Centre for Sustainable Fashion, and Social Purpose Lab, University of the Arts London              SFS0002

Written evidence submitted by Professor Dilys Williams on behalf of Centre for Sustainable Fashion, and Social Purpose Lab, University of the Arts London

Centre for Sustainable Fashion (CSF) is a University of the Arts London research, knowledge exchange and education centre, based at London College of Fashion. Founded in 2008, the centre shapes and contributes to Fashion Design for Sustainability, as a field of study and set of industry, and education practices. CSF takes a systemic approach towards fashion’s sectoral, social, economic and cultural practices being embedded in practices of equity and ecological stewardship.

Centre for Sustainable Fashion wholeheartedly welcomes the state of play review and enquiry of the Environmental Audit Select Committee, and its call for action towards a UK fashion system with underlying operating principles of environmental care and benefit, social equality and good jobs.

 

Policy context since original enquiry

At the time of the Fixing Fashion enquiry in 2018, and the follow-on enquiry in 2020, the fashion and textiles sector had been operating in a global policy vacuum. The UK still has no substantive policy framework to address the fashion industry’s extractive and exploitative practices, which have worsened since then. However, the policy context outside of the UK has shifted significantly since this time. Led by the EU and the US, regulatory and legislative changes are now underway that will affect the operations, practices and value chains of the global fashion and textiles industry. Although many of these initiatives have yet to be fully implemented, we can learn from their scope and coverage to determine the UK’s best course of action.

In 2019, the European Commission released its vision for a climate-neutral economy, the European Green Deal. The Circular Economy Action Plan is one of the main building blocks of the European Green Deal, introducing initiatives across the product lifecycle from design to waste prevention, as well as a specific strategy to boost the market for sustainable and circular textiles. The EU Strategy for Sustainable and Circular Textiles and its associated policy initiatives have marked a step change in fashion policy.

Concurrently, state-level legislation in the US (such as California’s Garment Worker Protection Act and New York’s Fashion Sustainability and Social Accountability Act and the Fashion Workers Act) is also being rolled out to address fashion’s impact on people and planet.

 

Which UK policy initiatives are working and where is there still a lack of progress?

Fashion and textiles environmental policy is still in its infancy into the UK, and fashion related emissions have worsened over the past five years. The trajectory of UK fashion related emissions is grim reading, with UK citizens the 4th highest fashion related carbon emitters in the G20. https://hotorcool.org/wp-content/uploads/2022/12/Hot_or_Cool_1_5_fashion_report_.pdf  There is evidence to demonstrate that cultural change, business model change and policy interventions could enable the UK to change this trajectory and keep within 1.5 degrees increase.

The policy initiatives that are taking place involve industry engagement, and there is a significant increase in industry activity relating to sustainability, albeit outsized by increases in the volume of production.

-          Textiles 2030: Textiles 2030 was introduced in 2021, as a voluntary industry programme funded by Defra. Its signatories, representing more than 62% of clothing placed on the UK market, are asked commit to science-based 2030 targets and to deliver the Textiles 2030 Roadmap, which aims to drive the implementation of design for circularity, circular business models and closing the loop on materials. Although these requirements are not binding, Centre for Sustainable Fashion’s engagement with industry has highlighted the benefits of being able to draw from a network of industry professionals committed to making progress on circular fashion. This ‘coalition of the willing’ means that many companies now employ sustainability teams to develop initiatives for reducing emissions and waste and to undertake EMS reporting.

 

-          Maximising Resources, Minimising Waste: In August 2023, Maximising Resources, Minimising Resources was introduced as England’s new waste prevention programme. It sets out priorities across several sectors, including textiles. It aims to support the UK’s net zero commitment and waste reduction targets, through increasing product longevity and reducing waste to landfill and incineration. The programme includes a circular economy innovation fund to support relevant projects, such as an EPR industry pilot and a textiles sorting and recycling demonstrator – both of which are underway. The programme is also exploring the potential to introduce measures relating to the collection, sorting and recycling of textiles, and it has consulted industry stakeholders via a survey and targeted interviews to gather initial feedback on its proposals (although this has yet to be taken to formal consultation stage). The programme represents a good starting point but action has not been taken to turn its priorities into substantive policy. There is also a burgeoning area of the fashion sector in re-sale and repair, across the spectrum from low value to luxury pieces. Despite these new models, there is no evidence of a drop in consumption, and indeed there is anecdotal evidence of a rebound effect, which is increasing overall consumption.

