In Brussels, the European Fashion Alliance calls for compromises on the forthcoming eco-design regulation

The European Fashion Alliance, an association of European fashion associations, met for the first time in Brussels. The aim was to present the fashion industry’s position on the forthcoming European legislation. The main focus was on the eco-design regulation for sustainable products and the associated obligation for a digital product pass.

The focus of the Brussels event was the discussion of the new legislative initiatives of the EU, which will affect the industry and its processes in a variety of ways. EU Commissioner Thierry Breton acknowledged that this transformation is challenging: “We are here to support you at this turning point in your sector. If there’s one industry that’s heavily involved in supply chains, it’s fashion. We are committed to ensuring that all textiles entering the European market are durable, recyclable and respectful and have launched several EU initiatives. Firstly, the ecodesign regulation to promote sustainability and the circular economy. Second, digital labeling with a digital product pass. Thirdly, the revision of the Waste Framework Directive, which will reduce textile waste.” However, Breton continues, the textile strategy can only succeed “if we can implement it in binding and implementable measures with the entire ecosystem.”

Creativity must be preserved

The central topic of the event was the positioning of the European Fashion Alliance on the forthcoming European legislation on the Ecodesign Regulation for Sustainable Products (ESPR) and the associated obligation for a Digital Product Passport (DPP). In doing so, the EFA expressly warned against adopting requirements “that would adversely affect the craftsmanship and artistic tradition and/or the competitiveness of the industry and the entire ecosystem of European fashion manufacturing, which is largely dependent on designers and high-quality brands”. the EFA in its position paper.

Photo credits: EU Commissioner Thierry Breton during his presentation in Brussels. Photo: (c) Alex Kolotouhkina

Longevity is also related to consumer behavior

An important part of the ecodesign regulation is the demand for a long service life of the products. “While durability is a key aspect of sustainability, it needs to be viewed holistically, using new metrics to measure it that take into account both intrinsic and extrinsic influences,” the EFA continued. Because longevity is also the result of consumer behavior and the care taken towards the product. Therefore, the EFA calls for a stronger focus on the reusability and repairability of the products, instead of just aiming at the functional robustness of the products.

Recycling: too few recycled fibers and poorer quality

The demand for a high proportion of recycled fibers currently contradicts the possibilities that the market actually offers. There is still a lack of availability and quality of such fibers.

In the case of mechanical recycling, the fiber length is impaired, which leads to quality losses during reprocessing and – in the case of synthetic fibers – the increased release of microplastics. This makes it necessary to mix it with other fibers, which in turn can affect recyclability. “The requirement to use recycled material may therefore lead to the production of more fibers or material blends that have lower recyclability,” according to the EFA. She therefore calls for greater consideration of raw materials that have a lower ecological impact, instead of a focus on recycled material.

More flexibility when destroying goods

The EFA also calls for more flexibility for manufacturers to choose alternatives to destroying goods – such as reuse, upcycling and recycling – that best fit the characteristics of their products. Any action in this regard should be taken after an appropriate sectoral impact assessment.

Especially for creative fashion products, recycling – which implements destruction – is “a key activity for realizing the circular economy and sometimes the most important or only available waste treatment for unsold products,” according to the EFA in its position paper. Resale is not always a viable alternative to destruction due to risks such as intellectual property infringement and unauthorized resale. This also applies to sample collections, for example. Pascal Morand, Board Member of the European Fashion Alliance and Executive President of the Fédération de la Haute Couture et de la Mode, stresses: “The EFA supports the ban on the destruction of unsold goods, but this requires a clear definition that these goods are intended for consumption and are suitable for sale. Also, upcycling and recycling in general cannot be considered as mere destruction as they also encompass virtuous practices. They are part of the circular economy mentality and the business models of innovative and creative designers.”

Therefore, the EFA strongly advocates the development of new practices such as remanufacturing and upcycling, which give a second life to unsold products while giving free rein to creativity, and opposes a ban on the recycling of these products.

Recyclability is still in its infancy

The amount of used textiles that can be collected in the European Union far exceeds the current possibilities for their further processing. In addition, textile recycling is not yet able to sort and dismantle the textiles efficiently. These obstacles must be taken into account when setting requirements in this area, according to the EFA.

Calculate product-specific environmental compatibility

According to the EFA, the assessment of the environmental impact of products also requires harmonized and product-specific calculation methods that are based on a life-cycle assessment approach and only in this way could comparable and reliable communication be possible. “This will benefit both consumers and green transition businesses, provided the environmental databases are sufficiently granular and accessible to economic actors,” the EFA continues, arguing that trade-offs between these ecodesign requirements should be considered in order to achieve sustainability comprehensive and practical, yet ambitious way”.

Photo credits: Scott Lipinski, Chairman of the European Fashion Alliance and Managing Director of the Fashion Council Germany in Brussels. Photo: (c) Alex Kolotouhkina.

Digital Product Passport: Warning of too much administrative effort

As part of the Ecodesign Regulation, the EU also requires the creation of a digital product passport. The EFA notes that it supports the provision of relevant, accurate and reliable information for consumers and the digitization of this information in a digital product passport. However, she strongly warns against any measure that would impose a disproportionate administrative and technological burden on businesses, and in particular SMEs, and which would not particularly address the challenges related to the long and multidimensional supply chain of textiles.

Call for participation in the “Status of European Fashion” survey

The European Fashion Alliance also announced the first European survey “Status of European Fashion” at the round table. The survey serves as the basis for an industry report to be presented in autumn 2023 at the next EFA conference, to which decision-makers from the European fashion industry and EU politicians are invited. “With our Europe-wide survey, which will be made available on europeanfashionalliance.org from June 15th, we will record the current state of knowledge on upcoming European legislative proposals and directives as well as the sustainability status of brands. Not only facts and figures, but also the experiences of the fashion industry are of great importance to us, as this enables the EFA to propose concrete and measurable calls to action,” says Scott Lipinski, Chairman of the European Fashion Alliance and Managing Director of the Fashion Council Germany.

The European Fashion Alliance (EFA) was founded in 2022 as the first transnational alliance of European fashion associations. Her goal is to give the European fashion industry a collective voice in the EU legislative process and to expertly accompany and accelerate the required transformation process.

ttn-12