consumer clothing and workwear. For other slight differences exist. The differences are explained
within the description of each step.

4.1

Overall view of textile supply chain in The Netherlands

Figure 4.1 shows the textile supply chain from produced raw fibres materials until the different
phases of end-of-use, e.g., reuse, recycling and recover. These phases are a strategic step for a
circular economy22. This report focuses on circular approaches such as reuse and closed loop
recycling which turns waste into value23 to achieve the circular goals discussed in chapter 3. As
with most European countries the production does not take place in the country itself. Production
usually is done in the far east. The Dutch textile supply chain differs from supply chains in other
EU countries because of its relatively advanced textile collection system. In Europe on average
35 % of all textiles are collected separately, in the Netherlands an average of 45 % of all textiles
get collected separately24,25. Enhancing technical and social innovations are key factors for a
circular textile supply chain26. Dutch sorting and consequently reuse and recycling facilities are
playing an important role in the processing of waste textile from several EU member states. At this
moment, many start-ups are working on fibre-to-fibre recycling technology in The Netherlands.

22

R-ladder - Strategieën van circulariteit (rvo.nl)
Circular fashion in Europe: Turning waste into value | McKinsey
24
Circular fashion in Europe: Turning waste into value | McKinsey
25
Afdanken en recyclen - Afval Circulair
26
https://www.afvalcirculair.nl/publish/pages/138236/170179-03_vertaling_roadmap_circulair_textiel_en_07.pdf
23

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Figure 4.1 The textile supply chain

4.2

Overview of the environmental impacts in the textile supply chain

Before going into more detail in the textile value chain this paragraph focuses on the
environmental impact of the whole textile chain. More detailed information is given in the next
paragraphs for each step of the chain.
Textiles have a significant environmental impact, ranking among the top five sectors for
greenhouse gas emission and water usage27. Additionally, the production and use of textiles have
a significant impact on human- and eco-toxicity and the release of microplastics. Therefore, this
report explores the environmental impact of textiles in terms of greenhouse gas emissions, energy
use, water usage, the potential use of harmful substances and microplastics emissions.
The severity of the environmental impact is described in the tables at the end of each paragraph
describing a step in the value chain (paragraphs 4.3). The severity is divided into three colours
ranging from low to high, see table 4.1. Labelling the severity of environmental impacts is very
complex as there is a large variety of textile products and production processes. Many different
studies have been made and each has its own backgrounds and assumptions. Therefore, they are
not comparable. This report is based on relevant recent studies to give a value to the severity of
the different steps in the value chain. However, it should be noted that the severity as it is given in
this report is generalised and might not apply for a single textile product.

27

Textiles and the environment: the role of design in Europe’s circular economy — European Environment Agency (europa.eu)

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Table 4.1 Colour scheme for the environmental impacts
The severity of the environmental impacts
High
Medium
Low

The following sub paragraphs explain in more detail the environmental impacts and how these
impacts relate to each other.
4.2.1
Greenhouse gas emissions
It is estimated that the textile sector is responsible for six to eight percent of the global greenhouse
gas (GHG) emissions28. These emissions occur from energy-sources and non-energy sources,
e.g., during farming (use of fertilizers) and production of chemicals. Overall, energy usage in the
textile chain is the main driver for GHG emissions in the value chain. Reducing GHG emissions
and achieving a carbon neutral textile supply chain is therefore closely related to increasing the
use of renewable energy29.
Complexity of determining greenhouse gas emissions
Determining greenhouse gas emissions for the production of a single piece of textile is complex.
The distribution of greenhouse gas emissions across the global textile value chain is challenging
to quantify, as it is dependent on the specific product, and materials, as well as the
emissions-intensity of the country of production and consumer behaviour. Many studies exist
which quantify the greenhouse gas emissions of various products made of different materials.
Comparing them is challenging as the methodology as well as the input factors differ between the
studies.
Another aspect of determining the greenhouse gas emissions is that different methodology is used
to measure the amount of GHG emissions globally. Life cycle assessment, Greenhouse Gas
Protocol and Higg Materials Sustainability Index are examples of the methodology used in recent
studies, each with variable input factors27. This makes it difficult to compare literature reviews and
draw conclusions to resolve what processes emits the most GHG emissions30,31,32.
Focus of this report
Due to the complexity of determining the GHG emissions within the textile supply chain, this report
follows the conclusion of the McKinsey and Company and Global Fashion Agenda report33. GHG
emissions in the tables include:


Production phase
Each step individually

28

Taking climate action: Measuring carbon emissions in the garment sector in Asia (ilo.org)
Taking climate action: Measuring carbon emissions in the garment sector in Asia (ilo.org)
30
Taking climate action: Measuring carbon emissions in the garment sector in Asia (ilo.org)
31
Beton, A., Dias, D., Farrant, L., Gibon, T., Le Guern, Y., Desaxce, M., Perwuelts, A., Boufateh, I. (2014) Environmental
Improvement Potential of textiles (IMPRO Textiles). JRC scientific and policy reports
32
fashion-on-climate-full-report.pdf (mckinsey.com)
33
fashion-on-climate-full-report.pdf (mckinsey.com)
29

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

Use phase



Washing and drying
End of life phase
Machinery used for sorting and recycling
-

4.2.2

Energy recovery
Water usage

A key source for our quality of life is water, next to clean drinking water we need water to provide
natural habitats and ecosystems. It is important to manage water well, which is a challenging task.
Proper water management is affected by several pressures such as water pollution, rendering
water unsafe, water ‘theft’ and droughts.34 All these pressures lead to long-term (usable) water
imbalances or water scarcity. Water scarcity is the result of insufficient rainfall in combination with
high water demands from industries and agriculture.
Focus of this report
For each step in the value chain of textiles the water usage is estimated. By water usage we mean
the aggregate sum of water extracted from its source to be utilized. The approximations of the
water usage in each step are based on an article published in Sustainability35.
Water usage includes:




Production phase
Farming natural fibres (organic and non-organic)
Producing polyester fibres36
Wet processing
Use phase
Amount of water used while washing
-

4.2.3

Amount of washing
Microplastics

Microplastics originate from various sources and follow different pathways to the aquatic
environment, e.g., atmospheric decomposition and wastewater of domestic washing process37.
Microplastics below five mm entering the aquatic environment can be mistaken for food by marine
animals with fatal ending38. This report focuses on the microplastics in wastewater. Microplastics
in wastewater are linked to contaminating the marine environment.39 Following the food chain,
these microplastics can accumulate in larger marine animals that in turn can be consumed by
humans. This accumulation of microplastics might pose a threat to humans. There is still too little
consensus on the effects on microplastics on human health to include these effects into this
report.

34

Water use and environmental pressures — European Environment Agency (europa.eu)
Sustainability | Free Full-Text | Life Cycle Based Comparison of Textile Ecolabels (mdpi.com)
36
WFA_Polyester_and__Viscose_2017.pdf (waterfootprint.org)
37
A review on microplastic emission from textile materials and its reduction techniques - ScienceDirect
38
sustainability-10-02457.pdf
39
A critical review of interactions between microplastics, microalgae and aquatic ecosystem function - ScienceDirect
35

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Microplastics in wastewater
Friction and abrasion, e.g., during washing of textiles, leads to shedding of micro fibres due to
mechanical stress on the textile fibres40.The shedding of microfibre can lead to micro plastics (in
the case of textiles made of polymers). This report divides textiles into three categories, consumer
clothes, household textiles and workwear. Each category has different maintenance cycles, e.g.,
washing temperatures. The shedding of microfibres depends on the maintenance cycle of the
textile products. Factors such as the (amount of) detergents used, amount of water used during
washing, and drying cycles influence the number of microplastics in the wastewater. For example,
a decrease of water usage during washing results in rising levels of fibre fragments in wastewater
due to the increased friction41. The presence of synthetic dyes on natural or synthetic cellulosic
fibres is another way for microplastics to enter the wastewater and aquatic systems.
In the Netherlands almost all the wastewater is treated in a wastewater treatment plant. However
even with treatment a significant amount of microplastics is released into the environment42.
Current removal efficiency for microplastics is between 76 % and 99 %43,44. But even then, a
significant amount of micro plastics and micro fibres enter the aquatic environment and will
probably remain there forever.
Focus of this report
The focus of this report is microplastics in wastewater, and the comparison made in the
description of the steps in the value chain is based on the three studies28,29,45. The microplastics
impact in the tables includes:
 Production phase



Wet processing
Use phase
Washing
End of life
Microplastics in wastewater

4.2.4
Potentially harmful chemicals
Throughout the entire textile industry substances are used to add functionality to the textile
products. Among the substances are auxiliaries, additives, catalysts, and surfactants. While some
of these chemicals may not be inherently hazardous, certain conditions such as oxidation or
pressure can lead to potential harm to humans. Potentially harmful chemicals can be released into
wastewater, into the atmosphere and are disposed through solid waste in different concentrations.
They can do harm to the human body through inhalation, digestion, or direct contact.