 

-          Green Claims: In July 2022, the UK Competition and Markets Authority (CMA) opened an investigation into potential greenwashing at ASOS, Boohoo and ASDA. The investigation examined the language used in green claims, the criteria used to include products in “more sustainable” collections, and the product-level information provided to customers. Following a collaborative investigation, ASOS, Boohoo and ASDA have signed formal agreements to use only accurate and clear green claims. The agreements (or “undertakings”) were published on 27 March 2024, and commit the brands to change the way they promote their products. The CMA plans to publish specific guidance for the fashion industry in due course, building on the existing Green Claims Code, to enhance accountability when it comes to green claims. The outcomes of the investigation will help brands to communicate more confidently about sustainability and will help customers to make more informed purchasing decisions.

 

-          Entrepreneurship and skills development: License to Sew: West Lancashire Borough Council has organised a programme in partnership with a local social enterprise, The Sewing Rooms, to offer a free course to train people to become textile machinists in 10 weeks, aiming to address the skills shortage that emerged after production left Lancashire in the early 1950s. The current aim is for the programme to be rolled out nationally, an exciting opportunity to support creative skills development across the UK. Net Zero as Catalyst PEC report https://pec.ac.uk/wp-content/uploads/2023/12/Net-Zero-as-a-Catalyst-in-fashion-micro-and-small-enterprises-PEC-Discussion-Paper-May-2023.pdf identifies examples of work taking place in Business Support for SMEs across three intersecting areas – ecological, social and economic wellbeing – that could act as pilots in and beyond the fashion sector. The findings suggest that efforts to operate more sustainably can encourage an expansion of creativity and business distinction. Likewise, design entrepreneurs who ground their creative practice in the context of the wellbeing economy are developing operational practices that align with that creative ambition; meaning operational (putting their own house in order) and conceptual sustainability (making and influencing change in society) can be mutually reinforcing.

 

-          Localism: We’ve seen the emergence of cultural placemaking both in practice (e.g., East Bank and The Trampery in East London) and in strategy, featuring in the government’s Levelling Up agenda. Although this still feels largely theoretical, Fashion Roundtable and other organisations have indicated the power of “localism” as a force that appeals to both sides of the political spectrum, seeking to support local British businesses whilst addressing the environmental impacts of the fashion system. Research projects such as Life in Clothes, working with UK Fibreshed regional chapters, demonstrates the need for design knowledge that is embedded in local knowledge and is interdisciplinary https://www.sustainable-fashion.com/life-in-clothes

 

-          Research & Innovation: We have seen research and innovation funding directed towards technological innovation in fashion and  textiles with UKRI’s £6 million investment and UAL’s FTTI New Landscapes Catalyst Grant Scheme. Such funding schemes are supporting innovations in the sector, and the industry is starting to report increases in the use of recycled materials. For example, recycled polyester usage has grown from 4% of all polyester in 2010 to around 14% in 2022, according to Textile Exchange’s latest report, although fashion – fashion recycling is yet to be commercialised. The pace of change is slow, funding is not representative of the sector’s value, and progress relating to regenerative materials remains difficult to scale. Overall volumes continue to rise and concerns regarding the efficiency paradox are emerging.

Beyond these few areas of progress, there is still an overwhelming need for legislation to support improvements in our current fashion system. We’ve seen a lack of progress in the following areas:

-          Production Volumes: Due to a lack of legislation, we are no closer to industry-wide reporting on production volumes. Only five companies (Adidas, Cotopaxi, Desigual, Inditex, and VF Corporation) disclose how much clothing they make each year, according to Remake’s Accountability Report. Unfortunately, all five companies saw an increase in production year-on-year (see below). A legislative requirement for brands to report their production volumes could be a first step, followed by the introduction of production reduction targets or production caps.

