There's a Need for Harmonisation of Textile Policies Across EU Member States, Says Policy Hub

Policy Hub has come out with a report which calls for the harmonisation of textile policies across EU member states, specifically looking at how Extended Producer Responsibility (EPR) can be implemented and operationalised.

THE REPORT: The report Further considerations to textiles EPR and complementary measures has been prepared by Eunomia Research and Consulting with Toby Connock, Lucie Long, Daniel Stunell, Eleanor Lewis, Kayleigh Lee-Simion, and Caitlin Harrington-Smith, under the leadership of Chris Sherrington. 

• The members of the project steering group include H&M Group, Bestseller, Inditex, VF Corporation, C&A, and Adidas.
• The Policy Hub is a partnership of the Sustainable Apparel Coalition (SAC), Global Fashion Agenda (GFA), the Federation of European Sporting Goods (FESI) and Textile Exchange.

THE OVERVIEW:

• Policy harmonisation is essential and of significant importance in delivering effective EU policy. It is of particular relevance, given many European nations are already forging ahead with amending legislation (France) or the development and implementation of new textiles EPR schemes (the Netherlands, Sweden and several more).
• Key to reducing these impacts will be enabling circular use and end-of-life solutions through Extended Producer Responsibility (EPR), reducing the vast quantities of disposed, landfilled or incinerated textiles.

BENEFITS: Harmonising EPR schemes between EU member states will be essential to reduce burdens on producers, maximise the benefits of the schemes and allow the single market to function effectively.

Some of the key benefits include: 

1. Creating a consistent definition for the “obligated producer” and providing better guidance so industry actors will better understand their responsibilities. 
2. Clarifying which textiles are to be included in EPR, both at the start of the scheme and in the future, to address the potential for variation. 
3. Suggesting key principles for reporting systems to accurately calculate and allocate fees, striking a balance between compliance and overburdening producers. 
4. Ensuring robust data security to establish trust with the EPR system, reassuring stakeholders on the confidentiality and use of data only for designated purposes.

NOT SUFFICIENT: It is important to recognise that EPR alone is not the answer to all of the textile sector’s challenges. Significant additional policy will be required to deliver change—as recognised by the EU Textiles Strategy (eg Eco-Design for Sustainable Products Regulation (ESPR), proposal for Digital Product Passports (DPP)), and may in turn facilitate the delivery of effective and efficient EPR. 

• The requirement for harmonisation will be equally relevant and necessary across all textile policies to reap the benefits of harmonisation set out earlier. Complementary investigations such as assessing the impacts of different financing mechanisms for (EoL) management activities and different levels of scheme cost coverage will be just as important. 
• Global textiles policy at the moment is undeveloped, and there is a significant opportunity for industry, policymakers and NGOs to come together to identify the most appropriate way to deliver circularity and achieve reductions in environmental impact. 
• Each stakeholder group has significant value and experience to add to ensure the design and delivery of policy that works for all. There will certainly be impacts (both positive and negative) for all in the textiles sector. However, if an agreement can be reached on the objectives and principles of textiles EPR & wider policy then a harmonised approach can be delivered to most effectively drive a systemic transition to a more circular, sustainable textiles industry.

THE CONTEXT: The highly complex textiles industry with an interconnected value chain that plays an important role in global economies, is also accountable for significant negative impacts on the environment. Current European environmental regulation is unfit to tackle the impacts associated with the textiles sector. 

• Existing regulation under Article 11(1) of the Waste Framework Directive (WFD) merely requires member states to set up separate collections for textiles by 2025, though member states also have a generalised power to create Extended Producer Responsibility (EPR) schemes. The collection obligation constitutes a small piece of the puzzle in ensuring appropriate management of used and waste textiles and can only be the beginning of the move to achieving a circular textiles economy. 
• At a national level, policy is equally inadequate in driving the transition to a sustainable textiles industry. France remains the only Member State that has established and implemented EPR. 
• Sweden, the Netherlands, Spain & Italy all have laws or draft proposals to obligate textiles EPR – but the schemes themselves are yet to be implemented. Nonetheless, the European Commission is taking steps towards implementing an appropriate policy framework. 
• Textiles were identified as a key value chain in the EU Circular Economy Action Plan published in March 2020. It was in March 2022 that the Commission published its Strategy for Sustainable and Circular Textiles, suggesting clear areas for future policy change.
• A fundamental component of the EU Textile Strategy is the proposal for EPR for textiles to become a requirement. It will be essential in the move away from linear consumption pathways and towards a European circular economy for textiles of reduced environmental impact.