European Green Deal – What about upcycling?

Become climate neutral by 2050 – that is the declared sustainability goal of the ‘European Green Deal’ of the European Union. Part of this is the textile strategy that the EU Commission published in March 2022. The focus is on two central points: recycling and eco-design. However, what is not mentioned in the strategy is upcycling, although the method contributes significantly to the circular economy by reusing old, already produced textiles. In this article, FashionUnited shows what obstacles the upcycling sector has to contend with and how designers are confronting the problems.

With the Textile Strategy, the EU Commission is designing a plan to promote the circular economy in the textile sector and to make the industry more circular and sustainable in the future. The monthly report ‘Schlaglichter der Wirtschaftspolitik’ on the textile strategy from last September states: “The textile industry [wurde] identified as a resource-intensive sector that requires targeted actions to become more sustainable and circular.” A core aspect is the environmental impact of fast fashion. Above all, the textile strategy is intended to tackle the problems that the manufacture, production and wear and tear of fast fashion clothing cause more in the future.

On the verge of legality

Upcycling designer Sinah Schlemmer draws attention to this fact and another major hurdle imposed by the European Union with her campaign ‘Don’t Label Me’.

The Koblenz native founded her label Amaran Studio in November and uses her fashion to draw attention to political and social grievances. When she designed her first collection, Schlemmer encountered an unexpected hurdle: the Textile Labeling Ordinance of 2011. This stipulates that the individual components of textile products must be broken down as a percentage and shown on the label.

The basic idea behind the regulation is transparency and openness to customers about the origin of the textiles used. However, as the legislation stipulates, the labeling for many upcycling labels cannot be implemented in practice.

Since upcycling fashion consists of textile waste and fabric remnants, it is often not possible to break down the individual components. Many donated old clothes no longer have labels, are made of mixed fabrics and are also limited in quantity. That is why upcycling thrives on patchwork looks that are made up of the tiniest scraps of fabric. But how can designers properly implement textile labeling in the production of their designs when they often use materials of unknown origin and unidentifiable fabrics?

“Unless you have a lab, you can’t really find out afterwards,” Schlemmer told FashionUnited. Only with a laboratory can she break down the materials as required by law. In reality, the whole thing works a lot more pragmatically – with the kitchen scales. The designer sorts the textiles in advance according to the type of fabric, weighs the individual parts and then weights them as a percentage of the total weight. If the amounts used are too small, or if she is unsure about the type of material, she uses the term “various types of fibers”. For labelling, she uses a time-consuming stamping technique that sometimes takes her half an hour for a label.

This approach poses two problems. According to the designer, she feels restricted in her creativity by the regulation. Because in order to meet the labeling requirements, she now mainly uses old clothes with labels and not the materials that she would use from her creative process. Other labels deliberately only process fabrics of which they can be sure of the material composition. This in turn leaves a lot of unused textile waste.

The second problem also accompanies her every day in her work – the concern about controls and warning fees: “We are on the edge of legality. We are all at risk of warnings,” said Schlemmer.

Don’t Label Me

With her campaign, Schlemmer wants to “make responsible EU politicians aware of this problem and, as part of the revision of the Textile Labeling Ordinance, bring about a change in the law that exempts upcycling clothing from the labeling obligation,” says the brand’s website. She has already addressed numerous politicians, NGOs and interest groups – but so far without any significant success.

The central measures of the strategy are listed in the appendix to the communication from the EU Commission. The revision of the labeling regulation and the examination of the introduction of a digital label for the period 2023 are listed under ‘Further measures for sustainable production and consumption’. So the timeframe for change is right now.

Schlemmer also demands that the European Union promote upcycling in order to promote the development of a circular textile economy: “If you want a circular textile economy, then you should definitely make life easier for upcyclers. Your obligation to label textiles really prevents upcycling from happening,” says Schlemmer.

“According to the current work program of the European Commission, a presentation of the proposal for the revision of the textile labeling regulation is planned for December of this year,” said SPD politician Delara Burkhardt in a written statement to FashionUnited. The member of the European Parliament is responsible for a sustainable textile strategy in her parliamentary group. “This means that the revision is unlikely to be completed before the end of this legislature. The upcycling sector offers many and particularly creative solutions for the circular economy and against textile waste. I will therefore check carefully how and whether the Commission’s future proposal will look like and whether these aspects have been sufficiently addressed by the Commission. If this is not the case, I will propose changes.”

Upcycling and circular economy

The relevance of the upcycling sector for a circular economy becomes particularly clear in view of the increasing amount of textile waste. In Europe alone, around 7.5 million tons of textile waste are generated every year, around 15 kilograms per capita. This is the result of the study ‘Scaling Textile Recycling in Europe – Turning Waste into Valuable’ by the management consultancy McKinsey & Company. According to the European Parliament, Europeans buy almost 26 kilograms of textiles a year and in turn throw away around eleven kilograms.

Tons of old clothes are turned into exported to developing countries. However, the largest amount, 87 percent, is incinerated or ends up in landfills, according to the European Parliament. From January 2025, the new separate collection obligation for textile waste will also apply, which provides for a mandatory separate collection of textile waste. Remnants of fabric that would probably have ended up in household waste in the past will increase the mountain of old clothes and donated textiles from there.

The Ellen McArthur Foundation estimates that less than 1 percent of all textiles are currently recycled. McKinsey & Company came to a similar conclusion. The researchers have also found that by 2023, one fifth of textile waste could be made into new clothing. Fibre-to-fiber recycling can therefore contribute to a functioning circular economy in the future. The big but, however, are investments of six to seven billion euros and technical upgrades.

The establishment of a circular textile economy by 2030 does not seem realistic under the given conditions and without investments in the billions. Upcycling, as a resource-saving, ecological and cost-effective method, is currently given little attention in the plans of the EU Commission. Rather, existing laws are putting obstacles in the way of upcycling labels and making their work, which makes a significant contribution to a circular economy, more difficult.

So what should the future of upcycling look like under the given conditions? And how is a circular textile industry supposed to succeed if the methods that contribute to it are not promoted? Questions to which the responsible EU politicians have not yet had any answers.