FACTUAL SUMARRY REPORT OF THE PUBLIC CONSULTATION ON THE EU Strategy for SUSTAINABLE TEXTILEs
I.Introduction
This report provides a factual summary of the results of the Online Public Consultation (OPC) held in the context of the preparation of the upcoming EU Strategy for Sustainable Textiles. The OPC was one element of a wider consultation that also included a set of seven workshops as well as consultation with national authorities. A more in depth analysis of the consultation activities will feed into the final report in support of the preparation of the EU Strategy for Sustainable Textiles.
The OPC took place between 12.05.2021 and 04.08.2021. It was launched on the EU Better Regulation platform, Have Your Say, and targeted all citizens and organisations. It was advertised via the European Circular Economy Stakeholder Platform and through the social media accounts of the Directorate General for the Environment and Directorate General for or Internal Market, Industry, Entrepreneurship and SMEs.
This document should be regarded solely as a summary of the contributions made by stakeholders to the online public consultation on the EU Strategy for Sustainable Textiles. It cannot in any circumstances be regarded as the official position of the Commission or its services. Responses to the consultation activities cannot be considered as representative sample of the views of the EU population.
II.Approach to the public consultation
The consultation was open to anyone via the EU online system. The consultation took place in the form of an online survey, which enabled two forms of input:
-Input through a stakeholder survey that included a general set of questions concerning the type and activities of the respondent, and a targeted questionnaire, which was split into three main areas: 1. Textiles, a key sector of the EU economy and key enabler of the recovery, 2. A circular economy in the EU textiles sector and 3. Global compliance, due diligence and transparency
The survey contained 12 multiple choice questions, using likert-scales of 5 options. The scales for most questions included one or more ‘opt-out’ responses, such as ‘Do not know’.
-Written input: stakeholders were invited to upload Position Papers or other supporting documents. One open question at the end asked the respondent for any further relevant feedback, information or opinions they wished to share.
III.RESPONSES TO THE PUBLIC CONSULTATION
a)Overview of respondents:
A total of 544 stakeholders responded to the consultation. Of these, 76 uploaded supporting documents via the online platform. A further 36 supporting documents were received by the European Commission via other channels.
80% of respondents originate from within the EU, representing 23 of the 27 EU countries (see Figure 1). There was a disproportionately high number of respondents from Austria, Belgium, Estonia and Portugal when considered against country population. The non-EU respondents came from 3 EFTA countries and 18 additional countries around the world. 34 responses came from organisations in Australia.
Figure 1: Country of origin of the stakeholders
Half of all responding stakeholders were either businesses or business associations, with a fifth of responses coming from citizens (Figure 2). NGOs were the third most frequent respondent.
Figure 2: Number and share of respondents from each stakeholder type
The part of the value chain that was most represented was the manufacture of new textiles and clothing (23% of all responses) and the brands and retailers that sell them (10%). The R&D sector was also well represented (10%).
A large share (45%) of responding stakeholders selected the ‘Other’ option. Many of these comprise citizens, public authorities, certification organisations and NGOs. However, 81 businesses and business associations also ticked the ‘other’ option. These included producers of fibres, chemicals and other materials that supply the manufacturers of textiles and clothing.
Figure 3: Number and share of respondents from stakeholder types according to main activity
b)Responses to the questionnaire
The results for the 12 questions included in the questionnaire can be found below. In addition to the overview of stakeholders views to each of the options suggested, this section features disaggregated data for most representative options.
Q. 1.1 How would you assess the relative importance of the following factors in promoting sustainability while ensuring resilience and competitiveness of the Textile Industry?
All of the proposed elements were considered to be very important or important by at least 70% of the stakeholders. Those elements which were considered to be most important were the use of clean production processes, design of textiles for circularity and proper and sustainable functioning of global value chains. Supporting the uptake of circular business models amongst consumers and using sustainably sourced fibre types received less support. Figure 5 shows that collectors of used textiles and footwear for reuse and brands/retailers of new clothing and textiles that considered supporting the uptake of circular business models amongst consumers to be least important.
Figure 4: Importance (according to all stakeholders) of factors in promoting sustainability while ensuring resilience and competitiveness of the textile Industry
Figure 5: Various stakeholders assessment of the importance of ‘supporting the uptake of circular business models amongst consumers’ in promoting sustainability while ensuring resilience and competitiveness of the textile Industry
Q. 1.2: Which tools should be given priority at EU level to recover from the crisis and promote resilience and sustainability of the textile industry?
