The proposed revision of the Waste
Framework Directive, presented on 5 July 2023, is garnering attention for its
focus on addressing critical waste streams, particularly textiles.
In a joint statement, a number
of signatories called on policymakers to fully implement the polluter pays
principle to address the textile waste crisis in the European Union.
Industry stakeholders
including the Changing Markets Foundation, Zero Waste Europe, Recycling Network
Benelux, the Environmental Coalition on Standard and the European Environmental
Bureau presented the need for a more comprehensive approach to several key
concerns with the proposed EPR for textiles and offered recommendations for
improvements:
- Setting targets for waste prevention, collection,
reuse, and recycling: The proposal falls short of
setting explicit targets for waste prevention, collection, reuse, and
recycling for textiles. The signatories stress the importance of
introducing waste prevention targets for food and textiles, emphasising
that tackling fast fashion trends is essential to reducing textile waste.
a) Waste management performance
targets: The absence of performance targets is believed to
hamper the development of effective waste management strategies. The
signatories call for the adoption of performance targets, drawing
inspiration from successful EPR models in the Netherlands and France.
- Eco-modulation as an incentive: The
EPR system should promote better product design and waste prevention
rather than acting as a mere fee for producers. Eco-modulation should be
enhanced to encourage eco-friendly design and address the environmental
impact of textile production.
- Volume criterion for eco-contribution fees to tackle
fast fashion: Introducing volume-based fees for the number of new
items placed on the market can incentivise brands to prioritise quality
over quantity, reducing the overall environmental footprint of textiles.
- A fund for change and justice: A
portion of EPR fees, at least 10%, should be allocated to fund reuse and
repair operations, fostering a more sustainable and profitable textile
sector.
- Annual waste compositional analysis:
Conducting annual waste compositional analyses will enhance data
availability, enabling targeted interventions to reduce textile items
ending up as residual waste.
- Preventing textile exports of waste: The
proposal should include regular inspections and strict penalties to deter
companies from exporting waste disguised as used textiles. Exported textiles’
actual reuse and their environmental impact should be monitored closely.
- Reforming the governance framework of EPR schemes: The
existing governance of EPR schemes is said to be “inherently flawed”,
leading to corporate capture and insufficient environmental outcomes.
Signatories propose various reforms to ensure a more democratic and
environmentally effective governance framework such as granting national
governments greater control to ensure a democratic policy-making process
with a broader range of stakeholders and involving all stakeholders, such
as social enterprises, municipalities, waste managers, and NGOs, in the
decision-making process for EPR schemes, rather than limiting them to an
observing role.
- Inclusion of online marketplaces in EPR obligations:
Online platforms should verify producer registration in EPR registries
before listing products and be held liable for non-compliance with EPR
schemes.
- Expanding the scope of EPR schemes: Items
like mattresses and carpets, which are often landfilled or incinerated,
should be included in EPR schemes to promote circularity in the industry.
- Shorten EPR transition period: The
signatories stress the urgency of addressing these issues, especially the
excessively long transition period, which could lead to further
incineration of textiles and impose additional burdens on municipalities
and taxpayers.
Last week (19 October), fashion and textile academics from the
UK’s University of Manchester argued that sustainable fashion and sportswear
needs Government focus as one million tonnes of textiles are disposed of every
year in the UK with 300,000 tonnes ending up in landfill or incineration.
In August, the environmental network Zero Waste Europe (ZWE)
highlighted how the most significant global warming impact of the fashion and
textiles industry lie in the production phase and called for a radical
remodelling of the industry with concrete targets.
By Just Style