Laudable, but with Some Shortcomings

A policy always starts in analysis. It rightly assesses that the dominance of fast fashion and disposable textiles is a recent one: dramatic decline in prices since 1996, increase in volumes. One wonders if it is connected to liberalisation of textile trade post-GATT/MFA. The assessment that there is still a strong EU textiles sector that is resilient and agile (e.g., with masks to the COVID-19 crisis), leadership in innovation, design and marketing is a good plus. However, it does not acknowledge that the industry has been weakened by fifty years of restructuring.

A closer look would show that the reduction of the fibre-making and spinning capacities seriously limit the potential to increase EU industrial autonomy. This is of relevance since the EC assesses that the Russian war on Ukraine demonstrates the vulnerability of global supply chains. For a long time, the EU still supplied its domestic consumption with 30% domestic production. It is now below 15% and that seems to be too vulnerable. The European commission (EC) correctly links the need or reshoring to the need to strengthen the EU skills base.

It is laudable that the EC integrates environmental and social concerns in its analysis. The analysis also stresses that the transition to a sustainable and circular value chain is too slow, the footprint remains high. But it does not reflect fully on the reason why that transition is slow. Could it be that the multiplicity of voluntary initiatives and the erosion of post-WWII industry structures (industry associations and other collective bodies) are too weak to assure proper advocacy, guidance and support?

A fundamental weakness in the strategy is the limited connection to the CO2 challenge, and the imperative to become fossil-free or fully biobased by 2050. More recycling helps but probably not enough. There is no perpetuum mobile in materials, all materials degrade, and current materials are hardly designed for longevity for recycling. That is not to say that limiting industrial, distribution and consumption waste is not important. Extending lifetime of products, promoting reuse and enabling recycling is an imperative, and is rightfully an ambitious part of the strategy. But it will only solve 20–30% of the problem, even if very substantial investments are mobilised.

The strategy has only a limited analysis on where the bottlenecks for recycling are (but the underlying excellent studies of the JRC  and of VITO for the European Commission does ). In the long run, a fully biobased textile industry is needed. Ans since the time from invention to industrialisation (from TRL 1 to 9) is 20–30 years, a coherent road map and programme is needed now. The increase of biobased resources would also improve the strategic autonomy of the EU.

There is a strong focus on recycling, on eco-design and on reuse. That is laudable, since it is coherent with the waste directive and initiatives of EPR (extended producer responsibility) in some Member States. That puts changes in motion, and increases awareness from consumers to industry. And more important, the different tenets of policies enable the 25% of consumers that wish to buy in a sustainable fashion to become able to make informed choices. That is a substantial improvement over the current choices, were sustainable choices represent far less than 5% of sales.

Indeed, the measures proposed close the door to quick-fixes and misleading claims such as plastic-to-textiles recycling. Green claims can only be made if verified by a third party. The same is for the improvement of labelling and introduction of a digital passport. This is essential to enable the transition, but it should fit with the needs of recycling (e.g., differentiate between PA6 and 66 content) and remain accessible to SMEs. It is also essential that the EU Commission strengthens its role as warrant of a well-functioning internal market e.g., by setting up a framework for EPR schemes, by using REACH as a framework. The proposal to strengthen due-diligence obligations for companies larger than €40 million turnover is laudable, even if many say that that threshold could be lower.

In line with my analysis: there is yet a total lack of proposals related to biobased fibres, be it of European origin (cotton, flax, hemp) or non-EU origin. The possible use of agri-food-residues to textiles (e.g., in man-made cellulosic fibres) or biopolymers is missing. WUR has identified in a study that agri-food waste may be able to provide fully the textiles industry and reduce the CO2 footprint of agriculture and improve farmers’ incomes. Also absent is the connection to the EU common agricultural policy (CAP). Fibres such as flax and hemp can be boosted, providing incomes to farmers, supporting the protein transition and enabling CO2 and nitrogen sequestration.

Also absent is a more international approach in analysis, policy and governance. A transition to materials with better durability, recyclability and a shift to fossil free and thus biobased materials will probably require a multilateral fibre agreement, in which countries like China, India and the US play a role. In attaining a better cotton value chain, a stronger connection with the development policies of the EU and its member states would be required. We cannot become fully biobased without cotton, but it must be better cotton, in terms of farmer incomes, ecological footprint but also fibre quality to enable recycling.

While the proposal addresses greenwashing, it does not recognise that some transitions from grey to green are gradual and a process of trial and error. It is unclear how a system will not penalise manufacturers and retailers taking a gradual and step by stem  approach to sustainability. The mention of EPR schemes is laudable, the impact of CO2 levies is unclear, but the reference to pricing instruments to create a level playing field for recycling and biobased alternatives could be stronger and the commitment to EPR schemes as a useful instrument could also be more convincing (including a monitoring of its impact).

A vision and strategy are only realistic if it comes with adequate resources, governance and processes. While I am very critical on  (conscious or unconscious absence of biobased fibres), the proposal of a process of co-creation of “transition pathways for the textiles ecosystem” enables the development of a roadmap (and possibly governance) for biobased textiles. The next step is thus possible. The proposal to include textiles innovation in a Circular Bio-Based Europe Joint undertaking is an excellent idea, that may address fragmentation and coherence in research and innovation.

The inclusion of social (and public) enterprises in the value chain is a positive element, since they have often been marginal in the value chain. Bringing them in (if they are supported by EPR and other schemes) enriches the dialogue. The overall financial resources allocated in the strategy is overall modest, too modest to have an impact as the recycling challenge will cost dozens of billions of Euros, and a biobased transition probably hundreds of billions of Euros. The EC commission rightly acknowledges that the recovery funds of several EU member states will allocate funding for investments in recycling and reshoring of industry, there is no credible coordination mechanism proposed (this could come through an I3 or Interreg proposal).

The encouragement to companies to be the champions of the paradigm shift, is not in line with theories and practices of paradigm shifts. It is debatable whether the champions of fast fashion can become the champions of slow fashion. The strengths of the chemical industry and fibre industry that have strategic roadmapping, research programming and industrialisation skills is not integrated in the policy. For biobased materials, the EC could foster cooperation between the textiles industry and the agri-food industry. It looks as if the EU is promoting rather a collection of initiatives and projects, than have an integrated approach.

While the development of a roadmap is laudable, the connection to projects is unclear. In a complex value chain and in an industry dominated by SMEs, even the ambitious objectives of this plan demand an adequate support structure. After 50 years of restructuring, and with funding mainly organised at national or regional level policies do rather lead to fragmentation than to coordination of scattered resources. Finally, there is no monitoring tool mentioned, nor an improvement of statistics (classification of goods). So how can we measure progress and success of policies and how can they be adjusted according to (lack of) impact? I do also apologise for my statistical estimates, since we lack an accepted dataset of facts and trends.