The Product Environment Footprint (PEF) methodology has a key role to play in the EU's apparel sustainability strategy, however industry experts argue it discriminates against natural fibres such as cotton, in favour of synthetics.

Over the past five years the EU commission has focused on its Green Deal and implementing sustainability-based legislation.

Its main objective is to ensure apparel and textiles on the EU market are durable, recyclable, made of recycled fibres, free of hazardous substances and produced in a way that is respectful of both people and planet. The deadline for the EU to achieve all of this is 2030 with the ultimate goal of making fast fashion out of fashion and having reuse and repair services widely available.

During a live panel discussion at COP29 in Baku, Azerbaijan, moderator and Better Cotton policy and advocacy manager Hélène Bohyn explains the EU is using the Product Environmental Footprint methodology for its sustainability strategy despite it “clearly” favouring synthetic fibres over natural ones. 

She says: “Better Cotton finds this highly questionable as does the Make the Label Count coalition, which Better Cotton is happy to be part of”. 

Man Friday Consultancy’s managing director George Candon who represents the Brazilian Cotton Growers Association (ABRAPA) agrees, stating: “For the textiles sector the commission is favouring the use of the Product Environmental Footprint category rules in relation to apparel and footwear.” 

During the session titled ‘Beyond the label: the climate impact of natural fibres versus synthetic fibres, he points out the Product Environmental Footprint (PEF) methodology is used to assess certain criteria for the sustainability profile of apparel and footwear fibres. 

Importance of updating PEF before green claims legislation 

Candon suggests the issue with this is that it discriminates against natural fibres and has a clear bias towards synthetic ones possibly out of a misguided assumption that they are more environmentally sustainable. 

He explains the most recent piece of legislation coming out of the EU is the green claims regulation, which aims to ensure any sustainability claims on a product are reliable, verifiable and credible. 

“That’s why we’re actively trying to get PEF adjusted and rectified before it gets published in the green claims legislation,” he adds.

Plus, he asserts the EU is coming into its trialogue session, which is Euro speak for when the three parties of the EU commission and parliament come together to work out what the final legislation is going to look like.

He states: “If we don’t get this right now it will be damaging from a climate perspective for decades to come.”

Bohyn is keen to clarify what is meant by natural versus synthetic fibres. She shares: “When we talk about natural fibres we refer to cotton, wool and silk as these are biodegradable and generally have a lower carbon footprint during disposal. Unlike synthetic fibres, millions of people around the globe depend on the production of natural fibres like cotton to sustain their livelihoods. 

“Synthetics are man-made and include polyester, nylon and acrylic. These fibres derive from petrochemicals so contribute to fossil fuel depletion and have higher greenhouse gas emissions during production. They are said to be more durable but are not biodegradable and can persist in the environment, which contributes to microplastic pollution.” 

Impact of EU legislation on natural fibres 

Australian National Farmer Federation CEO Tony Mahar admits he’s concerned about the impact of the EU’s sustainability legislation on natural fibres. 

He says Australia is a large producer of natural fibres, including cotton and wool and it is export-dominated so rightly or wrongly the EU has a strong influence on regulations that can filter down through Europe to other countries and corporates that will buy Australian cotton or wool. 

He states: “The implications of regulations are quite instrumental and can have a really large impact.

“We definitely need to influence the adoption or the development of these standards and guidelines to make sure they’re accurate and reflect the true sustainability of natural fibres.

Why is there misconceptions on natural fibre’s sustainability? 

Mahar points out the natural fibre industry in Australia has done an amazing amount of work to improve its sustainability credentials. A few decades ago there were some issues in terms of water and chemical usage in Australia’s industry, but over the last 30 to 40 years it has reduced both by half, while producing more cotton. Plus, he’s proud to say there has been lots of investment in innovation and technology. 

He shares: “The natural fibre industry has a great story to tell in terms of its environmental gains and achievements.” 

The data shows cotton is an incredibly sustainable product and it’s not only having an environmental impact but also a positive social and economic impact around the world so it’s the true definition of sustainability.

Candon highlights Brazil and Australia are two of the largest cotton-producing countries, which means both countries can deliver solutions and sustainability at scale.

How to make PEF regulation more fit for purpose? 

However, Candon shares that if using the current PEF methodology as applied to textiles, apparel and footwear, the comparison between natural cotton fibres and synthetic fibres gives synthetics a gold star ranking, while putting naturals in the “naughty corner”. 

He believes it is a “completely wrong picture” as it doesn’t take into account that microplastics are an issue. It could be argued that synthetic fibres are recyclable but Candon states that in reality the amount of recycling that’s happening is “negligible and most synthetics end up in landfill or being incinerated which causes even more CO2 emissions”.

He reminds the live audience that synthetics are manufactured from oil that comes out of the ground and even the extraction of the oil is not taken into consideration in terms of the energy and the environmental performance of the material. 

He goes as far as to say PEF itself and its methodology being applied to fibres is “fundamentally not fit for purpose”. 

Mahar agrees and urges EU legislators to use a standard and guidance that is realistic and reflects the true nature of natural fibres and their circularity benefits.

If we are going to be accurate and these standards and guidelines are going to be meaningful then they have to take oil extraction into account, he insists. 

Plus, he says the way natural fibres are produced, the recyclability and impact on communities also need to be considered. 

“We feel the footprint and sustainability of cotton and wool is not being captured well enough to reflect the benefits of these products and the fact their attributes are much more sustainable than synthetic fibres.” 

Will changes to PEF be made in time? 

When quizzed on whether the changes to the regulations will get made in time of upcoming regulations, Candon sees the panel being at COP29 and coming together to discuss the issue as a positive step. 

He adds that he is actively supporting Make the Label Count, which is a coalition of natural fibre producers. He is also engaging with European stakeholders and there’s a public consultation that’s ongoing until early December so he urges everyone to get involved. 

Make the Label Count is calling for PEF to have three key things: 

• An indicator for microplastics emissions as that’s not currently taken into consideration 

• An indicator for plastic waste, especially as the EU is focused on reducing plastic waste 

• An indicator for circularity as oil is neither renewable or circular. 

Mahar concludes that ranking natural fibres as worse than those that come from oil doesn’t make any sense so he urges all involved and especially key members within the EU to make the standards more realistic. 

In September a survey conducted by non-profit Changing Markets Foundation revealed an increase in the use of synthetic textiles with the organisation warning the EU’s anti-greenwashing plans make polluting fabrics a better choice than organic cotton.