EU Textile Strategy in progress:

shaping the transition towards a green and innovative industry


The EU Strategy for Sustainable Textiles (Textile Strategy), expected for the third quarter of 2021, will strive to fundamentally alter the linear resource flow of the textile, clothing, leather, and footwear (TCLF) industry (see European Commission, here). It has the potential to rebuild, innovate and green the sector in Europe and beyond, and will set the framework for all future negotiations on regulations concerning this multi-trillion-euro industry. In light of the EU Recovery Plan, the sector has the opportunity to gain unprecedented support for its transition to decrease its environmental and social footprints, boost innovation and enhance competitiveness.    

What are the main objectives of the Textile Strategy? 

Under the Green Deal, the European Commission has declared its ambition to tackle the biggest sources of pollution. Textile consumption is the fourth highest pressure category in the EU in terms of primary raw material and water use, as well as the fifth for greenhouse gas emissions. Europeans consume on average 26 kg of textiles per person annually with each item being used for an increasingly shorter period, while collection and recycling rates are still low (see EEB, here).


The sector, which is among the largest globally in terms of employment, has often been accused of poor working conditions and right’s violations, particularly in third countries. The European Commission will, therefore, aim to go beyond environmental aspects, and seek to deliver a comprehensive strategy including workers’ rights, transparency, and accountability. 


Faced with a globally operating industry, policymakers will simultaneously need to build a framework that will strengthen innovation and competitiveness of European companies, promote circular business models and new technologies to reach its ambitious targets for the sector.


What are the key challenges for the TCLF industry?

Following the recent economic crises, the EU Textile Strategy will seek to enable an environmentally and socially sound recovery. Recent economic data shows a drastic contraction in the demand and production of textiles and clothing caused by the Covid-19 pandemic. Compared to the previous year, EU sales of textiles fell by 9.3% in 2020 (see EURATEX, here). Whilst European TCLF companies have proved their adaptability and resilience over the past months, adverse effects on international supply chains threaten to continue to pose challenges.


Earlier this year, the TCLF industry, predominantly composed of SMEs, called for sufficient time and support to generate the necessary investments and implement the transition (see European Commission, here), while other stakeholders have urged the Commission to maintain the high level of ambition with regard to human rights and environmental preservation (see, for example Wardrobe Change, here or Civil Society Organisations, here). 


Despite the complexity of the issues, efforts to rebuild the European economy under the guiding principles of the Green Deal offer the unique opportunity for stakeholders to play an active role in shaping the future operating conditions for the TCLF industry in Europe and beyond.

What are some of the core issues of the Textile Strategy? 

       Due diligence

Within the Textile Strategy, European policymakers will aim to bring forward mandatory requirements for how business are to identify, prevent, manage, and communicate about risks. Legislation on mandatory due diligence will include clear reporting criteria and extend companies’ risk assessments beyond their immediate operations to all suppliers and contractors along their value chain. 


National strategies, such as the United Kingdom’s Modern Slavery Act or the French Duty of Vigilance Act, along with international guidelines already provide direction to this endeavour. The new Directive on sustainable corporate governance, expected this summer, will also cover human rights and environmental due diligence, and seek to ensure real impact across the TCLF value chain.


Harmonised criteria for conducting due diligence which apply to businesses based in the EU, as well as those wishing to access the Single Market, will ensure companies become accountable and transparent players to investor, partners, and consumers, whilst also enabling them to identify and mitigate risks in their supply structures. At the same time, policymakers will need to establish that the burden of compliance is equally distributed - also in third countries - and proportional to company size and means.

       Product policy & Ecodesign

Estimates state that over 80% of product-related environmental impacts are determined during the design phase (see JRC, here). Therefore, next to an overall reduction of resources consumed, ‘design for recycling’ will be a major component of the new Textile Strategy. Within the context of the Sustainable Products Initiative (SPI), expected for the end of the year, the European Commission foresees the revision of the Ecodesign Directive to address sustainability and circularity requirements for a wide range of products – including textiles.


