Written evidence submitted by Green Alliance
About Green Alliance
Green Alliance is a charity and independent think tank focused on ambitious
leadership for the environment. Since 1979, we have been working with a growing network
of influential leaders in business, academia, NGOs and politics to stimulate new thinking and dialogue on environmental policy, and increase political action and support for environmental solutions in the UK.
This submission draws upon concepts and evidence set out in recent Green Alliance publications, including: our output in collaboration with the Centre for Industrial Materials, Energy and Products, Less in, more out,[i] and with the Resource Recovery from Waste programme, Building a circular economy.[ii] These publications cover in greater detail topics relevant to this inquiry.
Summary
Green Alliance’s research in this area focuses on maximising resource efficiency and transitioning to a circular economy. Within this submission, we examine the changing situation of the UK clothing market, and examine the infrastructure needed for a more circular system, and set out government policies that will encourage a reduction in the amount and impact of clothing consumed in the UK. Our key points include:
- Investment in circular infrastructure for textiles has been adequate, and requires a more strategic approach and vision from government. This should include an infrastructure stocktake, improved data capture and a £400 million kickstarter fund for upstream activities, as part of a wider programme of net zero compatible infrastructure investment for a green recovery.
- Voluntary progress from the fashion industry to date has in no way matched the considerable challenge of creating a sustainable fashion industry. Government intervention is required to ensure the sustainability of the entire industry and not only those that volunteer to reduce their impact.
- Regulatory options include a more ambitious approach to extended producer responsibility that extends beyond the end of life phase; making use of resource efficiency standards; and extending due diligence requirements for access to the UK market.
Detailed comments
- What impact has the pandemic had on fashion waste?
2.1. The pandemic has caused considerable upheaval in the fashion industry, and it remains unclear what the ultimate outcome will be. It was particularly hard hit by the lockdown as, despite considerable growth in online shopping in recent years, the bulk of purchases still take place in physical shops. That meant that clothing sales plummeted in the spring, including falling by more than a third in March, and as of September, clothing sales were still 12.7 per cent lower than pre-pandemic levels.[iii] As would be expected, online sales have not been hit to the same extent and have been increasing; the proportion of sales taking place online increased to 27.5 per cent in September, compared to just 20.7 per cent before the pandemic.[iv]
2.2. In the first instance, this means the unexpected lockdown in March led to a rise in unsold items of clothing, and retailers were faced with the problem of what to do with excess stock. Storing clothing for future is only a viable option for ‘basics’, with seasonal items needing to be offloaded through a combination of in-store discounts and sales to off-price retailers, though neither of these are long-term options.[v]
2.3. At the same time, households that conducted clear outs in lockdown were facing similar issues of what to do with the clothing they no longer want, with an expectation that there would be a surge in used clothing to deal with, whether through charity shops or through the export markets that have traditionally accepted much of the UK’s secondhand clothing. This excess of stock was complicated by the closure of many international markets, with prices for used clothing plummeting compared to pre-lockdown levels. (As of October, they had recovered slightly, with a tonne of clothing from a textile bank fetching £35-95, compared to £100-170 in January, and shop collections worth £190-320 per tonne, compared to £320-420 in January.[vi]) The Textile Recycling Association warned in May that, when charity shops, etc, fully reopen, there could be a surge in used clothing with nowhere to go, adding: “HWRC operators, local authorities and charities must understand that they may not get any income at all through banks and a gate fee could be introduced. In some other European countries they have already introduced a collection fee, with merchants pulling only high value reuse grades and being offered low rates to divert recycling grades to energy from waste incineration.”[vii]
2.4. We are therefore concerned that the likely short to medium term impact of the pandemic will be a considerable increase in both new and used clothing for which there is no market, meaning many items are likely to go to waste. The longer term picture is less clear, as it remains to be seen how the fashion industry will emerge from the current situation and whether the public’s appetite for high levels of consumption will continue.
- How can any stimulus after the Coronavirus crisis be used to promote a more sustainable fashion industry?