The 10 options were given by stakeholders an average rating of between 3.5 and 4.1 on a scale of 1 (low preference) to 5 (high preference).
Figure 6: Average score given (by all stakeholders) to tools at EU level to recover from the crisis and promote resilience and sustainability of the textile industry
Environmental organisationsnd public authorities prioritise binding requirements and economic instruments for ensuring sustainable products higher than businesses do. However, all the selected stakeholders rate voluntary instruments such as ecolabels lower than binding requirements and economic instruments.
Figure 7: Score given by selected stakeholders to tools at EU level to recover from the crisis and promote resilience and sustainability of the textile industry
Q. 1.3: In your opinion which technologies will contribute most to supporting a competitive and sustainable textile sector in the EU?
Stakeholders expressed preference for some technologies over others for contributing to a competitive and sustainable textile sector, although all technologies achieved a reasonable score (see Figure 8). The most preferred technologies are those concerned with the recycling of non-reusable textile waste: automated sorting by fibre type and colour; and technologies for fibre-to-fibre recycling of both single-fibre textiles and blends. A digital product passport for textiles is also rated relatively highly.
Figure 8: Average score given (by all stakeholders) to technologies that could contribute to supporting a competitive and sustainable textile sector in the EU
When differentiated by stakeholders, there is relatively high agreement on the importance of automated sorting technology, and to a slightly lesser extent on fibre-to-fibre recycling technologies for single-fibre waste textiles (see Figure 9). Second-hand retailers, in general, rate recycling technologies lower than any other stakeholder, but are supporters of digital product passports and customisation and fitting technologies. Recyclers and waste collectors, on the other hand, rate automated sorting and recycling technologies highest.
Figure 9: Score given by selected stakeholders to technologies that could contribute to supporting a competitive and sustainable textile sector in the EU
Q. 2.1.1: Which elements of circularity in the value chain do you consider should be tackled as a priority?
On average, stakeholders consider all ten suggestions for elements to support the selection of more sustainable raw materials as being relevant (see Figure 10). All ten have been given an average rating of between 3.7 and 4.5 on a scale of 1 (low preference) to 5 (high preference).
Collectors and processors of used textiles and second-hand retailers prioritise that no unsold clothing ends in landfill more than other stakeholders, and recyclers and waste collectors prioritise fibre-to-fibre recycling more than other stakeholders. Second-hand retailers, have in general prioritised most elements lower than other stakeholders, the only exception being supporting repair and ensuring no unsold textiles end in waste. (see Figure 11).
Figure 11: Prioritisation by selected stakeholders of elements of circularity in the value chain
Figure 12: Prioritisation by selected stakeholders of elements of circularity in the value chain
Q. 2.2.1: Which element of raw material selection do you consider should be prioritised in order to promote sustainability?
On average, the respondents assessed promoting the utilisation of sustainably sourced/produced fibre types in the EU and globally as most important with an average score of 4.2. However, several respondents, commented in the open text box, that ‘sustainably-sourced’ fibres must be clearly defined. Acting on a lack of demand from end-consumers (households and public bodies) for recycled content in clothing and textiles was assessed as being least important, still scoring 3.7.
Figure 13: Average score given (by all stakeholders) to elements that promote sustainable raw material selection
A further set of proposals and comments in the free text concerned the use of recycled materials in new products. It was proposed that economic incentives for recycled content should favour recycled content from post-consumer textiles rather than recycled plastic waste from other sources (such as PET bottles). Other stakeholders argued that any discussion on economic incentives should focus on instruments at Member State level.
Question 2.3.1: Which of the actions listed below should be given priority to promote more environmentally-friendly production processes?
Figure 14: Average score given (by stakeholder groups) to actions that promote environmentally friendly production processes
The avoidance/limitation of hazardous substances and reducing emission to water, soil and air from production processes are considered of highest preference. When split via stakeholder type (see Figure 14), environmental and consumer organisations and public authorities were most positive about avoiding/limiting hazardous substances (rating this action at 4.5 or higher), businesses relatively positive (rating it at 4,1) and research institutions least positive (with an average score of 3.4).
Q. 2.4.1: In order to facilitate the transition to a more circular economy, how would you assess the relative importance of the following product features?
Stakeholders considered the avoidance of hazardous substances and the recyclability of the product as of highest importance. These were followed in importance by product durability, along with information on its lifetime plus information on the lifecycle impacts of the product. Of least importance were timeless design, lower resource demand for laundering, reusability and information on product repair.