This will go hand in hand with a review of applicable standards, certifications and labelling requirements, including the EU Ecolabel and related methodologies. Targeted primarily at consumers, Europeans should move to a more circular consumption model aided by measures that prolong the useful life of textiles. 


Approximately 10% of the 2400 substances used in textile production are of potential concern for human health, and another 5% pose a threat to the environment (see KEMI, here). In close alignment with the Textile Strategy, the Commission has committed to addressing these hazardous substances in its Chemicals Strategy for Sustainability. Legislators will need to assess and go beyond the current voluntary standards and develop clear measures for the substitution, recycling, and disposal of substances of concern.


Another key innovation piloted in the textile sector will come in the form of digital product passports, which will contain information on a product’s origin, durability, composition, reuse, repair, and dismantling possibilities, as well as end-of life treatment. As additional digital support infrastructures, legislators will seek to establish resource mapping and waste shipment tracking systems still this year (see European Commission, here).


TCLF producers will need to ensure that the requirements set by policymakers are harmonised and can give them a competitive edge to maintain a level playing field internationally. Reliable and systematic product assessments along international value chains as well as monitored compliance with the new rules will be fundamental to guarantee the success of all measures. 

       Circular business models & Extended Producer Responsibility (EPR)

EPR schemes hold the potential to play an important role in financing the transition to a more circular TCLF sector. The European Commission will support research on the issue to enable identification and sharing of best practices, as well as incentivise companies to make their products more durable. Some stakeholders have suggested that subscription to an EPR scheme should be mandatory for all companies wishing to access the Single Market.


At the time of writing, France has the most developed EPR scheme for end-of-life clothing, linen, and footwear (see Refashion, here), which could serve as an important example for other Member States. In the meantime, NGOs keep urging the European Commission to introduce mandatory EPR schemes for all textiles placed on the market, which respect and implement the EU waste hierarchy with a clear transparent governance.

       End-of-life & Recycled content

With 2025 marking the deadline for mandatory separate collection of textile waste across all EU Member States, some stakeholders are already calling for more comprehensive legislation on the collection and sorting of throwaway clothes. Currently, only 13% of the total material input across the industry is recycled after use, with most materials going into lower-value applications (see Ellen MacArthur Foundation, here). New requirements could target the use of recycled content to boost uptake of secondary materials in closed loop fibre to fibre applications, as well as limiting chemicals usage and textile blends, which are challenging to recycle.


Further innovation and infrastructure will be needed as legislators move forward with these requirements, as many Member States are currently not equipped to adequately deal with end-of-life textiles, and secondary raw materials are often considered economically less viable than their virgin counterparts. EU and national funding opportunities, dedicated to research, innovation, and knowledge-sharing in this field could offer interesting incentives for companies developing new solutions for waste management and recycling.


What comes next? 

With the Textile Strategy’s publication expected shortly, the TCLF industry is readying itself for this new framework. Starting with the currently held Public Consultation, stakeholders are looking at an array of upcoming opportunities to play a part in the active shaping of policies spanning the entire value chain and life cycle of TCLF products.


Ensuring the ambition of due diligence legislation and bracing against greenwashing will be a main concern of industry leaders and NGOs alike. The development of EPR schemes will require civil society actors, governments and the TCLF industry to pull in the same direction and connecting European and individual Member States’ ambitions in a meaningful way will be key. Pioneering digital solutions to enable tracing products along a global value chain, as well as improved waste management will present innovative businesses with interesting new applications for their technologies, as well as funding opportunities for further development. One thing is clear, a wide range of different interests will be at stake in the months following the adoption of the EU Textile Strategy – especially with a view to depth and pace of the reforms.


With the Public Consultation closing on August 4th, and the final Textile Strategy expected before the end of September, it is high time for interested stakeholders to formulate their positions and strategies to claim a spot at the negotiating table.

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