PLG: Snapshot of our Services
- Introduction of an Extended Producer Responsibility (EPR) Scheme to encourage retailer participation in supporting reuse and recycling of textiles in the UK.
- Government Funding/Tax Incentives for companies such as PLG to increase capacity and recycling volumes/investment in recycling technology.
- Stricter Labelling Requirements to allow for better understanding of material compositions and recycling possibilities.
- Investment into the circular economy – making it easier to convert old material into new garments.
An EPR scheme is a tool that is used to ensure producers and retailers of goods are made responsible for their products once they reach their end of life. It can be used to encourage retailer participation in supporting reuse and recycling of textiles in the UK. It briefly consists of:
1) Encouraging sustainable production and consumption of products within an industry
2) Aligning incentives to allow intelligent design of products to make the easy to recycle at end-of-life
3) To reduce landfill and encourage recycling of products, and to help create a revenue framework to help investment into recycling
Further details on how EPR schemes run and how they can be implemented most effectively can be found in this a paper commissioned by EXPRA (Extended Producer Responsibility Alliance) in March 2016: http://www.expra.eu/uploads/downloads/EXPRA%20EPR%20Paper_March_2016.pdf
Illustrative: What could an EPR levy on goods produced look like in the UK fashion industry?
Levy on goods produced:
Clothing created for UK sale per year | Tonnes | Kgs | Pieces | 1p per garment | 5p per garment |
Amount of clothing sold | 1130000 | 1130000000 | 3390000000 | £33,900,000.00 | £169,500,000.00 |
amount made but not retailed 5%*[4][5] | 56500 | 56500000 | 169500000 | £1,695,000.00 | £8,475,000.00 |
| | | Total Revenue | £35,595,000.00 | £177,975,000.00 |
* Doesn’t include shoes
Figures including shoe sales:
Clothing created for UK sale per year | Tonnes | Kgs | Pieces/pairs | 1p per garment | 5p per garment |
amount of clothing sold | 1130000 | 1130000000 | 3390000000 | £33,900,000.00 | £169,500,000.00 |
amount made but not retailed 5% | 56500 | 56500000 | 169500000 | £1,695,000.00 | £8,475,000.00 |
shoes sold in 2016[6] | | | 3400000000 | £34,000,000.00 | £170,000,000.00 |
| | | Total Revenue | £69,595,000.00 | £347,975,000.00 |
Landfill style tax based on unsold clothing only
Clothing created for UK sale per year | Tonnes | Kgs | Pieces | 20p per garment unsold only |
amount of clothing sold* | 1130000 | 1130000000 | 3390000000 | £0.00 |
amount made but not retailed 5%* | 56500 | 56500000 | 169500000 | £33,900,000.00 |
| | | Total Revenue | £33,900,000.00 |
Illustrative: EPR as a model used for the clothing industry in other countries
In France, the member-run EPR scheme, EcoTLC (TLC relating to French for Clothing, Linen and Footwear) has made it a legal requirement for all retailers and manufacturers that sell or make clothing for sale in France to be part of the EcoTLC scheme (or run their own producer compliance scheme). As part of this, levy has been placed on all goods made for sale in France (regardless of whether they are sold or not).
There are some omissions for garment such as:
- Full leather clothing items;
- Non-clothing items (doll, toy, pets products, etc.);
- Medical and orthopaedic items;
- Technical sport items (ice skating, skiing boots, etc.);
- Household linen like blankets, pillows, etc.; [7]
The contributions are used by EcoTLC to support in the following ways:
- R&D Projects focussing on recycling solutions
- Communications and campaigns to encourage sustainable consumer behaviours and consumers’ attitudes towards recycling
- Support for all sorting organisations that support/respect EcoTLC requirements
How are contributions calculated?