Figure 15: Importance (according to all stakeholders) of product features that facilitate the transition to a circular economy
Second-hand retailers (see Figure 16) rated reusability, information on lifecycle impacts and avoidance of hazardous substances highest while recyclers (Figure 17) were much more concerned with recyclability and recycled content. Both collectors of used textiles for reuse, and providers of textile services such as leasing, rated recyclability and recycled content significantly higher than they did durability, reusability or reparability. It is not clear what lies behind these choices and information in the free text did not provide clues. All stakeholders agreed on the need to avoid hazardous substances in products, with at least 80% of each stakeholder group rating this as important or very important (see also under Question 2.3.1).
Figure 16: Importance (according to second-hand retailers) of product features that facilitate the transition to a circular economy
Figure 17: Importance (according to recyclers) of product features that facilitate the transition to a circular economy
Q. 2.4.2: How can the environmental impact from microplastics shed from clothing/textiles best be tackled without causing environmental problems in other areas?
The listed activities to reduce impacts of microplastic shedding were all considered to of similar relevance, (Figure 18). Technological solutions were also seen as important; both improving textile manufacturing to reduce shedding at source, and end-of-pipe technology for filtering out microplastics at wastewater treatment plants, and, to a lesser extent, in washing machines. Provision of information to consumers via labels was seen as least relevant.
Figure 18: Average score given (by all stakeholders) to actions to tackle the environmental impact of microplastics shed from clothing/textiles
Stakeholders used the free text box to provide further information on the options presented above. Regarding reducing the use of synthetic fibres in favour of natural fibres, there were several that argued that shedding of natural fibres can also be an issue if they have been coated with various finishing substances which may reduce break-down in the environment and carry hazardous chemicals. Moreover, some argued that there should be a distinction between non-degradable and biodegradable synthetics. Technical solutions could include filters on washing machines; ultrasound cutting of fabrics, reduced brushing in production and the removal of microfibres (via a wash-cycle or otherwise) prior to retail to consumers. Stakeholders also raised concerns regarding the degree to which products shed microplastics should be included as an element of the digital product passport and as part of the impacts measured by PEF method.
Q. 2.5.1 How would you assess the relative importance of the following measures to promote sustainable consumption behaviour at EU level?
Figure 19: Importance (according to all stakeholders) of various measures to promote sustainable consumption behaviour
The share of stakeholders that felt the measure to be important or very important ranged from 59% to 90% (Figure 19). Stakeholders prefer measures relying on the provision of reliable information to consumers on the circularity and sustainability of products, with provision of information and protection from false and misleading claims both being considered important or very important by 90% of stakeholders.
Businesses, EU citizens, public authorities, research institutions and NGOs had roughly the same prioritisation: they all prioritised product information, tackling false green claims and campaigns on overconsumption significantly above the promotion of new business models and repair, strengthening of product guarantees and promotion of the EU Ecolabel.
Q. 2.5.2 Which of the following business models contributing to a circular economy do you believe have most potential for economic viability and upscaling?
Figure 20: Average score given (by all stakeholders) to circular business models according to which have most potential for economic viability and upscaling
The sale of quality durable products with high personal value scores highest of all circular business models. This is completed by repair and fitting services, and redesign of used products into new products, which lie in a similar vein and have also been accorded high scores. Leasing/rental services also receive a high score as a business-to-business model, but less so when it concerns leasing to private consumers. Consumer-to-consumer exchanges received the lowest score of all business models.
Figure 21: Score given by selected stakeholders to circular business models according to which have most potential for economic viability and upscaling
In general businesses, business associations and research institutions are least enthusiastic about circular business models while consumer organisations, NGOs and trade unions are most enthusiastic. Those models that all stakeholders rate relatively highly (with a score of 3.5 or more) are selling quality durable products, repair and fitting services and business-to-business leasing/rental.
Q.2.6.1 How would you assess the relative importance of the following challenges to a greater reuse of used textiles?
The two challenges that are most highlighted by stakeholders both lie on the supply side rather than the demand side. These are a lack of collection systems for post-consumer textiles (80% consider important or very important) and a lowering quality of new textiles placed on the market. Demand-side challenges are seen to be of lesser importance by stakeholders, although falling global prices for second-hand textiles and lack of European demand for second-hand are evaluated by 59% and 57% of stakeholders respectively as being important or very important.
