Miljø- og Fødevareudvalget 2021-22
B 12
Offentligt
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The Danish Government's comments on the Roadmap for an EU
strategy for textiles
The Danish Government appreciates the opportunity to comment on the
Commission’s roadmap for an EU strategy for textiles.
The Danish Government strongly supports the Commission’s decision to launch a
common European strategy for textiles, as well as achieving a green transition. A
more sustainable textile industry requires a common and coordinated effort.
The Danish Government advocates for an ambitious textile strategy that
contributes positively to environmental, climate and health outcomes, whilst
considering the current covid-19 crisis. The Danish Government supports the
outlined scope of the textile strategy, as presented in the roadmap. Thus, we would
encourage the Commission to consider additional content in the final strategy
within five prioritised areas, which we consider to be in line with the roadmap:
1. Increased focus on prolonging product lifetime via design and ecolabels
2. Minimise harmful chemicals and plant protection products
3. Less waste – more and higher quality recycling. Establishing a market for
recycling and secondary raw materials
4. Use of business models and public procurement to promote the transition
to a circular economy
5. Combating micro plastics, biodiversity loss and climate change
1.
Increased focus on prolonging product lifetime via design and
ecolabels
Based on the knowledge that the design phase of products is a deciding factor for
products' environmental impact and durability, Denmark calls for a coherent
product policy that supports circular design of products with increased focus on
resource efficiency and prolonged product lifetime. This requires an increased
focus on quality, durability, reparability, re-usability, recyclability and substitution
of chemicals of concern in regards to design practices.
With an increased focus on more sustainable design, avoiding the
overconsumption of goods is central, and should therefore be included in the EU
strategy for textiles. Furthermore, the strategy should discourage overproduction,
as this causes an unnecessary use of resources. An opportunity to achieve this is
focusing on innovation that reduces by-products and waste in production and
increase the opportunity for production-on-demand.
To inspire to more sustainable design, encouragement for more traceability
throughout the value chain should be included in the textile strategy. This would
also be a first step to minimise green washing.
More sustainable product design practices could be achieved e.g. by innovations
and digitalisation. Both factors are important in regards to accelerating the green
transition and should therefore be a strong focus area of the coming strategy.
Miljøministeriet • Slotsholmsgade 12 • 1216 København K
Tlf. 38 14 21 42 • Fax 33 14 50 42 • CVR 12854358 • EAN 5798000862005 • [email protected] • www.mim.dk
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Moreover, Denmark supports the widening of the eco-design directive to the
widest range of products possible, including textiles as part of the Sustainable
Products Initiative, to set minimum requirements and thereby removing the worst
performing products from the market.
Denmark finds that in order to ensure transparency and coherency - a common
underlying methodology is required for the various instruments assessed in the
Impact Assessment Study for the Sustainable Product Initiative (SPI), as well as
the Sustainable Product Policy Framework (SPPF), including the three legislative
initiatives, as a whole. The Product Environmental Footprint (PEF) developed by
the Commission is an important instrument that should serve this purpose.
Furthermore, it is essential that the common underlying method is based on a
common knowledge base, with updated and validated data of high quality.The EU
Ecolabel and national Type I ecolabels has proven useful for companies promoting
their products and substantiating green claims. The ecolabels include
environmental and quality criteria, as well as “how to use” information (wearing
and washing).
2. Minimise chemicals and plant protection products
The Danish Government supports the aim to address challenges regarding the
widespread and diverse use and presence of substances of concern in textiles.
Thus, the strong connection to the Chemicals Strategy for Sustainability and the
Circular Economy Action Plan is essential. The Danish Government supports the
aim to propose actions to promote more sustainable production processes
(including for raw materials used for textile production) and tackling the presence
of chemicals of concern throughout the entire life cycle of textiles and in recycled
raw materials for textile production. In addition, the Danish Government supports
the use of green diplomacy from the EU to globally phase out the use of the most
harmful substances in textiles and use of pesticide active substances not
authorized in the EU. The diplomatic work should also focus on enhancing the
flow of information on most harmful chemicals throughout the supply chains.
It is worth highlighting the importance of including the effects that chemicals and
plant protection products in the production, distribution, use and disposal of
textiles might have on health, including occupational health, biodiversity and the
environment, including waterways, groundwater and water quality. This would
contribute to underlining the need to reduce negative effects on human health and
the environment stemming from the use of chemicals of concern throughout the
entire lifecycle of textiles.