40

Cause of microfibers found in the domestic washing process of clothing; focusing on the manufacturing, wearing, and washing
processes | Fashion and Textiles | Full Text (springeropen.com)
41
Cause of microfibers found in the domestic washing process of clothing; focusing on the manufacturing, wearing, and washing
processes | Fashion and Textiles | Full Text (springeropen.com)
42
STOWA 2021-51 microplastics rwzi.pdf
43
Nederlandse rwzi's verwijderen veel microplastics | STOWA
44
Significante hoeveelheid plastic komt via zuiveringsinstallaties in milieu | RIVM
45
Microplastics from textiles: towards a circular economy for textiles in Europe — European Environment Agency (europa.eu)

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Current regulations on substances of high concern
The use of chemical substances is mainly regulated through the REACH (Restriction, Evaluation,
Authorization, and restriction of Chemical substances) regulation. The use of substances of very
high concern is strictly regulated and ECHA (European Chemicals Agency) helps textile producers
by making a list of banned chemicals to avoid during production and manufacturing of textile
products. Besides the Reach regulation other regulations apply to chemicals as well. This includes
the regulations on Classification, Labelling and Packaging (CLP), Regulations on materials and
products intended to come in contact with food, Regulation on cosmetic products and the
Regulation on persistent organic pollutants.
The General Product Safety Directive (GPSD) regulates the safety of products including textile
products. The Directive demands that producers cannot put products on the market when risks are
associated with that product. This includes risks of chemical substances. Mostly the GPSD refers
to national standards for specific product categories.
This report also investigates the ZDHC (Zero Discharge of Hazardous Chemicals) manufacturing
restricted substances list (MRSL). This is a list of chemicals of which the use should be avoided in
the production of textile products.
Potentially harmful chemicals related to design requirements
Design requirements can stimulate substitution by less hazardous substances or negligible use of
hazardous substances in a product. This report highlights some of the hazardous substances in
each step in the textile value chain based on the Best Available Techniques (BAT) Reference
Document for the Textiles Industry report46. A comparison between different chemicals and
indicating the environmental impact with a colour is not possible.

4.3

In depth analysis of supply chain

This paragraph gives an in-depth analysis of the value chain. For each of the steps the following
information is given where available:
 Technological processes used to produce, maintain, or dispose of textiles
 Technological challenges in the textile market



Relevant environmental impacts related to the place in the value chain
If available volumes of textile on the Dutch market

4.3.1
Fibre production, primary raw materials
This paragraph describes the production of the two widely used fibres in textile: Cotton and
polyester. Polyester and cotton together share about 75 % of the global market of raw materials.
In the Netherlands, this percentage is relatively high as this percentage is above 80 %47.

46
47

BREF News | Eippcb (europa.eu)
Beleidsprogramma circulair textiel (2020)

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Cotton fibre production
Cotton has an annual production of twenty-six million tons worldwide in 202048. It takes about
three months to fully grow and harvest cotton fibres after seeding. The fabric feels soft and
comfortable, is breathable and therefore is popular for use in textiles. The production of cotton
does not take place in the Netherlands as the climate is not suitable. China, the USA, and India
are the most important producers of cotton49. It is estimated that the worldwide production of
cotton will decrease due to the consequences of climate change50.
Environmental impact
Growing cotton is a water-intensive process and uses a large area of agricultural land. Traditional
farming uses synthetic fertilizer and pesticides, resulting in the release of nitrogen to the
atmosphere and groundwater and plays a role in soil degradation. Production of cotton is
comparable to producing any other agricultural crop, so it entails seeding, growing, and harvesting
the plants. This can be done with a higher or lower environmental impact. The current market
already offers organic cottons and some certification schemes for a more sustainable production.51
The environmental impact of organic cotton differs from traditional cotton farming as the use of
fertilizers and pesticides is prohibited (in the case of GOTS certified organic cotton). Land use in
the production of organic cotton, however, may increase due to lower production per hectare as
there is more land needed to grow a kg of organic cotton. Water usage largely dependents on
location. Comparing environmental impact between organic and traditional cotton production is
complex and is affected by local circumstances.
Table 4.2 environmental impact of cotton production
Impact category

Severity

GHG emissions

GHG emissions can be linked to fertilizer (NO2) and emissions from producing
livestock. In addition, fossil fuel-based agriculture machinery increases
greenhouse gas emission; value is high

Water usage

Agricultural production is a water intensive process on natural fibres; value is
high52

Microplastics

The production does not use plastics for growing the cotton crops; value is low

Potentially harmful chemicals

Traditional farming uses harmful fertilizers, pesticides, herbicides, and
defoliants. Organic cotton growers use no chemicals to produce the crop

48

Textile-Exchange_Preferred-Fiber-and-Materials-Market-Report_2021.pdf (textileexchange.org)
FAOSTAT
50
Cotton and Climate Change (wto.org)
51
All ecolabels on textiles | Ecolabel Index
52
(PDF) Life Cycle Based Comparison of Textile Ecolabels (researchgate.net)
49

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Polyester fibre production
The annual global production of polyester for textile fibre applications is around 61 million tons and
is increasing. The production of polyester fibre for textile applications predominantly occurs in
China and India.
Polyester fibres have several advantages that make them highly suitable for polyester-fibre-based
textile clothing. Examples are their strength, durability, and characteristics such as quick drying,
low temperature washing and almost no need to iron the textile20.
Environmental impact
Polyester is a fossil fuel-based plastic. There is plant-based polyester available on the market, but
it is available in small volumes and at a relatively high cost, which makes it unsuitable for fibre
production. Apart from its fossil fuel origin, polyester production requires a substantial use of
energy, generating high volumes of carbon emissions.
The production of plastic is known as a source of microparticles (e.g., pellets) that spill into surface
waters and end up in sediment and in the world's oceans.
Table 4.3 Environmental impacts of polyester fibre production
Impact category

Severity

GHG emissions

As it is a fossil-fuel based production; value is high

Water usage

Used as a cooling functionality for machinery53. However, in the production of
the monomers and polymers pollution of water is an important factor54; Value is
medium

Microplastics

As water is used for its cooling functionality there will most likely be a small
number of nano plastics (e.g., oligomers) in this wastewater; value is low

Potentially harmful chemicals

Ethylene glycol is used as antifreeze fluid, if there is a leakage this could be
fatal for humas55
Cyclic oligomers can be formed, migrate to the surface, and negatively affect
the dying process.
In some processes Antimony (Sb) is used as a catalyst. Trace elements of
Antimony can be found in the polymers. In the production of polymers used for
fibres the use of antimony is relatively common

4.3.2
Textile production
The produced fibres are shipped to factories where they are manufactured into yarns by spinning.
Those yarns are internationally sold on a global market. By different methods, such as weaving
and knitting, the yarns will be fabricated into fabrics.

53

Ecological Footprint and Water Analysis of Cotton, Hemp, and Polyester (sei.org)
WFA_Polyester_and__Viscose_2017.pdf (waterfootprint.org)
55
Polyester | Materials Index | CFDA
54

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In the Netherlands, the production of textiles has dramatically decreased and nowadays virtually
all yarns and fabrics are imported from producing countries in Asia and Africa56. The following
subparagraphs give more information on spinning, weaving, and knitting, finishing the fabric, and
producing the garment.
4.3.2.1
Spinning
Multiple techniques are available for mixing different fibres and spinning them into yarns. During
the process, relatively harmless to rather hazardous, chemicals can be added to dye or coat the
fibres. Currently there are a few innovative spinning initiatives in the Netherlands aimed at circular
textile applications.
Table 4.4 Environmental impacts of spinning yarn
Impact category

Severity

GHG emissions

The energy needed for spinning is relatively high. In addition, transportation
also contributes to GHG emissions; value is high

Water usage

Water used for the technique as well as a cooling functionality for machinery;
value is medium

Microplastics

Water technique spinning with polyester fibre will contribute to microplastics in
wastewater; value is medium

Potentially harmful chemicals

Conditioning agents and spinning lubricants used adds to air- and water
pollution

4.3.2.2
Weaving and knitting
Of all textile-production-techniques weaving and knitting are the most well-known techniques for
producing textile fabric. Every technique has its own impact on the characteristics of the produced
fabric. For example, the knitting technique provides elasticity in fabrics. When a textile is smartly
designed this can reduce the need for yarns that provide stretch, such as elastane. Weaving and
knitting of the fabrics mostly takes place outside of the EU. Before knitting of weaving yarns are
treated with a sizing agent which makes them smoother, which prevents them from breaking in
high-speed weaving looms.
Table 4.5 Environmental impact of weaving and knitting.
Impact category

Severity

GHG emissions

The weaving and knitting of the fabric are an energy intensive process, where
weaving is more energy intensive than knitting. In addition, transportation also
contributes to GHG emissions; value is medium

Water usage

Hardly any water is used during knitting/weaving; value is low

Microplastics

Water might be used for cleaning which might lead to microplastic pollution;
value is low

Potentially harmful chemicals

Lubricant, oils, and wax is used for protection against mechanical stress, this
contributes to the total amount of pollution of the mill

56

Interview Jan Mahy

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4.3.2.3

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Textile finishing

To enhance the performance of textile fabric mechanical or chemical treatments may be applied, for
example to textiles are dyed to improve their looks, coated to make the fabric water-resistant, flameretardant, air and vapor permeable or light blocking. These coatings are important for applications
where particular comfort, aesthetics or personal safety requirements play a role. To add these
coatings the fabric is pre-treated. Among others the fabric is desized. The sizing (smooth coating)
used to reduce yarn breakage during production is removed. Then the fabric is scoured, the
impurities found in the textile are removed, this prepares the fabric for dyeing and bleaching. After
these steps, the fabric is bleached. The natural colour of the fabric is removed. Another process is
dyeing, where synthetic chemicals are used to colour the textiles.
Table 4.6 Environmental impacts of textile finishing
Impact category

