Dear Executive Vice-President Timmermans, Commissioner Sinkevičius and
Commissioner Breton,
We would like to share our views on the announced EU Strategy for Sustainable Textiles. This
paper serves as a follow-up to the Roundtable on Textiles that took place on the 1
st
of June 2021.
We wish to thank Commissioner Sinkevičius for his participation and the much appreciated
opportunity to have an open discussion on this very relevant and important initiative.
General reflections
The textile sector is a resource-intensive sector with significant climate and environmental
impacts, which is identified as a key value chain in the EU Circular Economy Action Plan and as
one of the priority industrial ecosystems to address the twin green and digital transitions in the
context of the EU industrial strategy.
We therefore very much welcome the announced initiative of the Commission for an EU
Strategy for Sustainable Textiles.
We would like to emphasise the need for an ambitious and comprehensive EU Strategy, that
focuses on the entire textiles value chain. To achieve the ambitions of the Green Deal and a
future competitive European textile industry, the transition towards a safe, sustainable, just,
circular and climate-neutral economy is crucial.
We stress the urgency, which has become even more apparent during the COVID-19 crisis. We
need to act now to facilitate the textile industry to recover in a more resilient, circular and
sustainable way that increases the competitiveness of the EU on the global market. Besides
our dependency on linear models with long supply chains, which are susceptible to disruption,
the crisis also highlights the emerging awareness among consumers and civil society of our
wasteful patterns and aspirations to different lifestyles and ways of doing business.
With the upcoming requirement for separate collection of textile waste in the EU, combined
with recent achievements in sorting and recycling technology, there is a clear possibility for the
EU to become a competitive leader in secondary textile materials.
We therefore would strongly welcome the introduction of clear, incremental and ambitious
targets on collection, reuse and recycling of textiles and the necessary EU-actions to ensure
that these goals are achieved.
In doing this, we urge the Commission to take an integrated approach and focus on both
environmental and social aspects in the textiles sector.
Design, product requirements and hazardous substances
Large amounts of unsustainably produced textiles enter the European market that are unfit for
repair and recycling and that do not meet sufficiently high durability standards. We believe this
situation needs to be addressed urgently, and propose the following actions:
The Strategy should be complementary to other policy initiatives, in particular the announced
Sustainable Products Initiative and Chemicals Strategy for Sustainability. It is crucial to focus
on the entire textiles life cycle and to stimulate the production and use of chemicals, materials
and products that are safe and sustainable from the design stage.
Within the framework of the Sustainable Product initiative and chemicals and products
legislations, we ask for measures that set clear and ambitious product requirements and
sustainability criteria, with equal conditions for EU produced, exported and imported textile
materials and products in a WTO compatible way. This will boost safe and sustainable
manufacturing worldwide.
In this regard, we would also like to stress the importance to address products entering the
market through e-commerce.
We ask to prioritize regulatory actions for minimizing and phasing-out the use of harmful
substances in textiles. These are not only harmful to health and the environment, but also
form an obstacle for recycling. Besides, the level of chemicals safety should not be lower for
recycled based articles compared to the other products on the market. Giving special attention
to PFAS, polybrominated flame retardants and other POPs. Furthermore we stress the
importance to minimize emissions of microplastics and the use of textiles that cannot be
recycled. Regulatory actions in this field should inscribe into (or in coherence with) the REACH
and CLP regulatory frame.