7.1. Investment in infrastructure for a circular economy – as part of a wider programme of net zero compatible infrastructure investment – should be seen as a way to promote economic recovery from the impacts of Covid-19. Green Alliance research has shown it is fundamental to the long term plan to promote growth and productivity, and getting on with building it will meet short term aims to boost demand, support new jobs and raise investment across the economy.[viii]
7.2. Our research into the current infrastructure for textiles in the UK suggests that the current situation is far from circular. Part of the reason that more than 80 per cent of the UK’s textile waste is ultimately disposed of in landfill or incineration is because we lack the infrastructure to recycle it, though the bigger problem is the volume of clothing sales and the lack of circular business models. At the moment, we estimate there is only capacity to recycle 50,000 tonnes, most of which is downcycling. In Building a circular economy: how a new approach to infrastructure can put an end to waste, we modelled three different scenarios for circular economy infrastructure for 2030 and found a considerable gap the required infrastructure in all instances (see below).
7.3. The best approach by far would be the transformation scenario, which assumes the consumption of textiles per person reduces in line with that of other European countries. In such a scenario England could cut the amount of material entering the waste system by half, to just over 300 kilotonnes in 2030. The amount collected for recycling would increase to just under 200 kilotonnes per year. England would require 15 new closed loop recycling plants by 2030, adopting innovative processes that enable ‘clothing to clothing’ recycling across a wide spectrum of fibres.
7.4. For this, new infrastructure and systems would also be needed, including:
- Information and education, including labelling for durability, recyclability and the presence or absence of substances of concern.
- Reuse facilities and leasing, for longer, more intensive use of clothing. This will require expanding existing facilities and making these business models more attractive to consumers by, for instance, improving cleaning, maintenance and quality monitoring; widening access to secondhand clothing through resale alongside new sales; and increasing leasing options, currently being trialled by some companies.
- Take back centres and specialist logistics, to support lower cost, shared operations for leasing and to expand clothing recovery schemes. Product tags that are scanned on collection, like those being trialled by Danish baby clothing company Vigga, could also improve tracking, sorting and inventory management.
7.5. These should be priorities for government attention to stimulate a green recovery. To succeed, government should first carry out an urgent infrastructure stock take for all materials, and should concentrate on the country’s current and planned capacity for reuse, repair and remanufacturing, and recycling, with textiles a priority sector. It should also improve data on material and products stocks and flows by following through on promises to create a National Materials Datahub. Finally, we believe it should create a £400 million circular economy kick starter fund, to move from research and innovation in the circular economy to actually embedding the upstream circular economy projects that will deliver carbon savings through better design, durability, reuse, refurbishment and high quality recycling.[x]
- Is the Sustainable Clothing Action Plan adequate to address the environmental impact of the UK fashion industry? How ambitious should its targets be in its next phase?
8.1. Voluntary progress from the fashion industry to date has in no way matched the considerable challenge of creating a sustainable fashion industry. The main problem with the existing targets is that they are measured per tonne of clothing, an approach that has not been keeping pace with the rise of fast fashion and the increasing churn of the nation’s wardrobe. Even if all the targets are met, the total impact of the industry could continue increasing, and the early figures suggest this has been the case to a worrying degree.
8.2. In the first four years after the voluntary agreement was introduced, total UK clothing sales increased from 950,000 to 1,130,000 tonnes a year, a rise of nearly 20 per cent.[xi] This 20 per cent increase more than offsets any improvements through the targets – the highest of which were 15 per cent reductions in carbon, water and waste to landfill per tonne of clothing sold. It is also worth noting that signatories account for less than half of the volume of UK clothing sales (see below). Changing this and reducing both the overall amount and impact of clothing bought should be a priority for the UK, given that consumption of clothing is already higher than in any other country in Europe, as documented in Fixing fast fashion.
8.3. As it happens, only one of the targets – related to reducing water use, which went down by 18.1 per cent – was met as of 2018, with the signatories performing particularly poorly on targets for reducing waste to landfill and reducing waste across product lifecycles. There was only a four per cent reduction in waste to landfill, compared to a 15 per cent target, and a 1.4 per cent reduction in lifecycle waste, compared to a 3.5 per cent target. By the end of 2020, signatories were expected to meet the target to reduce the carbon footprint per tonne by 15 per cent.[xii]
8.4. The follow-on initiative to SCAP, Textiles 2030, has promised to introduce aggregate greenhouse gas and water reduction targets, rather than targets per tonne of clothing.[xiii] While the exact targets and definitions are yet to be agreed, this represents a considerable increase in ambition, not least as it is aiming to deliver greenhouse gas reductions in line with the Paris Agreement.