Severity

GHG emissions

The energy consumption of machinery used during manufacturing

Water usage

Intensive water usage in certain steps, e.g., dyeing; value is high

Microplastics

Wet processing of polyester fabrics; value is high

Potentially harmful chemicals

Large amount of strong alkali; PFAS; AOX emissions; formaldehyde
emissions; toxicity of dyes; melamine formaldehyde resins et cetera

4.3.3

Manufacturing of the textile product

In the final step of the production, fabrics are turned into textile produce by cutting and stitching or
gluing these materials to products. This may also involve adding accessories like buttons, zippers,
and sequins. Now the product is ready to be packed, shipped to markets, and sold in the physical
or online retail stores worldwide. It is estimated that in the Netherlands in 2019, 349 to 802 million
pieces of clothes were sold.57 This translates to 84 to 190 million kilograms of clothes in 2019.58
A particular feature of the online sales model is that it generates a substantial flow of clothing that
consumers return after purchase for several reasons, often for free. This return flow is sometimes
inspected, cleaned, ironed, and repacked, but it is assumed that a significant volume is not resold
but is destructed instead59. It is estimated that in the Netherlands 150 to 300 tonnes of unsold
clothes are incinerated60 to however it can be stated that the industry offers very little transparency
in this matter 61.
Table 4.7 Environmental impacts of manufacturing
Impact category

Severity

GHG emissions

The factory and transportation contribute to GHG emissions; value is low

Water usage

Not discussed in literature; value is low

Microplastics

Wastewater of product assembly not discussed in literature; value is low

Potentially harmful chemicals

No potentially harmful chemicals discussed in BAT report

57

Vernietiging ongebruikte goederen (2020) (overheid.nl)
Based on the assumption that the average weight of a garment is 240 grams. This is the same assumption as is made in the
previously mentioned report.
59
Onlinehändler Amazon vernichtet massenhaft Neuware (wiwo.de)
60
Vernietiging ongebruikte goederen (2020) (overheid.nl)
61
Retour Rumoer (nos.nl)
58

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4.3.4

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Product use

In 2018, the sale of textile products amounted to 248 kilotons of consumer clothes, 76 kilotons of
home textiles and 28 kilotons of workwear in the Netherlands62. When in use these textile products
require cleaning and maintenance on a regular basis, including washing, dry cleaning, ironing, and
repair, which varies per textile category.
Consumer clothes and household textiles of consumers
Consumer clothes and household textile are mostly home cleaned, tumble dried and ironed,
although dry cleaning outlets lauder substantial volumes as well. In the Netherlands, the average
washing temperature is approximately 40 degrees Celsius. Washing is done on average 143 times
a year in a Dutch household. On average 30 % of the laundry will be thermally dried in a tumble
dryer and 38 % of the textiles are ironed afterwards63.
Workwear and business to business household textiles
Workwear is often washed in large industrial laundry facilities. These facilities can be in-house e.g.,
in large hospitals where large amounts of workwear need to be washed. In other cases, workwear
is taken to an external industrial laundry facility. In these facilities the workwear is laundered and
checked for continued use, and eventually returned to the user. This is the case for many types of
workwear and business to business household textiles such as towels and bedsheets used in
hotels.
Table 4.8 Environmental impacts of the use phase
Impact category

Severity

GHG emissions

Washing machine and laundry facilities require power during operation; value is
high

Water usage

Washing machine and laundry facilitate use water for washing; value is high

Microplastics

Washing products discharges microplastics into wastewater; value is high

Potentially harmful chemicals

Type of detergent used

4.3.5
Consumer-to-consumer product reuse
It is important to consider the reuse of clothes as the prolonged use of the textiles is a way to
reduce the environmental impact of textiles64. Reuse can be stimulated by design requirements
aiming at longevity. Therefore, it is important to identify the structure that makes this prolonged
use possible.
Public awareness on the environmental impact of textiles has increased. Reuse has been
embraced by the public as a crucial step to reduce the environmental impact of textiles. As a
result, second hand retail stores and online platforms such as Vinted, eBay or Marktplaats have
emerged and become key players that facilitate consumer-to-consumer clothing reuse in the
Netherlands.

62

Monitor beleidsprogramma textiel
Monitor beleidsprogramma textiel
64
Textile reuse ’70 times better’ than the production of new garments - letsrecycle.com
63

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Consumer clothes
There is an increased interest in the reuse of consumer clothes. In 2018, 5 % of consumer clothes
in the Netherlands were reused by a new owner24. These clothes were collected and sold via
channels such as thrift stores. This amount does not include informal reuse or consumers selling
products to other consumers. It is assumed that the last type of reuse has grown over the last
years65. According to the Dutch mass balance of textiles, 53 % of all separately collected clothes
are reusable. Most of these reusables are reused outside of the Netherlands.66
Household textiles
There is no insight into the reuse percentages of household textiles within the Netherlands. It is
assumed that household textiles (used by consumers) are used until the product has reached the
technical end-of-life, as such it does not switch owner and is not ‘reused.’ These textiles are
sometimes disposed of for reasons such as becoming ‘unfashionable.’
Workwear
The business model of workwear is often built upon reuse, and it is assumed that in essence
workwear is worn until it does not comply with the standards within the sector. The laundry
facilities play a large role in the assessment and reuse of the workwear. Reuse may be hampered
when a company logo is added to the workwear, or if the workwear is a particular uniform67 that
must sometimes be destructed to protect the original owner from misuse of the uniform. In
addition, reuse is not possible when workwear has been designed for specific events.
Reusing textiles reduces the environmental impact of textiles. Some studies report that the
environmental impact of reused consumer clothes is up to 70 % less compared to new clothes68.
This is only the case when consumers purchase second hand textiles instead of new textiles.
When 2nd hand textiles are used as an addition to the existing wardrobe, the environmental impact
will not be reduced. Often, clothes will be shipped or mailed for reuse, which adds carbon
emissions to the reuse process.

4.3.6
Collection, identification, and sorting
The collection, identification and sorting steps are an important step in the value chain of textiles.
These steps determine if a textile gets reused, recycled, or used for energy recovery. A deep
understanding of these steps can help to identify design options of textiles that can help to
circularize the textile value chain. Sorting of mixed materials is more difficult than mono materials.
A considerable technology and investment gap in this step has been reported69 and requires
substantial innovations and accelerated scaling to allow for more accurate, faster sorting to
provide better feedstock quality.

65

De markt voor tweedehands kleding groeit als kool, maar hoe duurzaam is het eigenlijk? (trouw.nl)
Massabalans textiel 2018 (ffact.nl)
67
https://info.havep.com/hubfs/R-Ladder_Infographic_V4.pdf?_ga=2.80836119.1653167666.1675091423-1078526749.1675091423
68
Hergebruik van kleding leidt tot 70 keer lagere milieu impact blijkt uit nieuwe studie - Duurzaam Ondernemen (duurzaamondernemen.nl)
69
Circular fashion in Europe: Turning waste into value | McKinsey
66

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4.3.6.1

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Collection

It is estimated that in the Netherlands 45 % of all consumer textiles are collected separately. The
rest is disposed of in the residual waste. Textiles that are collected separately are identified and
sorted. Some of these collected textiles will be reused (see paragraph 4.4).
Consumer textiles (Consumer clothes & household textiles)
Consumer textiles are collected for reuse through different routes. There are organizations that
pick-up clothes from households by door-to-door collection, and municipalities often facilitate
textiles collection through dedicated textile containers in residential or shopping areas. In these
containers, consumers can drop off their clean textiles. The latter collection method introduces a
few challenges. Consumers also drop off other waste in these containers, which contaminates and
affects the reuse potential of the clothes inside. The percentage of residual waste and other
contaminants determines the quality of the textiles. These contaminants have increased in the last
few years70. In addition, the system cannot always cope with large input fluctuations71, although
some collection containers are being equipped with sensors to give an alert for emptying the
container.
Workwear
Workwear is often collected by the supplier of the workwear or the industrial launderer of the
workwear. This results in a relatively homogeneous waste stream. In 2020 it was estimated that
33 ktonnes was collected this way. However, it is estimated that 73 ktonnes of textiles from
businesses in 2020 were disposed of in the residual waste72.These residual textiles can include
workwear but also other kinds of textiles such as industrial cleaning cloths.
Table 4.9 Environmental impact of collection of textiles
Impact category

Severity

GHG emissions

Transportation within the Netherlands or outside of the Netherlands contributes
to GHG emissions; value is low

Water usage

Not discussed in literature; value is low

Microplastics

Misplaced discharged clothes on land; value is low due to geographical reasons

Potentially harmful chemicals

Not discussed in literature

4.3.6.2

Identification and sorting

Consumer textiles (Consumer clothes & household textiles)
Textiles that are collected in containers are manually sorted to a large extent into bespoke bales by
similar product types, e.g., T-shirts, jeans and household textiles, or colour.
Sorting clothes by material type is difficult and unproductive. The first mechanized sorting facilities
are being developed. However, there are some small-scale initiatives to automate sorting based on
colour and material.

