Can sustainable fashion marketing truly hit the mark of accuracy?

The regulations in the textile industry are approaching like a dark cloud announcing an impending storm. However, many professionals in the sector are unsure about how, when, and through what means they will need to start addressing the requirements that European authorities are primarily emphasizing to improve transparency in the industry.

Navigating Marketing regulatory uncertainty

The regulatory fog brings confusion and misinformation, leading to the launch of marketing campaigns that, in a strong effort to steer clear of greenwashing, are inadvertently pushing away their consumers. Sustainability sells, but moralistic messages do not resonate as well.

However, consumer trust is exactly the goal of two prominent European directives. Firstly, the Directive on Empowering Consumers for the Green Transition, already in effect since last March, aims to enable consumers to make informed purchasing decisions and thereby foster more sustainable consumption. Secondly, the Green Claims Directive, on which the Council announced last week that it is ready to begin discussions with the European Parliament, aims to safeguard consumers from greenwashing practices by ensuring that purchasing decisions are guided by trustworthy environmental claims.

The Green Claims Directive and the Empowering Consumers for the Green Transition Directive jointly establish a coherent policy framework to help the Union in the green transition by transforming consumption patterns in a more sustainable direction.

Europe has established the framework for how commercial messages concerning the sustainable aspects of products should be handled. Among the requirements, environmental claims must be substantiated with recognized scientific evidence. For a robust evaluation, data demonstrating a high level of quality and accuracy should be provided, or methodologies used to calculate such data should be made accessible. Yet, upon closer inspection of the regulations, there is a lack of definition regarding the criteria for data accuracy or the methodologies required for extracting the communicated information.

The role of methodologies in sustainability claims

What level of accuracy can we expect from green claims substantiated by data if the use of a specific methodology for calculating such data is not required?

From the viewpoint of a sustainability expert in the fashion industry, upcoming regulations seem to lean towards being overly broad, aiming to create loosely defined frameworks that provide companies with a kind of carte blanche. However, the lack of clear boundaries within these systems could endanger the ambitious environmental goals for which the regulations were originally intended.

Without a standardized methodology for assessing impact information, the system will continue to lack transparency. Let's consider for a moment that we're discussing food products, and depending on each brand's calculation methods, an almost identical product could display different calorie counts on its label. In the food industry, calorie calculation adheres to certain rules and standards to ensure accuracy and consistency in the nutritional information provided to consumers. So, why aren't the most accurate impact calculation methodologies also being outlined for the fashion industry?

The Product Environmental Footprint (PEF) is a methodology developed by the European Commission to evaluate and communicate a product's environmental impact across its lifecycle. Some sustainability platforms, like BCome, adhere to the recommendations of this methodology for conducting Life Cycle Assessments, alongside the ISO 14040/14044 Environmental Management standards. However, European regulations currently do not require the PEF as a mandatory measurement methodology for all companies.

Lessons from recent controversies in fashion compliance

To address sustainability regulations, it's crucial for fashion businesses to apply scientific methodologies that ensure the accuracy of their findings. A couple of years ago, concerns arose when it was revealed that H&M was manipulating the sustainability ratings of its products. The H&M scandal underscored the limitations of relying solely on the Higg Index as a tool for assessing clothing sustainability. If the aim of regulations is to educate consumers and provide them with an accurate representation of the products they're buying, along with the opportunity for maximum transparency to make informed decisions, it's vital to consider the methodology used and its limitations to ensure the utmost accuracy in brands' sustainability claims.

According to a study conducted by the European Commission in 2020, over half of environmental claims and labels are vague, misleading, or unfounded, with 40 percent lacking substantiation.

With 50 percent of European consumers believing that brands often mislead them when communicating their environmental efforts, regulations do little to help by not setting clear terms for the methodologies that brands should use when calculating their impacts. Even if brands were to meet all the requirements outlined in the Green Claims Directive, the risk of greenwashing would persist if the methodologies they employ lack scientific basis and rely on vague calculations that fail to accurately represent the reality behind the product.

The path ahead for European regulations

With a two-year deadline for Member States to transpose the Empowering Consumers for the Green Transition Directive into national laws, it's still unclear whether each country will establish its own calculation methodology — which would further complicate the comparison between products from different Member States — or if, on the contrary, a standardized methodology will be established to harmonize the system and make it easier for consumers to compare and understand information.

In recent months, we've witnessed France taking the lead in defining an aggregate impact score through ecolabelling, led by the French Agency for Ecological Transition (ADEME). We'll see if this strategy positions the country as the industry standard or, conversely, sparks the desire to develop independent evaluation systems, hindering industry standardization.

Nobody said establishing a regulatory framework was easy, and the intersection of fashion and sustainability is no exception. With regulations evolving and the urgent need to tackle greenwashing, the industry faces a monumental challenge that it must address sooner rather than later.