8.5. However, we remain very concerned about the voluntary nature of the agreement and the fact that it will not capture all the actors in the fashion industry at a time when action is clearly needed across the board. We believe that, given the continually increasing impact of the sector, government intervention is required to ensure the sustainability of the entire industry and not only those that volunteer to reduce their impact. SCAP notably covers less than half of the UK fashion industry, with WRAP saying the signatories make up “more than 48 of UK retail sales by volume”.[xiv]
8.6. Although they are favoured by the government, voluntary measures have a patchy track record that should be reconsidered in light of global net zero goals and the associated environmental emergency. Multiple studies, including a review by RSPB, have questioned their usefulness in achieving environmental policy outcomes, and previous OECD research has suggested that voluntary targets do not normally go beyond what would have happened anyway.[xv]
- How could an Extended Producer Responsibility scheme for textiles be designed to incentive improvements in the sustainability of garments on sale in the UK?
11.1. To be successful, Extended Producer Responsibility schemes must do more than focus on end of life costs. As originally proposed, the concept of EPR was “a policy principle to promote total life cycle environmental improvements of product systems by extending the responsibilities of the manufacturer of the product to various parts of the product’s life cycle”.[xvi] In practice, though, including in the UK, attention has focused on transferring costs only at the end of life phase, which is not an adequate approach to reduce the social and environmental impacts from extraction and production phases.
11.2. The draft Environment Bill Schedule 5, for instance, is creating a new power to introduce charges to cover disposal costs in producer responsibility schemes, which it says may include: “(a)collecting and transporting products or materials for disposal, (b) sorting and treating products or materials, (c) other steps preparatory to disposal of products or materials, and (d) providing public information about the disposal of products or materials.” This is altogether too narrow and misses an opportunity for much more impactful attention at the upstream processes that should also be covered by EPR.
11.3. It is also a particular problem for textiles, where the vast majority of impacts occur during fibre production and processing. Together, they account for more than 70 per cent of the total carbon footprint of clothing in the UK (and the contribution of the end of life phase is actually carbon positive because of the reuse and recycling that occurs – see image below).
11.4. To be successful, then, EPR must do more than cover end of life costs, and should provide greater incentive to reduce the amount and impact of material placed on the market in the first instance. This can be achieved to some extent through ecomodulation of EPR fees to reward desirable clothing characteristics like durability and recycled content or indeed circular business models or systems of reuse. On its own, though, this is still unlikely to be enough to ensure the sustainability of the sector.
11.5. To complement any EPR scheme, much greater use should be made of standards and processes of due diligence to ensure that products that are placed on the UK market do not result in environmental degradation either in the UK or in any other country that produces products for the UK market.
11.6. The Environment Bill Schedule 7, for instance, is creating the power to introduce wide ranging resource efficiency standards that cover “(a) the materials from which the product is manufactured; (b) the techniques used in its manufacture; (c) the resources consumed during its production or use; (d) the pollutants (including greenhouse gases within the meaning of section 92 of the Climate Change Act 2008) released or emitted at any stage of the product’s production, use or disposal.” These are potentially powerful measures to address the considerable impacts that are unlikely to be covered through EPR in the UK. They are, however, enabling powers and the government has yet to indicate a plan to use them. Given the pollution and carbon impacts of the textile sector and a very real lack of resource efficiency demonstrated to date, we believe that the sector is a prime candidate for early development of resource efficiency standards using these powers.
11.7. We also believe that the concept of due diligence is a potentially useful one in this sector. The government has introduced an amendment to the Environment Bill with the aim of making it illegal for larger UK businesses to use commodities if they have not been produced in line with local laws protecting forests and other natural ecosystems. Questions remain about the final design, but this is another potentially powerful regulatory tool. It will already affect the textiles sector to some extent as leather is one of the commodities covered. As it develops, though, we believe the focus and stipulations of due diligence should not be limited just to deforestation, but should also be used to address all environmental and social harms caused by the supply chains for goods sold in the UK. These include pollution, water use, greenhouse gases, and poor labour conditions, which are all key concerns for the fashion sector.