70

Steeds meer textiel vervuild: dit gebeurt er als oude kleding in de bakken komt | RTL Nieuws
Kledingcontainers lopen door corona over met kleding: ‘Als dit nog even duurt, kunnen we hele sporthallen vullen’ | Gouda | AD.nl
72
Monitoring beleidsprogramma circulair textiel
71

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These initiatives mainly depend on NIR (Near InfraRed spectrophotometry) sorting technology.
This NIR technology is capable to identify the material type (e.g., cotton or polyester) and removes
some off the ‘guesswork’ that is involved in manual sorting31. This technology is currently in use in
the RTT (Regional Textielsorteercentrum Twente) in the Netherlands and installed on the
Fibresort equipment of Wieland Textiles.
Sorted and baled textiles are brought to the market. The quality of the bale determines the value of
the bale. Some of these textiles will be sold to be reused, either within NL or outside of NL.
Other bales are sent to recyclers.
4.3.6.3

Workwear

Workwear is often relativity easy to sort as it is manually collected in bulk streams. The potential
presence of Substances of Very High Concern (SVHC) e.g., due to coatings as fire retardants
poses a challenge for this sorting process.
Table 4.10 Environmental impact table on identification and sorting of textiles
Impact category

Severity

GHG emissions

Transportation within the Netherlands or outside of the Netherlands contributes
to GHG emissions; value is low

Water usage

Water usage has a cooling functionality; value is low

Microplastics

Wastewater of sorting not discussed in literature; value is low

Potentially harmful chemicals

During the sorting process of workwear workers might be exposed to harmful
chemicals in the waste

4.3.7
Recycling
Approximately 18 % of all textiles after collection is currently being recycled. The quality of
recycled textiles depends on the purity of the bale it is sorted in. Waste streams that consist of
single materials such as white hotel bedding will have a large potential to be recycled into a
valuable product. There are currently two main recycling technologies that can be used to recycle
textiles: mechanical recycling and chemical recycling. These recycling technologies can be used in
combination. The next paragraph discusses the differences between open-loop and closed-loop
recycling, and recycling methods.
4.3.7.1
Open-loop and closed-loop recycling
Distinction between open-loop and closed-loop recycling lies in what kind of product is made from
the recycled material. Open-loop recycling uses the recycled material as feedstock for other nontextile fibre-based products, e.g., sound isolation material in cars. These recycled products leave
the textile supply chain. Closed-loop recycling (also known as textile-to-textile or fibre-to-fibre)
aims at using the materials for new textiles production and will not leave the textile supply chain.
Currently high-quality recycled fabrics are more expensive than their virgin counterparts.

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Mechanical recycling

Mechanical recycling turns textiles into loose fibres. This is done by cutting and shredding the
textile. After recovering the fibres from the textile, the fibres can be respun into yarns. This type of
recycling is the most common type of recycling within the Netherlands. A large player in this field is
Frankenhuis in the Twente region, part of Boer Group73.
Mechanical recycling is a well-developed recycling process, but it has shredding stretchy materials
such as elastane and hard accessories such as zippers and buttons remains a challenge. In
addition, the shredding process leads to relatively short fibres, which makes it more difficult to
reuse the obtained fibres into new textile products. Besides, suboptimal sorting might result in
mixed fibres when mono materials are desired. Some initiatives focus on these difficulties and
research for opportunities for optimizing the mechanical recycled material to high-grade postconsumer recycled material74.
4.3.7.3
Chemical and dissolution recycling
Chemical recycling is mainly aimed at polyester-based textiles however cotton can be recycled
chemically as well. By dissolving or melting the textile fibres, a pure polymer remains. The
polymers can in turn be processed into a new yarn. This is possible for both cellulose based fibres
and ‘plastics’ such as polyester. CuRe within the Netherlands is developing a technology to
recycle polyester from textiles. It is anticipated that in 5 years this technology is capable of
recycling relatively large amounts of polyester. SaXcell is a party in the Netherlands that works to
recycle cotton fibres. It is estimated that within 5 years this technology can be widely implemented.
In Scandinavia there is more experience with the physical recycling of cotton or other cellulose
based textiles.
The CuRe technology is sensitive to certain contaminations e.g., the presence of a small
percentage of elastane, as low as 0.5 %, or other types of materials may disrupt the recycling
process. Common contaminants are labels, zippers, and threads of a different material. The
SaXcell technology reports similar sensitivities and potential disruption but can handle a small
percentage of pollutants. This sensitivity to contamination is confirmed in other literature sources75.
4.3.7.4

Other chemical recycling technologies

Chemical recycling completely returns the textiles into monomers, the basic building blocks of
plastics. This is achieved with enzymes or other chemical agents. These building blocks can in
turn be repolymerized and processed into a new yarn. Ioniqa in the Netherlands near Eindhoven
works to depolymerize PET, to produce new PET from textiles76. Just as chemical recycling this
type of recycling is sensitive for pollutants and requires thorough sorting and pre-treatment.

73

Boer Groep neemt textielrecyclaar Frankenhuis over (fd.nl)
Green Deal Circular Denim - Afval Circulair
75
Textiles for Circular Fashion: The Logic behind Recycling Options (wur.nl)
76
Ioniqa technology enables limitless PET recycling - Plastic Soup Foundation
74

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A very small percentage of textiles is being recycled into a raw material that can serve as a
feedstock for new textile production. Textile-to-textile recycling is only possible when the feedstock
is sorted well and has a high quality. It is expected that in the future the amount of textile-to-textile
recycling will increase. There are, however, some hitches to overcome77.
Table 4.11 Environmental impact table on recycling of textiles
Impact category

Severity

GHG emissions

The energy consumption of machinery used during manufacturing

Water usage

Water usage has a cooling functionality; value is low

Microplastics

Water only used as a cooling functionality; value is low

Potentially harmful chemicals

Shredding coatings added on products can release harmful chemicals to the
environment and might result in exposure of workers. No definitive data
available

4.3.8

Waste to energy

Textiles that are not sorted properly and combined with other household waste streams end up in
residual waste. These textiles are processed in (waste-to-energy) incineration plants in the
Netherlands. Textiles segregated from collection and sorting processes that cannot be reused or
recycled follow the same route. For 2020 it was estimated that 59 % of textiles was incinerated,
with 35 %-point of waste originating from consumers and 24 %-points from organisations.78
Table 4.12 Environmental impact of end-of-life textiles in incinerated plants
Impact category

Severity

GHG emissions

Incineration plants contributes to GHG emission, due to energy recovery value is
low

Water usage

Not discussed in literature; value is low

Microplastics

Not discussed in literature if there are microplastics in wastewater, but unburned
material in the bottom ash still has microplastics as a solid residue in incinerators79;
value is low

Potentially harmful

Harmful substances might be produced during this process. When incinerated

chemicals

properly these substances will not leak to the environment

4.4

Conclusion

Environmental impacts


The environmental impact of textiles can largely be attributed to the production phase and use
phase of textiles. The production of raw materials and wet processing are the processes with
the highest environmental impacts



GHG emissions is the highest during the production phase for both cotton and polyester fibre

77

Textielrecycling: wat zijn de mogelijkheden vandaag? (vdp.com)
Monitoring beleidsprogramma textiel
79
Is incineration the terminator of plastics and microplastics? - ScienceDirect
78

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

Water usage has certain areas in the textile supply chain where the amount of used water is



high. Mainly during cotton farming, wet processing and in the use phase
Microplastics are mainly released during the use phase. Microplastic are released because of
abrasion during the washing process



There are many processes in place to prevent the use of substances of high concern. REACH
is already in place, but additionally some industry partners have its own standards (ZDHC).
Workwear is one of the industries where Substances of high concern are commonly added.
Substances of high concern are added in the production phase but can lead to disturbances in
the recycling process and can influence the value and properties of recycled content

Table 4.13 An overview of the environmental impact value on each step of the textile supply chain
GHG emissions

Water usage

Microplastics

Potentially harmful

Raw material/

Fossil fuel

Cooling functionality

Neglectable

polyester

production

Raw material/

Agriculture

Water intensive

Neglectable

cotton

production cotton

process

Spinning

Factory and

Technique + cooling

Technique with

transportation

functionality

water

Factory and

Cooling functionality

Water only used for

Lubricant, oils, and

cooling

wax

Wet processing

Strong alkali; AOX

chemicals

Weaving/knitting

cyclic oligomers

transportation
Additional value to

Wet processing

Ethylene glycol and

Wet processing

Fertilizer and
pesticides

fabric

Preparation agents

emissions;
formaldehyde

Product

Product use

Factory and

Not discussed in

Not discussed in

Not discussed in

transportation

literature

literature

literature

Washing and drying

Washing and drying

Discharged

Type of detergent

wastewater

used; chemicals
present in the
product might leach
out of the product
during washing

Collection

Identification /

Transportation

Transportation

Cooling functionality

Cooling functionality

sorting
Recycling

Factory and

Cooling functionality

transportation

Misplaced

Not discussed in

discharged clothes

literature

Not discussed in

Can add to harmful

literature

chemicals to waste

Water only used for

Shredding coatings

cooling

can release
chemicals

Waste to energy

Factory and energy
recovery

Cooling functionality

Not discussed in

Unburned materials

literature

leaking into the
environment

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Supply chain


In NL there is limited production, mainly of high-quality workwear and technical textiles.
The Netherlands does have a solid recycling industry, which however needs accelerated
upscaling to commensurate with increasing amounts of (sorted) post-consumer textile



streams, which are less and less being exported outside of the country
Currently mechanical recycling is the most common recycling technology, chemical is an
emerging technology and will most likely be established in 5 years



Following R-strategies is a way to reduce the environmental impact

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5 Textiles key issues and the complexity of the textile
market
Textiles are complex materials from economic, technological, and esthetical aspects. Another
layer of complexity is added through the wide variety of textile products and their applications.
The functionality and specifications of a sock differs from a coat, and even within the coats
segment there is a large variety of purposes, materials, and qualities. Some clothes are meant to
last while other textiles are designed with a short life span in mind.
The main goal of the ESPR is to reduce the environmental impact of products. However, it is
important to note that only performance requirements cannot stop impactful practices. This should
fit within a larger policy structure.
In this chapter the following points are discussed:
 Identified key issues (per defined product category) that hamper the transition to a more
sustainable textile value chain


Best practices that facilitate the transition towards a more sustainable textile value chain

This chapter will be the basis for the performance requirements.