The importance of product safety for consumers should be emphasised. This
includes avoiding substances of concern in products, as well as ensuring that
consumers have easy access to information on the chemical content throughout
the product lifecycle.
3.
Less waste – more and higher quality recycling. Establishing a
market for recycling and secondary raw materials
The Danish Government supports the focus on extended producer responsibility
schemes in promoting a more sustainable textile and treatment of textile waste in
accordance with the waste hierarchy. The requirement in Directive (EU) 2018/851
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for separate collection of textile waste from 1
st
of January 2025 in EU member
states, will already be implemented in Denmark by January 2022, as part of the
Government's strategy for a green waste sector and Circular Economy from June
2020. This will create a push for new business models and technology
development in recycling. Furthermore, this will contribute to the transition to a
circular economy and EU's goal of a climate neutrality.
The Danish Government supports the proposal to make the textile ecosystem fit
for the circular economy for instance by improving textile waste collection and
recycling in the member states. The Danish Government encourages the
Commission to focus on less textile waste throughout the whole value chain, reuse,
repair, refurbishment and recycling possibilities, in regards to design, business
models and especially technological development.
The Danish Government supports using targets to improve reuse and recycling
efforts, as well as promoting green public procurement. The planned engagement
of a broad range of stakeholders in forming the objectives is of great importance in
order to develop and implement the solutions successfully.
The Danish Government stresses the importance of developing technological
solutions for textile recycling. This can increase the options for textile recycling
and be a way to address the expected increase of textile waste following the entry
into force of the requirement of collecting textile waste in 2025. Solutions for
higher traceability (including of chemicals of concern) in regards to textile waste,
especially exports hereof, should be part of the new textile strategy.
4.
Use of business models and public procurement promote circular
economy
The Danish Government stresses the importance of exploiting the potential in
circular business models in the aim of reaching a sustainable textile industry.
Circular business models can help companies to extract significantly more value
from textile products by prolonging the lifetime of products. The higher value
extraction can imply a good business case besides the environmental and climate
related benefits of the lower need for raw materials. Therefore, the Danish
Government supports the proposal of actions to underpin business models that
e.g. sell textile products as services, buy back and resale of used products, second
hand stores, renting of products, and stores for repair and refurbishment of
textiles. In this regard, it is important to note that data and digitalisation can
enable the circular business models - also in the textile industry. Data on the
condition and damage of textile products after use or intelligent price setting on
second hand- or rental of textile products are examples of how data and
digitalisation can enable circular business.
Moreover, it is important to gain further insights and improve the available data
on the consumer’s use of textiles and clothes during its lifetime to promote
sustainable usage and contribute to the development of sustainable business
models.
The Danish government supports proposing minimum mandatory Green Public
Procurement (GPP) criteria and targets, including for textiles. The Commission
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should ensure a better and more systematic monitoring of member states’ use of
GPP criteria, common definitions and the different tools. The Danish government
suggests that PEF or ecolabel criteria should be used to provide the basic
environmental profile for a product or service.
5. Combating micro plastics, biodiversity loss and climate change
The Danish Government supports the Commission's focus on tackling the climate
crisis and limiting the release of micro plastics. Additionally, the global
biodiversity and habitats of animals and insects should be considered as a central
topic in relation to the production of textiles. Agriculture, resources extraction,
micro plastics, climate change and the release of chemicals play a central part in
shrinking local habitats, but also globally. We encourage the Commission to
present concrete actions to address these issues.
The Danish Government welcomes the cost-benefit analysis of policy measures
reducing unintentional release of micro plastics but would suggest an extension of
the analysis to include an ecological profile (e.g. by using PEF) and taking into
account the user pattern. Natural fibres (e.g. cotton, wool etc.) and synthetic fibres
(e.g. PET, polyamide etc.) typically have different applications not necessarily
interchangeable one-to-one, and the Danish Government would thus urge the
Commission to take into consideration the specific challenges related to release of
micro plastic from synthetic fibres.
The Danish Government suggests that the strategy highlight the potential
contribution towards achieving climate neutrality in the EU by 2050.
Please do not hesitate to contact the Danish Ministry of Environment for further
explanation of the above points.
We look forward to participating actively in the implementation of the
Commission’s work towards an EU textile strategy.
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