SFI0044

Written evidence submitted by the London Textile Forum

The London Textile Forum is made up of almost 100 organisations in the textiles sector that are dedicated to making the industry more sustainable. The forum aims to tackle textiles issues with the three main goals:

-          To keep textiles out the waste stream.

-          To identify and overcome barriers that hinder the collection, processing and potential market development opportunities for textile re-use and recycling.

-          To monitor and support relevant projects developed by members while providing a platform for the latter to openly discuss the issues surrounding the industry.

The primary aim of the Forum is to support the development of strategies that increase the diversion of textiles waste from disposal in London through London-based and national initiatives.

Our key asks include:

-          There needs to be an extended producer responsibility tax to incentivise brands to manufacture and dispose of their products responsibly, and imbed sustainability into core business strategy.

-          To address the major skills gap and challenges facing the the domestic used textiles sorting and recycling industry there needs to be adequate funding for NVQs.

1. Have UK clothing purchasing habits changed in recent years?

Compared to other goods, clothing prices have remained low. Due to the availability of cheap clothing and population growth the current trend is for clothing consumption per person to increase, while clothing utilisation has decreased. In a four-year period between 2010 – 2016, there was an increase of almost 200,000 tonnes of clothing purchased in the UK[1].

Source: WRAP

This is a global trend; over a 15-year period from 2000 to 2015 clothing production has almost doubled from circa 50 billion tonnes to more than 100 billion tonnes, while on average clothing utilisation has reduced 36%[2].

Source: Ellen McArthur Foundation Report: A New Textiles Economy

The rise of fast fashion is due to the following factors:

- Shopping is easy: it’s possible to shop on the go with smart phones using ecommerce websites, apps and mobile wallets. As a result, online clothing sales have grown consistently over the past 7 years[3].

- Marketing channels: celebrity endorsement of products on social media is the norm, where lifestyle digital content acts as both consumer inspiration and entertainment. Additionally, social media platforms link to shoppable content allowing users to easily click away from browsing to buying[4]. 

- Logistic improvements with rapid delivery and return processes: retailers can offer same day deliveries (Asos, Amazon), while ecommerce systems like ‘click and collect’ make it easy to collect and return items. This has greatly improved the online shopping experience and made it possible for consumers to purchase many items at a time with the intention of trying them on and then sending unwanted items back.

- Price: fast fashion is cheap. Millenials, who make up circa 28% of the UK population[5] have an estimated spending power of $2.45trn and tend to be more price sensitive, favouring fast fashion over other purchases[6].

- Speed: by mastering sales data analysis and being able to react within their supply chain fast fashion brands are able to offer new products constantly to meet consumer demand. Goldman Sachs compared the relationship between like for like sales and lead times, finding ASOS and Boohoo outperformed all other brands on the high street:

2. What is the environmental impact of the fashion supply chain?

How has this changed over time?

Clothing has the 4th largest environmental impact after housing, transport and food[7]. Some of the reasons are as follows:

1. Chemical Pollution from Textiles Processing

Of the 8,000 plus chemicals used in the textiles industry, many are toxic and persist in the environment such as heavy-metals, formaldehyde, alkylphenol compounds and phthalates. These chemicals are still being used, especially in developing countries where untreated toxic effluent waste from textiles processing is released into rivers and oceans. An estimated 20% of water globally has been polluted by the fashion industry[8]. The situation is considerably worse for the largest textile producers; China, Bangladesh and India have polluted up to 80% of their fresh water supplies to levels too toxic to drink or wash in[9], resulting in irreversible environmental damage, water scarcity, and adverse health impacts[10]. 

In developed countries legislation is used to enforce the proper treatment of effluent waste and regulate chemical use. In Europe, regulations such as REACH[11]  have resulted in a 190 tonnes reduction in the releases of substances of concern each year[12]. Additionally, there is a growing uptake of voluntary chemical accreditations such as OEKO-TEX®, Bluesign® and ZDHC. Unfortunately, this is not wide spread in the least developed countries and they are failing to address their effluent waste pollution from textiles[13].