5.1

Key issues of consumer textiles

Fast fashion
The Netherlands' consumer clothing market accounts for roughly 50 % of the country's textile
industry. However, not all garments are designed to withstand the test of time, particularly those
considered ‘fast fashion.’ The fast fashion industry thrives on four factors according to the report
Fast fashion Onderzoek, published in 202080.
 The competitiveness of the market
 The long supply chain of the products



The dependability on other actors in the supply chain
Consumerism

These factors show that the impact of fast fashion trend is a multifaceted issue that requires more
than just design solutions. It is crucial to acknowledge that fast fashion impedes the development
of a sustainable fashion supply chain. While clothing that has a longer life span comes with a
lower environmental impact81, increasing the quality of clothes does not always lead to a reduced
environmental impact.82 Higher quality clothing can result in higher environmental impacts. If the
higher quality does not lead to a longer use phase because the product is discarded because of a
change in fashion the total environmental impact goes up.

80

Fast fashion onderzoek
ECOS-REPORT-HOW-ECODESIGN-CAN-MAKE-OUR-TEXTILES-CIRCULAR.pdf (ecostandard.org)
82
Fast fashion onderzoek
81

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Durability of textile
To reduce the environmental impact of clothing a simple measure is to use clothes for a longer
period. However, the durability of clothes depends on several factors, of which the technical and
emotional factors are most important. Between 50 - 60 % of all clothes are discarded because of
technical issues, such as loss of shape, or stains that cannot be removed. But it is essential to
note that the remaining 40 to 50 % of all clothes are discarded because of other reasons such as
improper fit (the wearer may have gotten another size) or because the consumer is bored of the
product.
The lifespan of clothes can be improved by repairing clothes. It is noted that consumers in the
Netherlands are starting to be aware of the use to repair clothes. However, to a large majority and
due to low quality clothing, it is considered expensive and therefore the consumer still prefers
rather to buy new clothes83. In addition, consumers often lack the knowledge to repair the textile
product at home.
Fabric design
The qualities and performance of fabrics can be altered by mixing different type of materials
together. This increases the aesthetics, comfort, or the strength of the fabric. These types of
fabrics are known as blends. Blends are also created to reduce the costs of the fabric as some
raw materials are more expensive than others, e.g., cotton is becoming much more expensive
than polyester fibre feedstock. Recycled content can be blended into fabrics. However, the
recycled content with a high quality, such as from chemical recycling, is currently more expensive
than their virgin counterpart due to limited chemical recycling volumes available in Europe. Blends
cannot be recycled as easily as mono materials.
In addition to textile blends, accessories can be added to textiles, such as rivets, prints, and
beads. These combinations of multiple materials hamper recycling opportunities significantly.
In conclusion:
 By setting requirements for consumer textiles, the largest reduction of environmental impact
can be established because around four fifths of the textile fibres are used in consumer


textiles.
Environmental impact can be reduced through two circular strategies:
Lengthening the use phase
-



Lowering the environmental impact of the production phase by using recycled content and
by making clothing recyclable
These strategies complement each other but can be in contradiction as well. Recycled content
can lower the lifetime of a product as the current recycling technology yields shorter fibres
resulting in a lower yarn strength. Whereas very strong and durable clothing might consist of
multiple materials which can hamper recycling

83

D&B - Gedragsonderzoek kleding IenW (2).docx (overheid.nl)

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

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Therefore, we suggest that there should be differentiation between consumer clothes that are
made to last and consumer clothing that are made to have a shorter life cycle. The end goal is
to extend the use phase of textiles as much as possible, but this goal cannot be reached with
only performance requirements. With the current situation overengineering textiles will lead to
an increased environmental impact, extending the technical durability beyond the
social/esthetical life of the textile product. We suggest the following differentiation:
For short cycle textiles the focus will be on recycled content and recyclability. Short cycle

-

clothes are not meant to last for a long time and are typically disposed of within two years
of purchases
For long cycle textiles the focus will be on durability and repairability. Long cycle textiles



are meant to last and will typically be worn for (much) more than two years
In a later phase the final differentiation should be finalized
It would be beneficial to limit the number of materials in fabrics as this makes recycling easier



Recycling should be stimulated by creating a market for recycled fibres with a textile origin

5.2

Key issues textiles for household textiles

One of the most notable features of household textiles is their durability. They are less susceptible
to fashion influences and often last until the product has reached the technical end of life of the
product. It should be noted that household textiles do slightly become more and more susceptible
to interior fashion.
Household textiles are affected by how they are used and in particular, how they are laundered.
They are often cleaned at high temperatures with detergents with a high PH (~pH 10).
This deteriorates the quality of the fibre over time.
Another key property of household textiles is that they are not made with complicated blends.
This makes them easier to recycle since they do not have to be separated into different materials
before recycling.
It is important to note that while household textiles used by consumers (B2C) have similar
performance specifications as those used professionally (B2B), but the latter often follow the same
laundry and cleaning processes as workwear and are used with higher intensity.
In conclusion:





It is important that household textiles keep their long lifespan
Household textiles can be a good source for recycling because of their relative uniform
composition. However, the quality of the fibre is relatively low due to the attrition rate because
of the long use phase
Distinguishing performance requirements between professional and consumer household
textiles might be beneficial, to reduce the environmental impact

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5.3

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Key issues textiles for workwear textiles

The workwear sector accounts for approximately 5 % of the Dutch textile market. Workwear is
primarily business-to-business, providing essential clothing, uniforms, and protective gear as well
as clothing for short events like festivals.
Workwear is often leased to the user in a business-to-business context. Producers/importers work
closely together with the professional laundry facilities. These businesses which focus not solely
on selling products but on service models often focus on durability within their business models,
as they must balance the costs of replacement with the needs of their consumer.
One of the most significant factors influencing the design and production of workwear is safety.
Workwear manufacturers and suppliers prioritize the safety of their products when designing and
producing workwear. Prioritizing safety might mean that chemicals such as PFAS or flame
retardants are added to the textile. This is not relevant for all types of workwear, e.g., hospital
workwear has different standards than the protective gear firefighters wear. In general, the
workwear industry regulates itself quite efficiently. Therefore, we propose to divide the category
workwear into protective and non-protective workwear.
Protective workwear has high standards, specific norms, and regulations for the safety of the end
user. For non-protective workwear lower standards are needed, which leaves more room for
ecodesign requirements to increase circularity in this category. Most business models in the
workwear industry are focused on longevity, although some promotional workwear is designed for
one day. To maximize the effectiveness of performance requirements for promotional workwear,
overengineering the quality of the textile product should be avoided. Therefore, we make the same
distinction between long and short cycle within the non-protective workwear category.
Security is an important issue when disposing of workwear. In some industries, workwear must be
destroyed after use due to security concerns. For example, military uniforms and police gear.
These clothes are often recycled as they are disposed of in large batches with the same
composition.
In conclusion



The workwear cycle is controlled by producers that service the products as well. As such the
practices within the Netherlands are relatively sustainable
Safety of the workwear must be guaranteed and therefore is a category on its own




The performance requirements should focus on non-protective workwear
Non-protective workwear is divided into long and short cycle, due to differences between
promotional workwear and e.g., hospital workwear



Disposables are excluded in the development of performance requirements

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Best practices and initiatives that work towards a sustainable value
chain

Within the Netherlands there are several initiatives that aim to increase the sustainable value of
the textile value chain.
Dutch Circular Textile Valley
The Dutch Circular Textile Valley works on creating a circular textile supply chain to lower
environmental impacts. With hubs in Twente, Amsterdam, Gelderland and Tilburg, the foundation
connects, innovates, and speeds up the transition to circular textiles.
TexPlus
The TexPlus Foundation is a cooperation between 6 frontrunners in the field of circular textiles.
This local cooperation is based in Twente, in the Netherlands. These frontrunners are active in
collection, processing, and the manufacturing of end products. The entire supply chain on a
regional scale represented within this project. The objective of the TexPlus foundation is to
connect and collaborate within the supply chain partners from collection to reuse in other regions
in the Netherlands. This objective is achieved by stimulating the reuse of textile products and
using innovative techniques to recycle non-reusable textile products to the highest possible quality.
They do this by actively involving the market in the development and application of recycled textile
materials. Moreover, TexPlus is the ‘recycling technology hub’ of the Dutch Circular Textile Valley
organization.
Dutch denim deal
More than 50 different national and international parties have signed the Dutch Denim deal. These
parties all have different roles in the value chain. The brand owners and retailers have committed
to achieve the specific, joint goal of using 20 % PCR cotton fibres in three million pairs of jeans
produced by these parties during the term of this Denim Deal. In addition to this, brands and
retailers have committed to achieving a minimum of 5 % PCR content in their denim collections
during this period by working together closely with other parties. Higher individual targets for PCR
in the denim clothing is set as well.
In conclusion
 It is important that the value chain is stimulated to work together in their efforts to reduce the
environmental impact



