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For too long, fashion has lagged behind on lobbying, leaving policymakers stabbing in the dark and industry players running to keep up with changes they had no hand in. Today, the European Fashion Alliance (EFA) — a group of 29 European fashion councils and other entities formed in 2022 to address this lobby gap — will present its first position paper, addressing the upcoming Ecodesign for Sustainable Products Regulation (ESPR) by the European Union. It marks an important turning point for European fashion, which finally has a united voice in policy debates.
“Some of my colleagues do not realise how important you are, in terms of jobs, creativity and the image of our continent,” EU commissioner Thierry Breton told EFA members at a roundtable in Brussels last week, ahead of the position paper’s release. “But, the creativity and entrepreneurial spirit of European fashion are vital to the long-term competitivity of the industry, as well as the resilience and visibility of the single market.”
The EU has developed a strategy for sustainable and circular textiles. Experts say it is a strong starting point, but social impact should be core to sustainability legislation.
The position paper details the EFA’s support for, and concerns about, the current ESPR draft. Its main aim is to highlight the potential unintended consequences of the horizontal regulation, which would apply to all industries, including textiles, but wasn’t designed specifically for textiles. “We must warn against the adoption of requirements that would affect the industry’s craftsmanship, artistic tradition, and competitiveness, as well as the whole European fashion manufacturing ecosystem, which is largely dependent on designers and high-end brands,” the EFA writes. “We call for the implementation of feasible, yet ambitious enough ecodesign requirements established in cooperation with representatives of the industry, all along the value chain.”
EFA board members and European fashion council CEOs in attendance at the roundtable included Caroline Rush (British Fashion Council), Carlo Capasa (Camera Nazionale della Moda Italiana), Cecilie Thorsmark (Copenhagen Fashion Week), Pascal Morand (Fédération de la Haute Couture et de la Mode) and Zuzana Bobikova (Slovak Fashion Council). Fashion Council Germany’s CEO Scott Lipinski, who is serving as chairman of the EFA, and Flanders DC’s Elke Timmerman, another board member, opened the event.
The EU laid out its strategy for sustainable and circular textiles — part of the European Green Deal — in March 2022, with the overarching ambition that, by 2030, all textile products entering the EU market will be durable and recyclable, free of hazardous substances, and produced with respect for both people and the planet. The policies hoping to make this a reality range from a crackdown on plastic packaging to tighter rules around greenwashing. Several key elements — including the product environmental footprint methodology being developed to justify green claims, and the ecodesign principles the EFA is lobbying on — are still being hotly debated.
For many pieces of policy, EFA’s involvement is too little, too late. But, there is still potential to impact others and secure funding for innovation. “We are at a turning point. For the first time in the history of the European budget, the Parliament has contributed €2.3 billion just to research for the creative industries, with €1 billion for the European textile industry,” Dr Christian Ehler, an MEP (Member of the European Parliament), explained. This means the EU has funds available to innovate in fashion, but — in an unusual turn of events — no advice on how to spend it. Ehler notes the importance of the creative industries in Europe in terms of both the economy and for employment, particularly for younger generations, "but we did not have anyone to speak to before EFA", he says. In other industries, like steel and chemicals, we have had advocacy groups for more than 40 years. We need your expertise; this transformation won’t work without you.”
Ecodesign principles
In theory, the products most compliant with ESPR will be made from minimal materials — chosen from a limited list of materials, dyes and finishings — with streamlined fabrications which are easy to disassemble and recycle. “When we talk about creativity, it’s not just the design, but innovation, from new fabrics to more resilient supply chains,” said Thorsmark. “We need to protect creativity and view it as an important force for change.”
One of the key sparring points between sustainability and creativity is recycled content and recyclability. In its position paper, EFA calls out the incorporation of recycled content as a potential limitation of ESPR, explaining that there is a lack of availability and quality in recycled fibres.
