Ref. Ares(2022)5114864 - 13/07/2022
22 February 2022
To:
Mr. Thierry Breton, Commissioner for Internal Market
Don’t lose the thread: the need for an ambitious tangible vision to change the textile sector
Dear Commissioner,
More clothing is being produced, consumed, and thrown away than ever before, putting immense
pressure on people and our planet. Textile supply chains are notorious for human rights and
environmental abuses, whose breadth and scope are often also concealed by corruption1. The COVID-19
crisis has shed further light on the power imbalances across textile and garment value chains and how
their impact is mostly felt by the most vulnerable in the value chain, namely workers and farmers.
Ambitious changes in the textile industry are essential to stand any chance of stopping further
environmental and climate breakdown, preventing widespread human rights abuses, as well as securing
human health.
The upcoming EU strategy for sustainable textiles should not miss the opportunity to set an ambitious
vision for a sustainable and circular EU textile sector which delivers on the EU’s zero pollution objectives
and the bloc’s 2050 climate-neutrality target, while advancing the EU’s objectives for the respect of
human rights and decent work worldwide.
On 11 December 2019, European Commission President Ursula von der Leyen presented the European
Green Deal as an ambitious direction for Europe towards sustainability. We, co-signatories of the civil
society
Strategy for Sustainable Textiles, Garments, Leather and Footwear 2, look forward to seeing this
ambition translated into an impactful and comprehensive EU strategy for sustainable textiles. Many
Members of the European Parliament expect the same3.
For the upcoming EU strategy to be coherent, ambitious, and impactful, it must:
● Set an EU-wide quantitative target for material and consumption footprint reduction with specific
objectives for textile products for the sector, and an accompanying timeline, while ensuring a Just
Transition to prevent any worker or region being left behind. Targets for the re-use and preparing for
re-use of textiles should also be set with the aim to create quality jobs in Europe in these fields.
1
www.transparency.org/en/news/cpi-2021-highlights-insights
2
https://fairtrade-advocacy.org/wp-content/uploads/2020/07/Civil-Society-European-Strategy-for-Sustainable-
Textiles.pdf
See also:
https://wardrobechange.eu/policy-recommendations/
https://cleanclothes.org/file-repository/fashioning_justice.pdf/view
3 Letters from MEPS: The Civil Society Shadow European Strategy for Sustainable Textile, Garments, Leather and
Footwear, 3 June 2020
: https://heidihautala.fi/wp-content/uploads/2020/07/Letter_ShadowStrategy_3rdJune2020.pdf;
Raising the ambition of the EU’s strategy on Textiles, 26 January 2022
: https://drive.google.com/file/d/1-
zycVfOG50RhGHqcl9Mn_lgaggW1zkzq/view
● Set out how the ban on the destruction of unsold/returned durable goods (introduced by the Circular
Economy Action Plan) would be implemented in the textile sector. Unsold goods should include excess
inventory, deadstock and returned items, with a particular focus on returns through e-commerce.
● Ensure Ecodesign measures go beyond recyclability and recycled content to focus on design for longer
lifetimes. Take clear regulatory action to minimise and phase out the use of harmful substances in
textiles throughout the value chain through requirements on chemicals of concern in final products
as well as those used in the different steps of the production cycle. Ensure the EU’s market
surveillance regime is made more robust as systemic and effective product checks will be necessary
to ensure compliance with new requirements.
● Investigate an Extended Producer Responsibility (EPR) scheme for textiles with strong progressive
eco-modulation criteria going beyond recyclability, by including disclosure of chemical information
and setting fee thresholds that depend on the number of new products placed on the market by a
company each year. Any EPR schemes for textiles must include separate targets on collection, reuse,
and recycling of textiles, and strictly respect the waste hierarchy in cooperation with social economy
enterprises active in the collection and re-use of textiles.
● Go beyond putting the responsibility on consumers to make sustainable choices and instead make the
existing linear model unattractive through economic incentives and fiscal measures.
● Ensure a level playing field for EU-produced products, exports, and imports. The EU should strengthen
social and environmental sustainability concerns in the EU’s trade regime, especially the GSP regime.
The EU should ensure that trade agreements and preference programmes are used as levers to
promote sustainable development, human rights, and fair and ethical trade around the world, and to
improve the responsibility of value chains.
● Address the economic, environmental and social impact of e-commerce across the value chain by
setting out a plan to regulate this area through legislative means.
● Address the impact of unfair purchasing practices (UTPs) imposed by buyers upon manufacturers in
the sector, including their environmental and social consequences. The Strategy must commit to
undertaking legislative action to ban the most damaging UTPs from the textile sector.
● Show the way for the future sustainable corporate governance legislation and its human rights and
environmental due diligence (HREDD) requirements to adequately tackle the challenges that are
specific to the global apparel and textile sector, such as freedom of association, health and safety,
living wages. This will require ensuring that all SMEs active in the sector are covered by the legislation,
that the impact of chemical use on the environment and people in production countries as well as the
impact of purchasing practices are covered by the due diligence obligations of buyers.4
● Require companies to provide detailed information about upstream or downstream environmental
impacts (such as chemical and material-efficiency aspects) and human rights and social aspects as well
4 The EU has already taken an initiative to curb similar practices in the agri-food sector. See also:
https://news.industriall-
europe.eu/content/documents/upload/2021/9/637684400585561764_210106%20Draft%20Leveraging%20UTP%20tr
ansposition_20210927.pdf
as responsible business conduct including prevention of corruption. Such traceability and
transparency requirements must include as a minimum information on all factories in the
manufacturing and post-consumer phase and be accessible to all stakeholders. Furthermore, it shall
also require that companies start mapping their full value chains, including home-based workers and
informal workers, and require disclosure where such disclosure can be done without potential harm
for workers. Require companies to provide detailed information on how they are recognising the
essential role of freedom of association and collective bargaining. Require companies to prevent and
mitigate the gap between actual and living wages. These obligations can benefit from the framework
of the digital product passport as a traceability and reporting mechanism and could be included in the
future HREDD framework.
● Set a strategy to achieve public procurement tenders which include integrity, environmental and
social responsibility as criteria. The role of social economy enterprises collecting and re-using textiles
must be enhanced and associated with the legal collection and waste management obligations and
targets of local authorities and Producer Responsibility Organisations.
Timely and effective action on these policy measures as well as strong alignment between them can
establish the ambitious pathway for sustainability and decent work that the textile industry urgently
needs. To this end, we call on you to ensure our recommendations are reflected in the EU strategy for
sustainable textiles.
We look forward to receiving your response,
Sincerely,
Fair Trade Advocacy Office
ECOS
European Environmental Bureau
Max Havelaar France
Transparency International xxxxxxx
Traidcraft Exchange
RREUSE
Solidaridad Europe
Zavod za pravično trgovino, 3MUHE