Opportunities for reuse and recycling at the end-of-life phase must be considered in the
design phase
Developing high quality recycled fibres is possible with a good collaboration in the market

The denim deal has shown that is possible to add 5 to 20 % post-consumer recycled cotton to
denim consumer clothes
Adding recycled content to textiles can reduce the environmental impact of the garment as the
production for the raw materials is not necessary anymore

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6 Performance requirements
Through literature research and the input of textile experts and stakeholders performance
requirements have been created in line with the ESPR framework. This chapter elaborates on the
performance requirements for textile products in scope of this project: household textiles,
consumer clothes and workwear.
Due to the scope of clothing products in combination with fashion, esthetical and economical
perspectives, this category is divided into two lifespan cycles, the short cycle, and the long cycle.
Each cycle has its own performance requirements. The short cycle is designed for recycling and
contains as much post-consumer textile recycled content as possible. Long cycle on the other
hand is designed for durability to extend the use phase of the product and may contain
pre-consumer recycled textile content.
The same division between long cycle workwear (e.g., uniforms) and short cycle (e.g., festival, or
promotional clothing) is made for workwear. We recommend abstaining from performance
requirements for protective workwear (personal safety equipment as defined in Regulation (EU)
2016/425 of 9 March 2016 on personal protective equipment). Protective clothing must primarily
protect the user from safety incidents and is therefore highly regulated. It is not clear whether the
safety levels of protective gears may be compromised by ecodesign requirements. Therefore, we
recommend investigating the potential impact of ecodesign requirements on the safety levels
before suggesting these for ecodesign regulation. Moreover, the market share of protective
workwear in the textile market is relatively small and protective workwear usually already has a
long lifetime. Therefore, we propose to exclude the safety work wear category from ecodesign
requirements. This subcategory may be added at a later stage.
Household textiles have a relatively long lifecycle as well as a relatively simple composition.
Therefore, the division between long and short lifecycle has not been made for this category.
The performance requirements should focus on longevity as well as on recyclability and recycled
content.
This chapter follows the framework of sustainability aspects of a product as mentioned in the
ESPR. Table 6.1 gives these aspects and their relevance for textile products. The following
paragraphs describe the most relevant aspects in more detail per textile category and proposes
performance requirements based on these aspects. This chapter finishes with recommendations
and conclusions.

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Table 6.1 Overview of the ESPR aspects and their relevance for the different textile groups
ESPR aspect

A. Durability

Household

Consumer

Consumer

Workwear

Workwear

textiles

clothes

clothes

Short cycle

Long cycle

Short cycle

Long cycle

Not the main

Yes

Not the main

Yes

Yes

focus

focus

B. Reliability

Not relevant

Not relevant

Not relevant

Not relevant

Not relevant

C. Reusability

Yes

Not the main

Yes

Not the main

Yes

focus

focus

D. Upgradability

Not relevant

Not relevant

Not relevant

Not relevant

Not relevant

E. Repairability

Yes

Not the main

Yes

Not the main

Yes

focus

focus

F. Refurbishment

Not relevant

Not relevant

Not relevant

Not relevant

Not relevant

G. Presence harmful substances

Yes

Yes

Yes

Yes

Yes

H. Energy use or efficiency*

Not relevant

Not relevant

Not relevant

Not relevant

Not relevant

I. Resource use or efficiency

Other

Other

Other

Other

Other

regulation

regulation

regulation

regulation

regulation

J. Recycled content

Yes

Yes

Yes

Yes

Yes

K. Remanufacturing or recycling

Yes

Yes

Yes

Yes

Yes

L. Recovery of materials**

Not relevant

Not relevant

Not relevant

Not relevant

Not relevant

M. Environmental impacts***

Yes

Yes

Yes

Yes

Yes

N. Expected generation of waste

Other

Other

Other

Other

Other

regulation

regulation

regulation

regulation

regulation

* Energy use or efficiency by the textile itself is not relevant, however energy usage in production or care is. These
are covered under M and should be addressed by care instructions
** Recovery of materials (energy recovery) is a lower step in the waste hierarchy than recycling. Therefore, we focus
on recycling (K.)
*** The environmental impact can be made clear through a product passport. One aspect which falls under this
aspect is the release of microplastics

Other regulation means regulation through another instrument (discussed in chapter 3) e.g.,
information provision through material passports.

6.1

A. Durability

Durability is the most important characteristic of a textile product when trying to lower its
environmental footprint. An extended lifetime should stimulate a consumer to wear or use the
product multiple times instead of buying new products, which results in a reduction of the
environmental impact. Longevity of a product requires certain quality standards, in which
three aspects are important:
1.
2.
3.

Technical durability
Economical durability
Esthetical durability

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These aspects have a mutual dependency, see also chapter 5. Regulation through performance
requirements based on the ESPR can only focus on the technical durability. In the following
subparagraphs the technical durability has been elaborated for each category.
Technical durability is about the mechanical quality of the textile product, e.g., its strength to
prevent tears, or its colourfastness and dimensional stability when laundered. To understand how
to increase technical durability for an extended use phase, it is important to know the reason(s)
why consumers dispose of their products. Having these insights helps setting standardized
performance requirement that promote durability and longevity.
If textiles are disposed of due to technical imperfections, the most important reasons are84,85:
1. Visual appearance (discolouring or fading, shape/fit, pilling)
2. Stains
Good quality clothing retains a good visual appearance after multiple washes. For various aspects
of the visual appearance tests and standards exist. These standards can be applied as
performance requirements and a minimum number of washing cycles could be set as a norm.
Prevention of stains is very difficult. Some types of fibre are more susceptible to staining than
others. A shift towards more stain-resistant fibres could mean a shift towards more synthetic
fibres. This is not necessarily better for the environment. Surface treatment might help in
preventing stains; however, this introduces extra materials/substances with consequent
environmental impact. Removing stains is done regularly by washing textile products. Although not
all stains can be removed, good care instructions might help in the removal of stains. So, design
requirements for preventing discarding because of stains could be aimed at good care
instructions.
6.1.1
Check on ESPR criteria
The performance requirements for durability should comply with the ESPR criteria of article 5.586.
The table below shows the check with these criteria.
Table 6.2 Durability performance requirements comply with the ESPR criteria
Product
category

Significant
negative
impact on the
functionality

Adverse
effect on
health and
safety of
persons

Impact on
affordability
of relevant
products also
second-hand

Negative impact
on
competitiveness

Proprietary
technology
imposed

Administrative
burden on
manufacturers

Household

-

-

-*

-

-

X

-

-

X*

-

-

X

textiles
Short cycle
consumer
clothing

84

Making Clothing Last: A Design Approach for Reducing the Environmental Impacts (ijdesign.org)
Interviews with experts of independent knowledge centers and Dutch stakeholders
86
Proposal for a Regulation on Ecodesign for Sustainable Products (europa.eu)
85

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Product
category

Significant
negative
impact on the
functionality

Adverse
effect on
health and
safety of
persons

Impact on
affordability
of relevant
products also
second-hand

Negative impact
on
competitiveness

Proprietary
technology
imposed

Administrative
burden on
manufacturers

Long cycle

-

-

X*

-

-

X

-

-

X*

-

-

X

-

-

-*

-

-

X

consumer
clothing
Short cycle
workwear
Long cycle
workwear
-

No negative impact on this subject

-*

No impact on affordability of relevant products also second-hand, estimated that the number of washing
cycles is already being met

X

Complying with durability standards might result in an administrative burden

X*

Might increase the impact on affordability of relevant products also second-hand, but probably lowers the
total cost of ownership.

6.2

C. Reusability

As reusability is strongly linked with durability for textile products, no additional performance
requirements for reusability have been included.

6.3

E. Repairability

Repairability is most important when one single defect such as a broken zipper or a missing button
prohibits the use of the product. Consumers or owners do not always have the skills needed to
repair textile products, while outsourcing the repair is sometimes more expensive than buying a
new product. But even if repair is possible and cheaper than replacement, consumers may decide
to discard a product, for instance because it is more hassle to repair than to buy new or due to the
desire for a new product.
Repairability is most important for products with a long technical lifetime and a high value,
therefore we recommend focusing on the long cycle categories. Repairability performance
requirements should be aimed at making replacement components available and making
information available about the correct replacement component. The latter is not so much a
performance requirement, but a requirement to accompany the product with the right information.
This could be in the form of an online product passport.
6.3.1
Check on ESPR criteria
The performance requirements for repairability should comply with the ESPR criteria of article 5.5.
This subparagraph shows the check with these criteria.