“Mechanical recycling used for fibre-to-fibre recycling can deteriorate the fibre and its length. In the case of synthetic fibres, which represent the large majority of recycled fibres, it increases the potential for microplastic release. In the case of natural fibres, it also shortens the fibre length and thus, reduces the quality output, necessitating mixing them with virgin ones to reach sufficient robustness,” the paper reads. EFA is advocating for the use of “low-impact materials” instead, although it doesn’t specify what this means.
Likewise, on the recyclability side, EFA says capacity and technology are limited. “There are barriers such as a lack of efficient sorting solutions and disassembling processes, and the complexity of supply chains including multiple stakeholders,” the paper says, arguing that setting requirements beyond technical capacity could pose a risk to brands who are simply unable to comply.
Unsold products
Also nestled within the ESPR draft is a sweeping ban on destroying unsold products. EFA says this is too broad, and the ban on destroying unsold products should be limited to those “fit for consumption and sale”. It would like to see counterfeit products, prototypes and samples excluded from the ban, it says, for “legal and compliance reasons, as well as the risks they may pose to health and safety”. For other excess stock, EFA says it supports remanufacturing and upcycling as alternatives to destruction.
One potential route for the EU to take is banning even the recycling of overstock, as a hardline way to cut initial production quantities, rather than allowing companies to continue overproducing and then simply recycling excess. EFA advises caution here. “Many brands in the circular economy rely on utilising deadstock, and upcycling is an important part of their process,” says FHCM’s Morand. “Of course, overstock is a problem, but tackling it in this way will not only harm the avalanche of waste.”
The scale of fashion’s overproduction problem is still largely unknown — according to the 2022 Fashion Revolution Transparency Index, 85 per cent of brands don’t disclose their annual production volumes. What we do know is that secondhand markets in the Global South are drowning in fashion waste: Kantamanto market in Ghana receives 15 million items of discarded clothing each week from the Global North.
EFA says the amount of unsold and discarded products each brand produces is “highly sensitive data” that could pose a business and competitive risk. It has requested that this data be provided directly to the EU Commission or another designated national authority, rather than being disclosed publicly, as the current ESPR draft mandates.
Digital product passports
In his opening address, EU commissioner Breton called out intellectual property rights and protection against counterfeits as key priorities for the collaboration between EFA and the EU. “This is something that could kill your industry if we are not careful, and it’s part of why we want to implement digital product passports,” he explained. “We also have an economy of non-material goods — of brands and trademarks — and fashion is one of its biggest drivers. This is what we have created and we need to protect it.”
EFA board members are not so convinced by the idea of digital product passports. “We support the provision of relevant, accurate and reliable information to the consumers and the digitalisation of such information,” its position paper says. “However, we strongly warn against any measure that would imply disproportionate administrative and technological burdens on businesses and especially on SMEs, and would disregard, in particular, the challenges related to the textiles’ long and multidimensional supply chain.”
EFA is calling for a phased implementation of digital product passports, based on the resources and data companies have available already. It also wants the EU to reassess its threshold for these phases. “£20 million in sales and 10 employees might seem like a good threshold, but that’s actually going to be quite restrictive because brands at that size still might not be profitable,” said BFC’s Rush.
“We can start with the larger companies, but it is only a matter of time until smaller companies will need to comply,” responded MEP Ehler.
The EFA also shared its concerns over what the digital product passports will include. Camera della Moda’s Capasa is keen for digital product passports to include a stamp for products created with artificial intelligence (AI) rather than human hands. FHCM’s Morand has concerns about whether digital product passports will require brands to share sensitive information, and how they will guarantee authenticity.
“There will be no trade secrets, simply the information consumers need to make informed choices and trust that brands are not greenwashing,” Ehler reassured them.
The EU has yet to issue a written response to EFA’s position paper, but will take it into account as the ESPR negotiation process continues. “This needs to be co-designed, we need working groups and legal entities representing the industry,” Ehler continued. “There is a lot of money and willingness to change, but we need calls from the industry on how to use it.”
Correction: Updates Scott Lipinski s titles to CEO of Fashion Council Germany and chairman of the EFA. (15/06/2023)
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