In 2020 the EU Commission has launched a Circular Economy Action plan1, aiming at making sustainable products the norm in the EU, support the 2050 carbon neutrality target of the EU, and to push for sustainable growth. The textile sector has been singled out by the EU commission, together with four others, as one with the highest environmental impact and less sustainable one.

Practically, this means that the EU Commission will deploy an array of regulations that will be impacting the way this industry designs, produces, markets and disposes of their goods. Some of those regulations will be implemented in the next few years, and their impact will be potentially massive. This is unprecedented.

This series of contributions aims at providing information, insight to some of the most impactful conversations currently happening for the apparel and footwear industry. This contribution will first aim at giving a general overview of the breadth of those EU regulations, outlining how they will impact virtually every actor (of the value chain), from sport to luxury brands, from manufacturers, fiber to product, to waste collectors. It will be followed by more detailed pieces, outlining for each key topic addressed the propositions on the table, their future journey and potential direction, how they will be impacting the industry strategies and operations, and what are the opportunities to have those regulations technically supporting the shift of the apparel and footwear sector to a sustainable and circular one. The main pieces discussed will be around the Sustainable Product Policy Initiative, transparency, both at European and French level, and finally waste and EPR.

As a starting point we have an extremely dispersed sector, both in terms of number of actors and in terms of countries involved. There is no equivalent of Apple, Samsung or Foxconn when it comes to T-shirts and trousers. Instead, you have a myriad of brands, retailers, interacting with a vast network of often small and medium size manufacturers and farms, scattered all around the globe, making it one of the sectors that could collectively benefit the most from impactful and well-designed regulations.

Some of the solutions discussed today will require strong coordination between the industry and policy makers, may this be for the development of new solutions, like fiber-to-fiber recycling, or to support building new infrastructure for the exchange of information all along its complex value chain.

Looking at all of the regulations in the pipeline today, they will impact each stage of the life cycle of a product, starting from the very beginning.

It will change the way you design your goods

An upcoming regulation is coming, the sustainable product initiative. This regulation, considered as the mother of all sustainability regulations, will impose requirements on how you design a product, from minimum quality levels to minimum recycled content of raw material. It will have a direct impact on what your products are, and will be.

Having completely integrated that on the side of sustainability, the other key transformation for apparel and footwear will be digitalization, it also integrates the creation of a digital twin for all garments put on the EU Market, the Digital Product Passport, accelerating information flow between all different actors, from manufacturers, brand consumers or governments.

It will change the way you source your goods

A draft regulation on Due Diligence2 has just been released. In its current status it virtually requires any brand doing business in Europe to have implemented solid programs to prevent and mitigate all potential issues (global warming, water scarcity, forced labor, poor working conditions, etc.) all along their value chain, from raw material (the cotton field) to end of life. It will require permanent improvement, and clear pathways to show how you will be able to do tomorrow what you can’t do today.

The effort required in terms of enhanced traceability, particularly upstream, monitoring and betters’ programs is significant. And the potential liability will be in percentage of turnover.

It will change how you market your goods

The textile sector has often been accused of Greenwashing. At the same brands, retailers and manufacturers are equally asking for stricter regulations to end this practice. To this end, The UCPD3 (unfair commercial practice directive) has been updated in December of 2021. In 2022, two additional pieces of regulations will be published, one on Substantiating Green Claims, aiming at normalizing how to measure the environmental performance of your product, for instance its carbon emission, and one on Consumer empowerment.

Those regulations are meant to accelerate comparability of claims, and accelerate the amount of robust information provided to consumers.

If you have or plan to have a message around the sustainability performance of your product or of your brand it is important to integrate those to avoid investing today into something soon obsolete, or potentially illegal.

Finally, it will change the way you think of the end of life of your products. By 2025 all waste in Europe has to be collected and sorted. To treat this waste and turn it into resources, a package of regulations are being discussed, and many countries are developing EPR schemes, to enhance the accountability of the brands and retailers regarding the products that they put on the market, to support the deployment of new sorting and recycling infrastructure, and to accelerate the transition towards a more circular business model.

All of those regulations will have a dramatic impact on the operations all along the apparel and footwear value chain, it has the means to really deliver an efficient transformation.

To make sure that those regulations are effective, and can lead to real impact, to actual decrease in carbon footprint and betterment of working conditions, the Policy Hub actively harvest all of the knowledge of the apparel and footwear sector to be able to build and deliver one ambitious industry voice to support policy makers into pushing for a circular and sustainable apparel and footwear industry.

This article is written by Baptiste Carrier-Pradal, Chairman of The Policy Bub. The Policy Hub- Circularity represents more than 700 apparel & footwear stakeholders including brands, retailers, and manufacturers. The Policy Hub for Apparel and Footwear is working to accelerate change by bringing the industry together to voice ambitious policy recommendations that promote a circular economy in the apparel, footwear, and textile industry. The Policy Hub was launched in 2019 by the Sustainable Apparel Coalition, Global Fashion Agenda, and Federation of the European Sporting Goods Industry and was later joined by two other partner organisations Textile Exchange and ZDHC Roadmap to Zero Programme.