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Table 6.3 Repairability performance requirements comply with the ESPR criteria
Product
Significant
Adverse
Impact on
Negative
category
negative
effect on
affordability of
impact on
impact on
health and relevant
competiti
the
safety of
products, also
veness
functionality persons
second-hand
Household

Proprietary
technology
imposed

Administrativ
e burden on
manufactures

-

-

X

-

-

X

-

-

-

-

-

-

-

-

X

-

-

X

-

-

-

-

-

-

-

-

X

-

-

X

textiles
Short cycle
consumer
clothing
Long cycle
consumer
clothing
Short cycle
workwear
Long cycle
workwear
-

No negative impact on this subject

X

Repair services and stocking of components could increase the price and the administrative burden on
manufactures

6.4

G. Presence of substances of concern

The presence of certain substances in textile products is reason for concern. Therefore, the use of
chemicals in products and other places in society is addressed by the chemicals regulation, such
as the EU REACH-regulation, CLP regulation and other regulations, e.g., the persistent Organic
Pollutants Regulation. Regulation of substances of concern through performance requirements is
allowed only when the regulation is not aimed at chemical safety and food safety. In the Council of
the European Union proceedings87 it is explicitly mentioned that
To overcome this limitation (Chemicals legislation cannot restrict hazardous chemicals based on
sustainability), this Regulation should allow, under certain conditions, for the restriction, primarily
for reasons other than chemical or food safety, of substances present in products or used in their
manufacturing processes which negatively affect products’ sustainability.
It says further:
The Commission, when setting performance requirements, the Commission should be able to
prevent substances that hinder circularity from being included in a product. The identification of
such substances should be part of the Commission’s assessment prior to the setting of Ecodesign
requirements for a specific product group and the Commission should in this assessment, for
instance, take into account whether a substance makes the re-use or recycling of a product more

87

Interinstitutional file 2022/0095 (COD) (europa.eu)

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complicated or negatively affects the properties of the recycled material, for example through its
colour or smell.
Interviews with Dutch stakeholders of the textile supply chain made us conclude that the
legislative processes to regulate new substances through REACH are slow. To fast track the
restriction of emerging substances of concern in the production chain, the textile industry works
with industry standards, e.g., the Manufacturing Restricted Substances List (MRSL) issued by the
Zero Discharge of Hazardous Chemicals foundation.
We suggest that restriction of hazardous substances should be regulated through the REACH
regulations. As no “substances” were reported that hamper incorporating circularity in a product
we do not recommend regulation of substances through ecodesign product requirements.
However, the presence of substances of concern should be communicated to the users of textile
products and therefore we recommend setting the presence of substances of concern in the
information requirements.

6.5

I. Resource use or resource efficiency

The resource use or resource efficiency varies widely between different types of products and
varies with the supply chain and logistics. As there is not enough information at this moment to set
standards for resource use or resource efficiency, we recommend making it mandatory for
producers to make this information available in a product passport in due course.
6.5.1
Check on ESPR criteria
The performance requirements for resource use or efficiency should comply with the ESPR criteria
of article 5.5. This subparagraph shows the check with these criteria.
Table 6.4 Resource use or efficiency performance requirements comply with the ESPR criteria
Product category
Significant
Adverse
Impact on
Negative
negative
effect on
affordability of
impact on
impact on the health and
relevant
competiti
functionality
safety of
products, also
veness
persons
second-hand
All categories
X
-

Proprietary
technology
imposed

Administrative
burden on
manufactures

X*

X**

-

No negative impact on this subject

X

Might increase the price of a product significantly, depending on the granularity of environmental
information required to include

X*

The product passport should be open source.

X**

Administrative burden on manufactures could be high, depending on the calculation method

6.6

J. Recycled content

Recycled content can lower the environmental impact significantly compared to virgin materials.
As the current production chain of short cycle textiles has a high environmental impact, while the
products have a short lifetime, the impact of short cycle products can be reduced significantly by
applying a high content of recycled fibres. To make the textiles sector circular the production of
short cycle clothing should apply high volumes of recycled post-consumer fibres.

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The fibre quality made from mechanically recycled materials will be less than the quality of fibres
made from virgin materials, particularly when fibres are recycled multiple times. The lifetime of
long cycle products could be substantially affected by adding too much post-consumer recycled
content. Therefore, we recommend applying post-consumer recycled content in short cycle
clothing and only allowing pre-consumer recycled fibres in long cycle clothing.
Currently less than 1 % of the textile products are recycled into new fibre materials. As mandatory
recycled content requirements expect the availability of recycled fibre materials, the recycling
industry will have to scale up quickly to produce sufficient volume of fibres. Consequently,
mandatory recycled content will have to start at relatively low levels, even though technically
higher levels of recycled material can be applied in textile products. With the expansion of the
recycling industry mandatory levels of recycled content should increase over time.
6.6.1
Check on ESPR criteria
The performance requirements for recycled content should comply with the ESPR criteria of article
5.5. This subparagraph shows the check with these criteria.
Table 6.5 Recycled content performance requirements comply with the ESPR criteria
Product
Significant
Adverse
Impact on
Negative
Proprietary
category
negative
effect on
affordability
impact on
technology
impact on
health and
of products,
competitive
imposed
functionality safety of
also secondness
persons
hand
Household X
X*
textiles
Short
X
X*
cycle
consumer
clothing
Long cycle -*
X
X*
consumer
clothing
Short
X
X*
cycle
workwear
Long cycle -*
X
X*
workwear

Administrative
burden on
manufactures

X**
X**

X**

X**

X**

-

No negative impact on this subject

-*

At the proposed recycled content, no impact is expected, when increased in time at a certain point could
affect quality

X

Products will probably become (marginally) more expensive

X*

It is important that transparency on the origin of recycled content is open source

X**

Administrative burden on manufactures could be high

6.7

K. Possibility of remanufacturing and recycling

The possibility of remanufacturing and recycling will have a high impact on the total amount of
textile waste. To create a more circular textile value chain increasing closed loop fibre to fibre
recycling is most important. Not only will increasing recycling rates promote circularity, also it will
create a fibre volume that allows for the uptake of recycled content. The ideal situation is
designing textile products that can be recycled for 100 % when the product is discarded.

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While durability is a particular performance requirement for long cycle products, remanufacturing
and recycling is a clear goal for short cycle products.
The current state of recycling technology does not facilitate the recycling of a range of fashionable
materials such as additional prints, metal rivets, paillettes etc. To achieve high recycling rates
such materials should therefore be restricted for short cycle textile products. Mandatory high
textile recycling rates will therefore have a negative influence on the designers’ freedom and may
have commercial impacts. In time, such materials should be restricted for long cycle textile
products as well. This should be revised after five years.
6.7.1
Check on ESPR criteria
The performance requirements for remanufacturing and recycling should comply with the ESPR
criteria of article 5.5. This subparagraph shows the check with these criteria.
Table 6.6 Remanufacturing and recycling performance requirements comply with the ESPR criteria
Product
Significant
Adverse
Impact on
Negative impact Proprietary
Administrative
category
negative
effect on
affordability on
technology
burden on
impact on
health
of relevant
competitiveness imposed
manufactures
the
and
products,
functionality safety of
also
persons
secondhand
All

-*

-

X

-

X*

X**

categories
-

No negative impact on this subject (long cycle workwear category need more research when percentage is
high)

-*

No negative effect expected for functionality. Aesthetics might be impacted

X

Products may become more expensive

X*

It is important that transparency on material composition is open source

X**

Administrative burden on manufactures could be high

6.8

M. Environmental impact (Emission of Microplastics)

The previous paragraphs have discussed performance requirements that aim to reduce the
environmental impacts of textile products. This chapter introduces another way to reduce the
environmental impact of textiles by means of reducing microplastic emissions. In addition, two
suggestions are made to increase the transparency about the environmental impact and allow
consumers to make conscious decisions. Although these suggestions aimed to increase the
transparency are out of the scope for the current project, it should be considered in future
initiatives.
Reduce Microplastic Emissions
One of the key issues in the textile supply chain is the release of microplastics during the use
phase of textile products. There is consensus that the bulk of microfibers is released during the
first few laundry cycles of a product. One option to contain the release of microfibers is to launder
the product before bringing it to the market, using laundry facilities equipped with filters to capture
the released microplastics.

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Increase transparency by means of a label and within a product passport
Another way to reduce the environmental impact is to increase transparency on the environmental
impact of textile products and allow consumers to make conscious decisions. This can be
achieved through a sustainability label that shows the sustainability score of a textile product, such
as an A, B, C, D or E score. The label should be based on the PEF for textiles that will be
published in 2024. The label should be understandable for consumers and differentiate between
different types of garments, such as underwear, household textiles, and coats.
The full overview of environmental impacts should be mentioned in the to-be-developed product
passport for textiles.

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7 Recommended performance requirements
This chapter provides recommendations for performance requirements for the various product
categories. It starts with three general recommendations for all product categories. Paragraphs 7.2
to 7.6 elaborate on the performance requirements for the individual textile categories.
These performance requirements were developed in close consultation with progressive
stakeholders. Although garments can be made, and have been made, with more ambitious
eco-designs, such as higher recycled content up to 20 %, the presented performance
requirements are quite ambitious for the European market as a whole. The global infrastructure to
supply recycled materials (collection - recycling - spinning - weaving/knitting) is almost nonexistent at this moment, so it needs to be built from scratch. Therefore, the recommended
performance requirements on recycled content start at the lowest practical percentage, but quickly
ramp up within a few years. This will allow for building and optimizing the required infrastructure.

7.1

General performance requirements

The three general recommendations are repairability, substances of concern and environmental
impact. Each explained in more detail in the next paragraphs.
7.1.1
Repairability
Repairability is most important for products with a long technical lifetime, and a high value. It is
important that consumers and repair professionals know what component they need to repair the
product and that a replacement for this product is available.
Table 7.1 Performance requirements for repairability
Repairability for textiles with a long lifespan
For all types of long cycle clothing, spare components must be readily available on the market. In the case of
bespoke items, spare parts must be orderable

7.1.2

Substances of concern

For all categories, the application of substances of concern in products should primarily be
regulated through chemicals and not through performance requirements at this stage. As this
legislation is aimed at chemicals on the European market performance requirements aimed at the
use of chemicals in the production chain can be made. These performance requirements should
be aimed at sustainability and/or reaching higher circularity. The textile industry already works with
such industry standards e.g., the Manufacturing Restricted Substances List (MRSL) issued by the
Zero Discharge of Hazardous Chemicals foundation. This list is aimed at protecting workers, local
communities, and the environment from the possible impacts of harmful chemicals. Therefore, we
recommend adopting this MRSL.