Figure 22: Importance (according to all stakeholders) of various challenges to a greater reuse of used textiles
Those stakeholders that are directly involved in the value chain for the reuse of textiles – second-hand retailers, collectors of used textiles for reuse and wholesalers of collected used textiles – rank these challenges similarly to other stakeholders, but in general give them a higher level of importance (see Figure 23). Similarly, to the other stakeholders, the stakeholders in the used textile value chain perceived a lack of collection systems for post-consumer textiles as the key challenge but also perceive falling global prices for second-hand textiles and lack of European demand for second-hand textiles as being significantly problematic.
Figure 23: Share of selected stakeholders that view various challenges to a greater reuse of used textiles as important or very important
Q. 2.6.2 How would you assess the relative importance of the following challenges to recycling of post-consumer waste textiles into new textiles in the EU?
All the challenges to recycling offered to stakeholders for evaluation under this question are perceived as important and relevant. Only one of the 14 challenges was put forward as important and very important by at least 65% of stakeholders: lack of cooperation/exchange of information along the value chain. Two challenges are judged by at least 85% of stakeholders as being important or very important: a lack of design of textile products for ease of disassembly and recycling and a lack of markets and capacities for textile recycling (see Figure 24).
Figure 24: Importance (according to all stakeholders) of various challenges to recycling of postconsumer waste textiles into new textiles in the EU
Recyclers of textiles waste perceive many of the challenges as even more critical than other stakeholders. No less than nine challenges are perceived as important or very important by at least 95% of recyclers.
Figure 25: Importance according to recyclers of various challenges to recycling of postconsumer waste textiles into new textiles in the EU
Q 3.1: Which of the following aspects are in your opinion more effective to promote sustainability (including fair wage, decent working conditions and labour and human rights across the value chain)?
Looking across the possible solutions to promote the social dimension of sustainability, more than 66% of the respondents assessed all the listed policy tools as important or very important (see Figure 26).
Figure 26: The percentage of respondents assessing different aspects to effectively promote sustainability as not important, not very important and very important.
Legislation ensuring that textiles placed on the European market have been produced under minimum standards for human and labour rights was considered the most important instrument among the possible options offered. 86% considered that such legislation was important or very important.
82% respondents rated Ensuring consistency on definition on waste/non-waste with respect to textile collection as important or very important. 80% of the respondents assessed that Better integration of social sustainability into EU Green Public Procurement criteria for textiles and setting target for green public procurement of textiles in Member States was important (34%) or very important (46%). One respondent suggested that sustainable procurement criteria should also be promoted in the private sector.
While the majority (66%) found voluntary agreements important or very important, one in four found it less (15%) or not important (10%). In general, those assessing voluntary agreements of less importance tend to be NGO’s, while businesses in average weighted voluntary agreement of higher importance. Respondents called for gender equality to be addressed in the Sustainable Textiles Strategy, as the textiles sector is dominated by women.
Figure 27: Importance according to selected stakeholders of voluntary agreements on human rights, upstream working conditions, labour rights, job security
Q 3.2: Which of the following instruments should be given priority to ensure that imported textiles materials and products comply with EU’s legislative requirements?
To ensure that imported goods comply with EU legislation, guidance in EU’s legislative requirements placed upon imported goods, including free trade agreements was on average considered of highest preference (4.3).
Figure 28: Average score of instruments to ensure that imported textiles materials and product comply with EU’s legislative requirements
Q. 3.3: Which of the actions listed below should be given priority to ensure that separately collected post-consumer textiles in the EU are processed and treated with due diligence to the waste hierarchy, environmental protection, human and labour rights and decent working conditions abroad?
All the listed instruments for ensuring that separately collected post-consumer textiles are processed and treated sustainably are considered of relevance (with average scores ranging from 3.3-4.2) (see Figure 29). Stakeholders accorded highest importance to Specify obligations for exporters to ensure and verify that textile waste exported to third countries are managed in an environmentally sound manner (4.2). The opinion on this varies little across stakeholder groups.
Of second most importance is Requirements of Member States to report on the processing and eventual destination of separately collected post-consumer textiles and textiles waste (4.1). Actors across the value chain were in relative agreement, but with NGO’s being most positive (4.4) and academic/research institutions being least positive (3.5).
Least important is the instrument establishing voluntary agreement with the post-consumer textiles industry on environmentally and socially responsible collection and processing of post-consumer textiles including downstream elements. NGO’s were least favourable (2.6). Some of the respondents noted in the free text that legislation is more reliable than voluntary agreements.
Figure 30: Score given (by various stakeholders) to actions of actions to ensure that separated collected post-consumer textiles are processed responsibly