A screenshot of a chart Description automatically generated

-          Clothing Longevity & Circular Services: It has been estimated that there are 20 new garments manufactured per person each year and that we are buying 60% more than we were in 2000. As such, the shift to cherishing our items and a prioritisation of value and longevity has yet to be realised. Remake’s 2024 Accountability Report found that only 15 out of 52 companies provide in-house repair or upcycling services. They also found that none of the 52 reviewed companies demonstrated that circular services and revenue streams will eventually be used to replace linear production, instead merely running in parallel to the production of new goods. This suggests that the tax system could still be used to encourage the uptake of circular services in place of excessive production and consumption.

 

-          Synthetic Fibre Use: Synthetic materials have dominated global fibre production since the mid-1990s, and polyester alone contributed the highest amount of GHG emissions of any single fibre in 2022. Textile Exchange finds that the production of virgin fossil-based synthetic fibres rose from 63 million tonnes to 67 million tonnes in 2022, while polyester continues to dominate, making up 54% of all fibres produced globally. Remake’s 2024 Accountability Report found that only three companies (Everlane, Reformation, and Victoria’s Secret & Co.) demonstrated and reported that their overall portion of oil-based synthetics is decreasing (and not simply that their use of recycled content is increasing). This highlights the need for a tax on virgin plastic or subsidy for the use of lower-impact materials, to help address the continued use of plastic-based materials in fashion.

 

-          Emissions: Remake’s 2024 Accountability Report found that only three companies (Burberry, Everlane, and H&M Group) met all four of Remake’s climate demands to 1) publish their full emissions; 2) set (and had approved) short-term 1.5°C pathway-aligned science-based targets; 3) set (and had approved) ambitious long-term net-zero targets; and 4) demonstrate reductions in their total greenhouse gas emissions compared to base years. A legislative requirement for brands to set 2030 and 2050 targets that align with net zero, and demonstrate annual progress against these targets, is essential.

 

-          Waste Colonialism: The export of clothing from the UK and Europe to countries, such as Ghana, prevails. Kantamanto Market in Accra, Ghana, sells and upcycles around 6 million garments every week, which translates to about 30% of the total clothing that arrives on Ghana’s shores. The remaining 70% ends up in ditches and drains, harming local communities and causing environmental damage. This highlights the need for the UK to address its mindset around overproduction and overconsumption, as well as the need to invest in local collection, sorting and recycling infrastructure.

 

-          SME Financing & Investment: Only 1% of UKRI’s spending is invested in the creative industries, let alone in fashion and textiles. This highlights the need to ensure that funding and investment better reaches fashion businesses, particularly SMEs, with over 99% of fashion businesses identifying as SMEs in 2018. SMEs often drive innovation in design, materials, and business models, which are then rolled out across the industry more widely, so improvements in access to research and innovation funding is essential.

 

-          Skills Development: Creative skills development, including design, making and repairing, are no longer a core part of the curriculum in the UK. Re-introducing core making skills into the curriculum will help to support the broader mindset shift required to rethink our approach to engaging with clothing. The License to Sew example (see above) provides a great use case for adult skills development in areas once famed for their fashion and textiles industry, an example which could be rolled out more widely.

 

-          Good work agenda and human rights: Labour abuses still prevail in fashion supply chains, with COVID-19 bringing light to a series of new cases. For example, we have recently seen the closure of Boohoo’s Leicester factory, following revelations around poor working conditions and illegal wage practices. In Milan, a Giorgio Armani subsidiary was recently shut down for exploiting and underpaying Chinese workers. Further afield, Remake’s 2024 Accountability Report compares annual CEO salaries to those of garment workers on minimum and living wages in Bangladesh (see below), to showcase the inequality that continues to reverberate through the fashion system. In 2022, California introduced its Garment Worker Protection Act to outlaw piece work, penalising both manufacturers and brands for wage theft and illegal pay practices. There is scope for the UK to draw from this, to ensure that worker rights are respected both in the UK and across supply chains internationally.

A graph with yellow bars Description automatically generated with medium confidence

Which European policy measures should the UK be taking up?