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Table 7.2 Performance requirements for substances of concern
Substances of concern through performance requirements
All additional substances of concern in the MRSL issued by the Zero Discharge of Hazardous Chemicals
foundation, which are not in REACH, should be regulated through performance requirements. On a regular basis
this list should be revised

7.1.3
Environmental impact / Emissions of microplastics
One key issue in the textile supply chain is the emission of microplastics during the use phase of
textile products. Various institutes investigate the opportunities to reduce the release of
microfibres from textile products, but no standard has yet been developed.
There seems consensus on the fact that the bulk of microfibres are being released in the first
laundry cycles of a product. Our proposed performance requirement is aimed at the primary
washing cycle.
Table 7.3 Performance requirement for environmental impact
Reduce environmental impacts of textiles
All cloth must be washed before it is brought to the market. This must be done in laundry facilities that are
equipped with filters that capture the released microplastics

7.2

Performance requirements for household textiles

Household textiles generally have a long life and can easily be recycled because of their relatively
simple (i.e., mono material) design. Therefore, the performance requirements should focus on
promoting longevity as well as on recycled content and recyclability. We recommend the following
performance requirements for household textiles.
Table 7.4 Performance requirements for household textiles
Household textiles

Performance requirements

Technical durability

Minimum requirement

After the number of washing cycles, the textile product



must still comply with:


The household textile must withstand at least
100 washing cycles

ISO 12947-2 (2016) - ‘Textiles - Determination of

Progressive requirement

the abrasion resistance of fabrics by the



Martindale method - Part 2: Determination of

The household textile must withstand at least
150 washing cycles

specimen breakdown’88
Recycled content

Starting at 5 % per item in 2027, to be raised with 3 %



Only post-consumer recycled content

annually



Closed loop (textile-to-textile) should be the
standard

88

Possibility for recycling



Promote the use of mono materials



Aesthetic additions to textiles that hamper



No multi-layer materials

recycling are prohibited



No metal rivets

ecodesign_criteria_for_consumer_textiles.pdf (europa.eu)

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Household textiles

7.3

Performance requirements


No paillettes



No metal/ glitter yarn



No PVC/PU printing

Consumer clothing - short cycle

For the short cycle consumer clothing the focus is on high levels of recycled content and
recyclability. For this category, the recycled content should be sourced from post-consumer
textiles (closed loop). The recommended performance requirements are given in the following
table.
Table 7.5 Performance requirements for short cycle consumer clothing
Short cycle consumer clothing

Performance requirements

Technical durability

Minimum requirement

After the number of washing cycles, the textile product



should still comply with:


Short cycle consumer clothing must withstand at
least 20 washing cycles

ISO 15487 (2018) - Textiles - Method for

Progressive performance requirement

assessing appearance of apparel and other textile



end products after domestic washing and drying

Short cycle consumer clothing must withstand at
least 30 washing cycles

Recycled content

Starting at 5 % per item in 2027, to be raised with 3 %



Only post-consumer recycled content

annually



Closed loop (textile-to-textile) should be the
standard

Possibility for recycling



Promote the use of mono materials



Aesthetic additions to textiles that hamper



No multi-layer materials, or easily detachable

recycling are prohibited



No metal rivets



No paillettes



No metal/ glitter yarn



No PVC/PU printing

7.4

Consumer clothing - long cycle

For long cycle consumer clothing, the focus is primarily on promoting durability and longevity of
the product. The application of (preferably pre-consumer) recycled textile material in new products
is mandatory to reduce the environmental impact of the textile chain, starting at 5 % and growing
year-on-year with the expansion of the recycling industry.
Table 7.6 Performance requirements for long cycle consumer clothing
Long cycle consumer clothing

Performance requirements

Technical durability

Minimum requirements

After the number of washing cycles, the textile product



should still comply with:

Long cycle consumer clothing must withstand at
least 40 washing cycles

Progressive performance requirement

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Long cycle consumer clothing

Performance requirements





ISO 15487 (2018) - Textiles - Method for
assessing appearance of apparel and other textile

Long cycle consumer clothing must withstand at
least 50 washing cycles

end products after domestic washing and drying


ISO 105-C06:2010 - Textiles - Tests for colour
fastness - Part C06: Colour fastness to domestic
and commercial laundering

Recycled content

Starting at 5 % per item in 2027, to be raised by 2 %



annually

Pre-consumer and post-consumer recycled
content



Closed loop (textile-to-textile) should become
standard

Possibility for recycling

After 5 years the possibility to set requirements for
recycling will be regularly evaluated

7.5

Non-protective workwear - short cycle

Workwear with a short cycle is typically worn during events and on shop floors. As the use phase
of this kind of workwear is short the focus is on recycled content and recyclability. The
recommended performance requirements are the same as short cycle consumer clothing.
Table 7.7 Performance requirements for short cycle non-protective workwear
Short cycle non-protective workwear

Performance requirements

Technical durability

Minimum requirement

After the number of washing cycles, the textile product



should still comply with:


withstand at least 20 washing cycles

ISO 15487 (2018) - Textiles - Method for

Progressive requirement

assessing appearance of apparel and other textile



end products after domestic washing and drying


The short cycle non-protective workwear must

The short cycle non-protective workwear must
withstand at least 30 washing cycles

ISO 105-C06:2010 - Textiles - Tests for colour
fastness - Part C06: Colour fastness to domestic
and commercial laundering

Recycled content

Starting at 5 % per item in 2027, to be raised by 3 %



annually

Only post-consumer recycled content from
textiles



Closed loop (textile-to-textile) should be the
standard

Possibility for recycling



Promote the use of mono materials



Aesthetic additions to textiles that hamper or are



No multi-layer materials

not recyclable is prohibited



No metal rivets



No paillettes



No metal/glitter yarn



No PVC/PU printing

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7.6

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Non-protective workwear - long cycle

The environmental impact of workwear with a long lifecycle, such as uniforms, may be further
reduced by increasing the technical lifespan. Therefore, the performance requirements focus on
the longevity. The application of (preferably pre-consumer) recycled textile material in new
products is mandatory to reduce the environmental impact of the textile chain, starting at 5 % and
growing year-on-year with the expansion of the recycling industry.
Table 7.8 Performance requirements for long cycle non-protective workwear
Long cycle non-protective workwear

Performance requirements

Technical durability

Minimum requirement

After the number of washing cycles, the textile product



should still comply with:


withstand at least 40 washing cycles

ISO 15487 (2018) - Textiles - Method for

Progressive requirement

assessing appearance of apparel and other textile



end products after domestic washing and drying


The non-protective long cycle workwear must

The non-protective long-cycle workwear must
withstand 50 washing cycles

ISO 105-C06:2010 - Textiles - Tests for colour
fastness - Part C06: Colour fastness to domestic
and commercial laundering

Recycled content

Starting at 5 % per item in 2027, to be raised by 2 %



annually

Pre-consumer and post-consumer recycled
content



Closed loop (textile-to-textile) should be the
standard

Possibility for recycling

After 5 years the possibility to set requirements for
recycling will be regularly evaluated

7.7

Suggested information requirements

Although this project focusses on performance requirements, information requirements have also
been discussed with experts and stakeholders. Although this is not a complete advice on
information requirements, this paragraph presents the knowledge gathered on information
requirements during this project.
Within the ESPR, the EU has identified digital product passports as a key tool to enhance
transparency and traceability of products and product components. We advise to also develop
product passports for textiles. The table below gives an overview of the information that should be
incorporated within this product passport. It would be valuable if this passport is easily accessible
and can be understood by the consumer of the textiles. This would give sustainability-minded
consumers the opportunity to make informed decisions. Besides, making a product passport,
forces producers to collect the proper information and by being informed about the impacts
enables them to lower the environmental impact.

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Table 7.9: Information that should be included in e.g., a product passport for textiles
Theme

Suggested information requirements

Resource efficiency

Make it mandatory to disclose the resource efficiency of the product in a product
passport. At a minimum report the following:


The amount of energy used to produce the product, specifying the
percentage of renewable and non-renewable sources



The amount of resources required to produce the product, which can be
determined through a mass balance

Repairability

Information about the correct replacement components must be provided and
accessible for both the user/consumer and the tailor/repair professional

Environmental impacts

It should be mandatory to disclose the environmental impacts of the product's
production. This should be done according to the PEF textile standard that is
currently scheduled to be released in 2024

Microplastics

Make it mandatory to disclose the potential for the product to release
microplastics. Differentiate between products that release a lot of microplastics
and those that release less microplastics. E.g., differentiate between a synthetic
shirt and cotton jeans that has only synthetic stitching yarn.

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Appendix 1

Organizations that have contributed to
this project

We would like to thank the following organizations for their valuable input.
 Ademe Commisariat general du development




Alcon Advies BV
ArtEZ University of the Arts
Cure Technology





Dutch Denim Deal
Ellen McArthur Foundation
EU Commissie





FTN
Groenendijk bedrijfskleding
Havep





Hogeschool en Universiteit Gent
Hogeschool Saxion
Institut fur textieltechnologie Aachen





Kuyichi
Loop-a-life
Modint





PVH
Schijvens
Studio Anneloes





Sympany
TU Delft
VITO





Wieland
Wolkat
Zeeman

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