2. Environmental impacts from growing conventional cotton.

Globally cotton accounts for 2.4% of cultivated land, but consumes 6% of pesticides and 16% of insecticides worldwide[14]. Pesticides kill almost 1,000 people daily from acute poisoning, while associated diseases include cancers, neurological diseases and reproductive problems[15]. The same health impacts are felt by all living organisms with drastic effects reported in non-target species, such as threatening animal and plant biodiversity, food webs and ecosystems, and reports of significant species population declines[16]. A study in Germany found insect populations had declined by up 82% during summer periods over a 27-year period, citing pesticides as one of the major causes[17]. Pesticides have also led to widespread contamination of air, water and soil bodies to toxic levels, in a study in Brazil 12 cotton pesticides were found in the rain water[18]. Furthermore, fat-soluble pesticides persist in the food chain for extended periods of time[19].

Nitrogen rich fertilisers used in cotton agriculture also increase soil acidity, releasing high levels of carbon and ammonia emissions. For example, in the UK the agriculture sector accounts for 88% of total UK emissions of ammonia from manures, slurries and inorganic fertilisers. Ammonia is a major greenhouse gas, contributing to global warming, smog and damaging sensitive natural habitats[20].

3. Micro-plastics

Polyester is now used in 60% of our garments and this quantity has doubled since 2000[21]. Washing synthetic textiles such as polyester, polyamide and acrylic is one of the greatest contributors to micro-plastic in the oceans[22]. Microplastics are persistent in the food chain and contain hazardous contaminants, an estimated half a million tonnes of plastic microfibres are released into the oceans annually[23].

Source: Ellen McArthur Foundations Report A New Textiles Economy

3. What incentives have led to the rise of “fast fashion” in the UK and what incentives could be put in place to make fashion more sustainable?

- Globalisation of the fashion industry: being able to find ever cheaper markets to operate in.

- Agile supply chains that allow brands to select their manufacturers based on price and lead time.

- No minimum quality standards: garment quality is brand remit. If garments had to meet certain quality standards they wouldn’t fall apart so quickly.

- No minimum manufacturing standards or supply chain traceability/visibility standards: factory auditing and policing within the supply chain is voluntary. One annual audit doesn’t eliminate child labour or bonded labour, brands can simply pass the responsibility down the supply chain, with no accountability.

- Poor enforcement of local working standards in the UK: factories in Leicester have been found to be paying workers £3 an hour[24], which means they can compete on price with factories outside the UK and produce products quickly.

- Tax incentives: for example Vietnam does not charge export tax on goods.

- Locality of manufacturers allows brands to react to trends quickly: European manufacturers can ship goods into the UK 15 days from the order being placed.

The linear model of take, make, dispose means there is no chain of responsibility. While fast-fashion brands enjoy all the benefits of this business model, the negative impacts are felt either down the supply chain, or by the organisations and communities dealing with the textiles waste problem. There needs to be an extended producer responsibility tax to incentivise brands to manufacture and dispose of their products responsibly, and imbed sustainability into core business strategy. Policy is needed to restrict textiles being imported into the UK if they do not meet minimum legal requirements with regards to the use of substances of concern or proper treatment of effluent waste. Standards for quality, chemical safety and sustainability need to be created, much like the legislation that prohibits the sale children’s clothing and toys that do not meet minimum safety requirements[25].

Additionally, the extended producer responsibility needs to be enforced. Where the UK government has brought in ‘The Modern Slavery Act 2015’[26], there are still over 8,500 eligible companies in the UK who have not complied three years on, almost 50% of all eligible companies in the UK[27]. Companies need to be held accountable for the environmental impact of their products at all stages of the life-cycle.

4. What industry initiatives exist to minimise the environmental impact of the fashion industry? Are there any industry standards or certifications in place to guarantee sustainable manufacturing of clothing to consumers?
    