The EU and its Member States are much further ahead than the UK when it comes to implementing policy specifically targeting the fashion and textiles industry. Despite Brexit, upcoming EU legislation will still apply to any UK businesses who trade or operate within the EU. Therefore, there is great scope for the UK to align its approach with the EU, given that many UK-based organisations are already preparing for change. Our engagement with industry tells us that sustainability teams are supporting teams in advance of upcoming legislation, engaging in industry networks on policy and legislation, and hiring new members of staff to support in the transition. Failing to implement similar legislation here would also present a significant risk both to the appeal of UK companies and traders in the global market and to the UK’s international reputation and competitivity.

There are a number of key areas where the UK could learn from the EU and its Member States:

-          Extended Producer Responsibility (EPR): France introduced its EPR scheme in 2009. Its latest five-year plan sets aside €1 billion of government funding up to 2028, of which €154 million will support the repair for shoes and garments (see above), and €100 million will be allocated to encouraging re-use. France has increased the collection of used textiles by 40% since the EPR was first introduced and it plans to reach 60% by 2028. Although the EPR scheme has been successful in terms of collection rates, it has received criticism for the continued export of textile waste to countries in the Global South. As such, should the UK intend to follow suit, ensuring that UK-based recycling infrastructure is in place to support the subsequent rise in the collection of used textiles will be essential. To note, the EU is planning to introduce an EU-wide EPR scheme to address the 5.2 million tonnes of clothing and footwear textile waste produced in the EU every year.

 

-          Repair Incentivisation: France implemented a bonus scheme for repair in October 2023. It enables customers to claim €7 for repairing a heel and €10-25 for clothing repairs, supported by a €154 million fund put in place by the government to cover 2023 - 2028. This applies to all tailors and repair shops that sign up to the government programme. Although it’s too early to assess its impact, Deloitte Insights show that high repair costs are the leading cause of replacement over repair, with 60% of customers citing high repair costs as the reason for preferring to purchase new rather than repairing. At the IPF Forum 2024, SOJO announced its Pledge to Repair initiative which aim to address the lack of UK policy relating to repair, by encouraging brands to pledge to offer UK-wide repair services for their customers.

 

-          Ecodesign Requirements: The upcoming revision to the Ecodesign for Sustainable Products Regulation (ESPR) will require brands and retailers to review the design of products to ensure that products are durable, repairable, recyclable, to a great extent made of recycled fibres, and free of hazardous substances. In addition, the Digital Product Passport (DPP) will be introduced, enabling easier access to and sharing of product data, which will improve product-level transparency and support customers to adopt more responsible purchasing practices. Through our industry partnerships, we know that UK-based brands are already pushing ahead with circular design, and they would be well placed to respond to UK legislation on ecodesign.

 

-          Waste Minimisation: According to the European Environment Agency, an estimated 4-9% of all textile products put on the market in Europe are destroyed before use, resulting in significant negative effects for the environment. A large share of unsold products is ultimately exported out of Europe, often burdening communities in the Global South and harming health as a result of the toxins released through incineration. Through the proposed update to the ESPR, the EU plans to introduce a ban on the destruction of unsold goods, as well as requiring companies to publicly disclose the volume of unsold goods.

 

-          Waste Exportation: The EU’s revised Waste Framework Directive aims to address the issue of illegal exports of textile waste through clearly defining waste and reusable textiles, to curtail exports of waste disguised as reusable textiles. This will complement the Waste Shipments Regulation, which will ensure that shipments of textile waste only take place when the country indicates its willingness to import the agreed waste and when there are guarantees that the waste is managed in an environmentally sound manner.

 

-          Washing Machine Filter Requirements: From January 2025, France intends to introduce a requirement for all new washing machines to be fitted with a device to filter plastic microfibres, as a means to address the impacts of microfibre shedding. This could provide a concrete solution to the microfibre pollution problem referenced in the Fixing Fashion Report recommendation in 2019.

 

-          Marketing & Communications: The EU has introduced two policy initiatives on information and communications, Empowering Consumers in the Green Transition and the Green Claims Initiative, which aim to ensure that product claims are substantiated to support customers to make better informed purchasing choices. As a result of this and France’s Anti-waste for a Circular Economy Law, some brands have started to publish the required product-level sustainability information, with LVMH brands hoping to achieve complete compliance by summer 2023. LVMH has committed to providing customer-facing information systems for all new products by 2026.