Every year, companies have to declare the volume of items put on the market on the previous year (ex: in 2019, companies have to declare the volume put on the market in 2018). This declaration will be used as a basis for the calculation of the contribution but the cost may vary depending on certain factors (size of the company, eco-design etc). There are 3 different ways to calculate the amount of the contribution:
- The contribution calculated to a real cost:
The contribution is calculated annually on the basis of the declaration of the previous year's volume put on the market and on the size of each item. There are 4 sizes for clothing and household linen (TPP, PP, MP, GP) and 2 sizes for footwear (PP, MP):
The cost for each item put on the market according its size applies as follows:
Clothing | Charge € (ex VAT) |
Very small items (TPP) | 0.00156 |
Small items (PP) | 0.00626 |
Average items (MP) | 0.00938 |
Large items (GP | 0.06259 |
Linen | Charge € (ex VAT) |
Very small items (TPP) | 0.00178 |
Small items (PP) | 0.00713 |
Average items (MP) | 0.01068 |
Large items (GP | 0.07128 |
Footwear | Charge € (ex VAT) |
Small items (PP) | 0.00739 |
Average items (MP) | 0.01107 |
- The flat-rate contribution:
Companies that realise a turnover (excluding taxes) of less than €750,000 or put on the market less than 5.000 items per year are eligible for the flat-rate contribution. The flat-rate contribution, considered as the minimum contribution, is of €45 (excl. VAT) per year.
- The variations in the scale of the contribution:
By eco-designing, members can benefit from a bonus on their contribution. EcoTLC has implemented modulation of the contribution calculation to encourage the creation of more sustainable products and the use of recycled fibres from pre-consumer textiles or footwear or production off-cuts.
To discover more about the modulation of eco-contributions, read the part below.
[8]
How to benefit from a modulation of the contribution calculation:
To incentivise companies that use recycled fibres from pre-consumer clothing, linen or shoes, EcoTLC has implemented a variation in the scale of the contribution calculation. Rates are announced each year, as per the necessity of EcoTLC to cover for the need of support, it can be found on EcoTLC news feed.[9]
1st modulation of the contribution:
Aim: encourage design of longer-lasting products
Bonus: 75% off the estimated contribution to a real cost per item.
This modulation is divided into 2 subcategories:
Clothing durability
That applies on t-shirts, jeans, pullover and Linen:
Required eligibility criteria: resistance, dimensional stability, dyeing fastness (learn more here)
Footwear durability
Required eligibility criteria: sole resistance to abrasion and sole resistance to pullout from the upper of the shoe (learn more here).
2nd modulation of the contribution:
Aim: encourage the use of recycled fibres from pre-consumer Clothes, Linen and Footwear (CLF).
Bonus: 50% off the estimated contribution to a real cost per item.
Required eligibility criteria: the item must contain at least 15% of recycled fibres from pre-consumer CLF.
3rd modulation of the contribution:
Aim: encourage the use of recycled fibres or materials from arisings from CLF production.
Bonus: 25% off the estimated contribution to a real cost per item.
Required eligibility criteria: the item must contain at least 30% or more of fibres from CLF production's cut-offs.
How would the UK approach offering Tax or other investment incentives to UK businesses that recycle?
The United States as a model for recycling incentives:
Some of the recycling incentives offered to businesses for recycling and saving energy include:
IRS credits: The IRS offers both depreciation credits for recycling, and energy credits for using products such as solar panels and fuel cells. Items that are included on the depreciation credit list include qualified reuse and recycling property acquired after 2008, and biomass and biofuel-related property – a full list can be found in the IRS’s Publication 553.
The Department of Energy: The Department of Energy offers grants to businesses for projects that meet certain energy-saving requirements, or those that want to invent new products and methods of saving energy. Additionally, the DEP offers grants to states for waste disposal programs; many states then allocate those funds to businesses that meet certain waste management requirements.