Environmental Initiatives/Standards:

BLUEISIGN® www.bluesign.com 

CRADLE TO CRADLE www.c2ccertified.org

EU ECO LABEL www.ecolabel.eu

GLOBAL RECYCLING STANDARD www.textileexchange.org/upload/Integrity/Standards/GRS/GlobalRecyclEStandard.pdf

GLOBAL ORGANIC TEXTILE STANDARD [GOTS] www.global-standard.org

ISO 14000 www.iso.org/iso/home/standards/management-standards/iso14000.htm

MADE IN GREEN BY OEKO-TEX® www.madeingreen.com

OEKO-TEX® STANDARD 100 www.oeko-tex.com/en

STEP BY OEKO-TEX® https://step.oeko-tex.com/

SOIL ASSOCIATION CERTIFIED www.soilassociation.org

WRAP www.wrap.org.uk

ZERO DISCHARGE OF HAZARDOUS CHEMICALS https://www.roadmaptozero.com/

Social Initiatives/Standards:

FAIR WEAR FOUNDATION www.fairwear.org (social environment)

FAIRTRADE www.fairtrade.org.uk (this is more social environment)

WORLD FAIR TRADE ORGANISATION www.wfto.com (this is more social environment)

With all of these initiatives it is virtually impossible to guarantee that the audit is a true reflection of the manufacturer or farmer. The only way to ensure supply chain transparency is to constantly police and have qualified personnel regularly meeting suppliers at every level conducting interviews, checking documents, comparing invoices with stock. No audit process exists that gives this service, it is up to brands whether they wish to operate in this way.

5. How could the carbon emissions and water demand from the fashion industry be reduced?

Carbon Emissions:

The highest carbon emissions happen during the initial extraction and polymer extrusion of petrochemicals to create synthetic fibres, and from conventional agriculture of cotton and animal fibres such as silk and wool[28].

Water Footprint:

Global water consumption needs are predicted to outstrip supply by 40 percent in 2030[29]. The UK’s total water footprint from clothing in 2016 was 8 billion m3, of that 7.6 billion m3 was used to produce raw materials and 5.25 billion m3 was solely used for cotton production[30].

Increasing the utilisation of textile products and therefore reducing the demand for new virgin fibres will achieve the greatest reduction in carbon emissions and water use[31]. Also, moving away from traditional methods of virgin fibre production and reducing the amount of virgin fibres used in garment production by developing fibre to fibre recycling would have a huge impact[32].

1. Moving away from petroleum based polymer extrusion:

Bio-based polymers derived from renewable crops such as corn and sugar cane require far less energy and release up to 60% less carbon emissions, partly due to the crops creating carbon sinks[33]. This technology is relatively untapped with few companies developing textile products, such as Virent[34]. Barriers to uptake include competing for biological sources for food, price and development is needed to achieve equivalent mechanical properties compared with conventional polymers[35].

2. Moving away from conventional farming for cotton and wool:

India uses 54% of global pesticides annually, but occupies just 5% of global crop lands[36]. This farming culture of using excessive amounts of pesticides and fertilisers results in serious soil degradation, acidity, and increases the water use. Using conventional farming, it can take up to 20,000 litres to make one pair of jeans and a t-shirt[37]. Regenerative and organic farming practices helps maintain soil health and biodiversity, effectively creating carbon sinks. Global Organic Cotton Standard for example reports up to 70% less soil acidification, 92% less water consumption and 62% less energy consumption[38].

Source: WRAP Report Valuing Our Clothes: The Cost of Fashion

Source: WRAP Report Valuing Our Clothes: The Cost of Fashion

6. What typically happens to unwanted and unwearable clothing in the UK? How can this clothing be managed in a more environmentally friendly way?