 

-          Due Diligence: The EU’s much-awaited Corporate Sustainability Due Diligence Directive requires big companies to identify, prevent, and bring an end to actual and potential adverse impacts on human rights, including labour rights, and the environment in their own operations and across their global value chains. This means that brands and retailers will have to map out their supply chains in full and address any potential concerns relating to worker rights and pay, as well as negative impacts on the planet.

 

-          Addressing Fast Fashion: In March 2024, France’s lower house of parliament advanced a new “Fast Fashion” Bill. It covers three proposed measures (see below), which could help to address the operations of fast fashion companies in France. The retailers and brands that would be affected by the proposed law have yet to be determined. Depending on the “fast fashion” definition that is adopted, the Bill could apply only to ultra-fast fashion companies (e.g., Shein, Temu), or also include companies with business models similar to Zara and H&M.

Have there been any rebound effects due to policy at European or UK level?

-          CMA Investigations: The CMA’s investigation into ASOS, Boohoo and George at ASDA initially resulted in a period of greenhushing across the fashion sector, as many brands felt afraid to openly communicate about their sustainability progress. However, from our understanding, the collaborative nature of the investigation has supported ASOS, Boohoo and George to feel more confident in their sustainability communications. We can hope to see that the upcoming update to the Green Claims Code will see other brands feel more confident in their communications. Initiatives including UNEP’s fashion communication playbook https://wedocs.unep.org/bitstream/handle/20.500.11822/42819/sustainable_fashion_communication_playbook.pdf?sequence=3 and Conde Nast and Centre for Sustainable Fashion’s Sustainable Fashion Glossary https://www.condenast.com/glossary evidence interest in ecological literacy and the role and accountability of fashion media in environmental stewardship.

 

-          EPR in France: The EPR in France has led to a positive impact on the collection and sorting of used textiles since its implementation in 2009. However, the EPR has not been supported by the needed recycling infrastructure, resulting in the continued export of used textiles to countries in the Global South. This highlights the need for complementary infrastructure and measures to ensure that clothing can be recycled in-country. Overall figures of production and products in circulation is needed in order to be able to understand the overall impact of EPR initiatives.

 

-          Modern Slavery Statement Requirement: Under the Modern Slavery Act, certain organisations must publish an annual Modern Slavery Statement to outline how they are preventing modern slavery in their operations and supply chains. However, worker abuses still prevail in fashion supply chains, begging the question as to whether the Modern Slavery Statement has provided a cloak for brands and retailers to simply hide behind rather than creating real change.  There is a need for further compliance measures, perhaps drawing from the EU’s Corporate Sustainability Due Diligence Directive.

 

-          Recycled Content Requirements: Recycled content requirements are likely to feature in the EU's revised Ecodesign for Sustainable Productions Regulation. Although recycled polyester content is preferable to virgin polyester use, it will be interesting to see whether a percentage requirement results in an uptick in recycled synthetics over organic or regenerative natural fibres. A tax on virgin plastic-based materials would be preferable to stipulating requirements over recycled content if this is the case, especially as recycled content from other industries does little to reduce fashion’s emissions and contribution to waste pollution.

 

-          Target Setting: We have seen the proliferation of target setting across the industry over the past few years, not necessarily met by action. Where we require target setting, we need to ensure that industry is also required to regularly provide progress updates and be held accountable to meeting these targets, to ensure that brands and retailers are not able to hide behind ambitious targets with no evidence of progress. Data gaps need to be filled and whilst there is evidence of some partnership initiatives, such as the Fashion Pact, there is little evidence of robust data gathering and benchmarking.

 

-          The value of SMEs. The UK’s world leading reputation for creativity, especially in fashion, has long given the UK a clear distinction. Whilst France and Italy enjoy world class status due to their luxury fashion sectors, the UK’s crown is based on the graduates from its world-leading design schools and its micro and small businesses. There is a lack of recognition of the value of SMEs in economic and environmental terms and opportunities for policy levers to support the vital contribution that fashion design entrepreneurs offer and to give them collective clout. . https://www.sustainable-fashion.com/_files/ugd/9dbc3c_c6ac51e2fded4d108bb2ce4a837cbb14.pdf?index=true

April 2024