Miljø- og Fødevareudvalget 2021-22
B 12
Offentligt
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.
B 12 - 2021-22 - Endeligt svar på spørgsmål 1: Spm., om et udvidet producentansvar omtales i brev til Kommissionen, til miljøministeren
We would like to stress the need to foster innovation and utilize available funds to stimulate
research and investments for non-toxic alternatives, high-level recycling technology, resulting
in non-toxic, high-quality secondary raw materials, sustainable bio-based fibres, as well as
utilizing fibres from waste- and side-streams. Thereby ensuring an overall positive
environmental and climate performance.
Closing the loop
The very linear model of the textile sector and the very fast turnover of products (an over-
consumption phenomenon also known as
fast fashion)
lead to significant and unsustainable
impacts. Therefore, the transition to a more circular model is indispensable. Fast Fashion is a
major issue; the average EU citizen buys 60 per cent more clothing and keeps them for about half
as long as compared to 15 years ago. Measures need to be put in place urgently to tackle
overconsumption and increase reuse and recycling as increasing (over)production and
consumption results in huge amounts of waste and aggravates the overall environmental impact of
textiles.
We ask for a study on the dynamics of fast fashion and how to address this phenomenon,
including influencing consumer behaviour as well as encouraging new circular business models
to counteract the negative effects of fast fashion.
We call for the waste hierarchy to serve as a basis in developing the strategy.
We ask for measures to prolong the lifespan of textiles to be key part in the strategy.
We would strongly welcome clear EU targets on collection, reuse and textile-to-textile
recycling.
We furthermore ask to explore for which materials textile-to-textile recycled content
requirements can be established on the short term.
We would strongly support measures to avoid disposal of unsold goods, for instance via a ban,
as it is unacceptable that products skip the use-phase entirely. While destruction may be
warranted in very specific cases, we ask for measures that tackle the root of the problem. It
could be helpful to oblige companies to provide data on the remains of their products and to
report on measures they undertake to prevent the destruction of goods.
We support the focus on harmonized EU-wide EPR principles, in line with the polluter pays
principle.
We stress the important role of green public procurement as a means to help create a new
market for recycled textiles and ask for comprehensive EU criteria and to consider common
targets.
Measures should not impede reuse initiatives, unless they are required to adhere to
restrictions on the further use of specified textiles, restrictions which are decided following the
REACH regulation.
Transparency and consumer information
Transparency needs to be improved and greenwashing must be avoided. Consumers have a right
to know the environmental and social impact of their purchases, as this enables them to make
informed choices.
We support the development of a digital product passport for textiles in order to enable
tracking and tracing and ensure access to information about products and their components
concerning; origin and composition including declaration of hazardous chemicals and
substances of concern, their durability if appropriate, reuse, repair and dismantling possibilities
and end-of-life handling, as well as their environmental performance.
We stress the importance of awareness raising measures among consumers, including the
production, use and disposal phase
We call for a mandatory label to inform consumers in a direct, simple and comprehensive
manner about both the environmental and social impacts of a garment at the moment of
purchase.
We would strongly welcome horizontal legislation on due diligence and sectoral criteria and
guidance for textile products.
We suggest the Strategy to be aligned with the Green Claims initiative.
B 12 - 2021-22 - Endeligt svar på spørgsmål 1: Spm., om et udvidet producentansvar omtales i brev til Kommissionen, til miljøministeren
Yours sincerely,
Austria
Belgium
Denmark
Germany
Finland
France
Luxembourg
Netherlands
Norway
Spain
Sweden
Minister Ms. Leonore Gewessler
Minister Ms. Zakia Khattabi
Minister Ms. Lea Wermelin
Minister Ms. Svenja Schulze
Minister Ms. Krista Mikkonen
Minister Ms. Barbara Pompili
Minister Ms. Carole Dieschbourg
State Secretary Mr. Steven van Weyenberg
Minister Mr.
Sveinung Rotevatn
State Secretary Mr. Hugo Moran
Minister Mr. Per Bolund