EPR Insufficient in Itself to Address Impacts, Additional Policies Needed to Complement EPR: OECD Study

An OECD study on ‘Extended producer responsibility in the garments sector’ contends that EPR is a promising approach for addressing environmental impacts of garments. Its focus on producers and post-consumer products lends it well to addressing impacts at the end-of life and production stages. However, complementary policies can amplify its effect.

Long Story, Cut Short
  • Regulation or complementary economic instruments can help encourage the implementation of the waste hierarchy (re-use, recycling, and then other recovery) by waste handlers.
  • Economic incentives can encourage demand for recycled content and stimulate investments in recycling infrastructure and technology.
  • Regulation is also needed to reduce the use of harmful chemicals during production and their treatment at end-of-life.
The OECD paper is relevant to policymakers and the public because it provides a review of the environmental impacts of garments, the landscape of current policy, and the analysis of the impacts of existing schemes.
Policy Matters The OECD paper is relevant to policymakers and the public because it provides a review of the environmental impacts of garments, the landscape of current policy, and the analysis of the impacts of existing schemes. Jahanzeb Ahsan / Unsplash

An OECD Environment Working Paper contends that although EPR is a promising approach for addressing environmental impacts of garments, an EPR approach by itself will be insufficient to address all the impacts and that additional policies are needed to complement EPR.

  • EPR is a promising approach and its focus on producers and post-consumer products lends it well to addressing impacts at the end-of life and production stages. However, complementary policies can amplify its effect. Complementary policies will also be helpful in the use stage to change household behaviour and extend the use phase of garments.

The study suggests:

  • Regulation or complementary economic instruments can help encourage the implementation of the waste hierarchy (re-use, recycling, and then other recovery) by waste handlers.
  • Governments can create standards by making definitions for garment waste, recycled content, and suitability for re-use. Harmonisation of these efforts where possible will ease compliance.
  • Regulation is also needed to reduce the use of harmful chemicals during production and their treatment at end-of-life.
  • Economic incentives can encourage demand for recycled content and stimulate investments in recycling infrastructure and technology. Complementary policies (e.g., awareness and behavioural interventions) can help households identify best practices to extend the use phase.

THE PAPER: ‘Extended producer responsibility in the garments sector’, talks about how in addition to improving collection and sorting, there is the possibility that EPR can help to reduce environmental impacts generated by the production, use, and disposal of garments. This is primarily by changing the economic incentives for producers, consumers, and waste managers.

  • The aim of this report is to evaluate the potential for the EPR approach to help achieve public ambitions for the adoption of circular economy principles in the garments product sector. The paper is relevant to policymakers and the public because it provides a review of the environmental impacts of garments, the landscape of current policy, and the analysis of the impacts of existing schemes.

However, there are challenges and these include:

  • Reuse and repair: Lengthening the use phase with support for repair and social enterprises: The French scheme made several changes in 2023. The scheme is starting to support social enterprises to boost sorting and reuse, as well as providing repair credits (in the form rebates on repair costs) to households through certified repair shops.
  • Recovery of exported used garments: There is a large global market for trade in used garments. This trade helps to extend the use phase, but there is concern that some importing countries are overwhelmed with management of poor-quality material that is not re-useable. Banning trade of used garments is unlikely to solve issues of waste generation and could negatively impact the people reliant on this trade for their livelihoods. Investment in improvements in sorting and recycling both domestically and abroad are needed. For example, the French EPR scheme provides funding for authorised sorters that are located outside France. Roughly 16% of the total material collected and processed by the scheme are sorted by facilities outside France (within the EU).
  • Recycling: After exhausting opportunities to reuse and repair garments, recycling is a next best way to recover some material value. There are significant technical and economic barriers to recycling. New recycling technology is available but will require investment and economies of scale to become competitive with primary material. Manufacturers generate pre-consumer waste in the production phase. This material is a potentially high-value resource for recyclers. This material could be a ‘low-hanging fruit’ for scaling up recycling of textiles. EPR could potentially help to stimulate improvements in the handling of this material by including pre-consumer waste recovery targets for brands or offering a fee bonus for using recycled content.
  • Design for the environment: EPR is one approach for setting incentives for producers to change design through modulating EPR fees. Criteria could for example include chemical content or indicators of quality such as abrasion or strength. The French EPR scheme uses recycled content as a fee modulation criterion and may include recyclability criteria in the future.

THE CONTEXT: An EPR approach by itself is insufficient to address all environmental impacts of garments. The report also briefly reviews opportunities and examples for other policy approaches to complement EPR for garments within a broader policy mix.

  • Several researchers at University of London created a policy map to identify interventions along the product lifecycle to achieve a sustainable fashion industry.
  • The researchers identified EPR as an established means for encouraging recycling. They identified other established complementary policies, including regulation of harmful chemicals, green public procurement, eco-labelling, right to repair and economic instruments to encourage re-use and repair.
  • Several complementary policies are available to amplify EPR’s effect at the post-consumer stage of the lifecycle.

Opportunities include: 

  • Regulation could help to require households to separate garments waste. For example, Massachusetts (United States) has banned disposal of textiles by households into mixed waste collection.
    • Regulation or complementary economic instruments can encourage the waste hierarchy (reuse, recycling, and other recovery) by waste handlers. One option is a ban on disposal or incineration of separately collected material. A tax could also raise the cost of this treatment for collected garments.
    • Investments in sorting and recycling. Governments can help to galvanise and encourage the direction of private investment in emerging technologies. Complementary policies can help change household behaviour in the use phase. Awareness and behavioural interventions help households identify best practices to extend the use phase. For example, Scotland commissioned surveys to identify common reasons for absolute obsoletion and is tailoring awareness efforts to the results. Economic incentives can also impact the relative price of garments. For example, some OECD countries do not charge value added taxes (VAT) on re-use products.
  • Regulation and economic incentives can also play a role in the production stage.
  • Governments can create standards by making definitions for garment waste, recycled content, and suitability for re-use. Harmonisation of these efforts where possible will ease compliance.
  • Regulation to improve the chemical composition of products. For example, in the EU the Registration, Evaluation, Authorisation and Restriction of Chemicals regulation limits the use of formaldehyde. This is commonly used elsewhere for its capacity to make textiles ‘noniron.’ This could also be used to increase the recyclability of products.
  • Regulation can require that producers disclose information on the composition of their products and production conditions.
  • Economic incentives to encourage demand for recycled content. For example, Italy is considering the impact that a reduced VAT could have on encouraging the integration of recycled content in products.

THE REPORT: This report is an output of the OECD Environment Policy Committee (EPOC) and its Working Party on Resource Productivity and Waste (WPRPW).

  • It has been authored by Andrew Brown, with support in conceptualisation, analysis, methodology and supervision by Peter Börkey.
  • Editorial assistance: Frithjof Laubinger. Vilma Gertane, and Illias Mousse.
  • The work on this report was conducted under the overall supervision of Shardul Agrawala, Head of the Environment and Economy Integration Division of the OECD’s Environment Directorate.
  • Interviews conducted: Agence de la transition écologique (ADEME), Re_Fashion, the Japanese Textile Federation (JTF), OR Foundation, Arisa, Centre for responsible business, and Reverse Resources.
Extended producer responsibility in the garments sector
Extended producer responsibility in the garments sector
  • Authored by:

    Andrew Brown, Peter Börkey

  • Publisher: Organisation for Economic Co-operation and Development
  • 43
 
 
  • Dated posted: 19 December 2024
  • Last modified: 19 December 2024