State government programs: Many states, including Maryland, Texas, Nevada, Iowa, and North Carolina, offer a variety of tax exemptions, tax credits, and other financial incentives to businesses for their recycling and waste management policies. These programs range from savings on income tax and property tax to rebate programs for buying recycling equipment. In some states, equipment rebates are fixed dollar amounts, while others are a percentage of the equipment in question.[10]
How would labelling requirements help affect positive change within the UK for disposing of fashion items responsibly?
It is currently a legal requirement to highlight the constituency (via % of materials used) of any garment made for sale in the UK. What is lacking, however, is any information on how you should treat the garment once you are finished using it, such as re-use information like donating the item to a clothing bank or charity shop. There is also no information on the end of life pathway for any garment – such as how easy it is for the garment to be recycled, or whether it can be recycled at all.
An example of recycling information being included on packaging can be seen on food packaging – that highlights how ‘recyclable’ an item of packaging is or can be. Some examples here https://www.recyclenow.com/recycling-knowledge/packaging-symbols-explained):[11]
Whilst this is interesting information – it is not understood how this labelling affects consumer behaviour, it also does not guarantee any recycling has been done to these items once they have entered the waste stream. Part of the issue with clothing garments is that the potential fate of each garment is so diverse, and the possible outcomes of re-use or recycling so unidentifiable – that it renders the information given speculative at best and potentially misleading.
How do we incentivise designers and producers of garments to create products that are easy to recycle? How do we create ‘closed loop’ systems that use fibres from old garments to create new ones, therefore reducing the impact on the environment? How do we make this process less costly and encourage businesses to adopt these methods?
‘Closed Loop’ recycling:
The current product roadmap could be described as linear:
A closed loop solution would allow the fibres create from down-cycling (fibres that currently get used to make blankets/create ‘shoddy’ that is used for car seat manufacturing/padding) to be used in the production phase again, reducing the need for additional raw materials like cotton.
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This way, Recycling and design/production work much more closely together, as opposed to the current model where designers and recyclers are at opposite ends of the process, and therefore cannot feedback information into each other’s process.
Current recycling practices & the need for investment:
Much of the material created post-retail and finds its way either to landfill or energy from waste (EFW), usually in the form of a type of incineration. Current re-use or re-purposing is as follows:
Re-use - (the garment gets re-used again as a clothing garment)
Down-cycled – the garment gets chopped up and made into wiper cloths
Re-cycled – material goes through physical tearing machine to produce shoddy or flock, which then gets re-purposed.
The composition of modern garments (particularly fast fashion items and the increased use of plastics in garment production due to the physical properties of compounds like polyester; i.e. long lasting, durable and relatively easy and cheap to produce) means that separating fibres to re-use in the manufacturing process is costly and extremely difficult, and involves a chemical separation process using techniques such as alkaline hydrolysis and depolymerisation of polyester[12]. Before this separation occurs, analysis of the textile constituency must occur to ascertain the specific fibre blend using techniques such as Infrared (IR) and Ramen spectroscopy and solid state nuclear resonance (solid state NMR) spectroscopy.[13]
This type of process is costly, rare in the garment recycling industry, and requires significant investment to make the process scalable and economically viable as an alternative to physical recycling – something that an EPR levy could be utilised to push research and development.
To conclude, it is clear to see that a lot can be done to move towards a more sustainable 'closed loop' fashion industry. But in order to do so, the government must intervene and incentivise both businesses and consumers to change behaviours and act responsibly. At the same time, investments in education and information-sharing must be made, as well as in R&D to find alternative, easily recyclable textile materials, as well as more sustainable methods of manufacturing. Retailers and consumers alike must be made to understand that there are better alternatives to sending clothes to landfill, such as the services PLG provides. More information regarding these alternative solutions can be found on www.parkerlanegroup.com
January 2019
The Guardian 2016 Reports that over 300,000 tonnes of clothing were sent to landfill in 2016[1], contributing to around the 6 million tonnes thrown away throughout Europe[2]. 25%[3] of all chemicals produced worldwide are used by the textile sector. 