Textiles are collected by local authorities, charities, civic centres, donations directly to charity shops, retailer in-store collections, door-to-door charity bag collections and ‘cash for clothes’ donations[39]. About 650,000 tonnes of clothing were collected for re-use and recycling in the UK in 2014, and of that approximately 213,700 tonnes were sold in charities[40]. Saleable textiles that don’t sell in the UK are sold on to used textiles sorters and traders and exported overseas to countries with limited collection infrastructure of their own. Around 350,000 tonnes were exported from the UK in 2016, mainly to Eastern Europe, Central Asia and Africa[41]. Unsaleable textiles can be downcycled into lower grade textiles, for example insulation, automotive felt and scrap wiping cloth etc., which accounts for about 13% of the total. There is also a small market for fibre-to-fibre recycling, but less than 1% of pre-consumer and post-consumer textiles are recycled into new clothing[42]. The rest goes to landfill or incineration; landfilling is estimated at costing the UK economy £82 million annually[43].

The export market of used clothing is facing significant challenges. Export volumes have been declining since 2014 and countries have started imposing restrictions on the imports of used textiles[44]. This in part is due to low quality textiles driving the value down, and in part due to other countries competing for market share, such as China.

Additionally, the domestic used textiles sorting and recycling industry is facing a major skills gap, reporting challenges to recruit, train and retain employees. Reasons for this include:

- Unattractive working conditions, for example low-skilled, boring, dirty work.

- Brexit

- A lack of funding for NVQs

For these reasons the majority of used textiles sorting has moved overseas resulting in jobs losses. If the UK is to become a hub for textiles re-use, remanufacture and recycling the textiles recycling and sorting industry needs support such as adequate funding for NVQs to help fill the skills gap.

Local solutions for recycling low quality used textiles needs to be identified and scaled up. A handful of companies are processing textiles from pre-consumer textile waste, other waste (plastic bottles, fishing line), and post-consumer textiles (mainly pure cotton and pure wool).  There needs to be fibre to fibre recycling solutions for low quality mixed fibres, which make up a huge portion of garments sold. Some innovators are in the incubator phase (Worn Again[45], Resyntex[46]), but significantly more factories are needed to cope with the vast quantities of used textiles in the textiles waste stream. Investment is needed into cost effective, scalable fibre to fibre textile recycling options.

Barriers include:

-          Used textiles vary in quality and fibre type - sorting these textiles is expensive/labour intensive.

-          Automated textiles sorting can’t differentiate quality, this technology is still being developed (The Fibresort[47])

-          Textiles are often made up of multiple fibre types that are difficult to break down and recycle

-          The technology is still being developed to cope with multiple fibre recycling

-          Fibre to fibre recycling reduces the quality of natural fibres such as cotton and wool

-          Recycled fibres aren’t price competitive

A small number of SMEs and premium fashion brands are starting to use more recycled fibres (Mud jeans, Gucci), but demand for recycled fibres needs to be strongly incentivised through an extended producer responsibility tax.

7. Does labelling inform consumers about how to donate or recycle clothing to minimise environmental impact, including what to do with damaged clothing?

Not normally, some brands that focus on sustainability give this type of information (Patagonia, Nudie Jeans, Mud Jeans). Other brands still don’t suggest reducing the washing temperature to 30 degrees to save energy. Mandatory labelling guidelines should be required to inform customers about the environmental impact of garments and how best to wash and dispose of them.

8. How could consumers be encouraged to buy fewer clothes, reuse clothes and think about how best to dispose of clothes when they are no longer wanted?

-          Targeted behaviour change campaigns

-          Social Media

-          Traditional Media

-          Education – from nursery through to post-graduate study

-          Community Engagement

-          Compulsory eco-labelling of garments i.e. carbon footprint/water footprint/stating if it’s conventional cotton etc.

-          Incentives and disincentives in shops i.e. charging extra for conventional cotton via a tax system, giving a discount for organic cotton, and making this absolutely clear on the labelling and at point of sale using the same principle as the 5p charge for single use plastics bags.

-          Influencer and celebrity endorsement

-          Pathfinders so that consumers can type in a barcode on their care label and see every single stage of the production process: country, people, process etc. DM Drogerie in Germany has this system: http://pfadfinder.dm.de/pfad/2X23RS18BKA6

-          Invest in and scale up the clothing rental market

September 2018