Jean-Pierre Schweitzer and Emily Macintosh take a look at the Product Environmental Footprint for apparel and footwear initiative.

Think about the last time you went food shopping, or bought a new appliance. Chances are you saw some organic certifications or nutri-labels which may have determined whether a product ended up in your basket or not. Maybe you bought a new washing machine or fridge and were influenced by the A-G energy label. Now, with an EU initiative looking at how to measure fashion products’ environmental footprint, clothes could be about to receive a similar treatment.

The basis of the initiative is the Product Environmental Footprint (PEF) methodology, a type of Life Cycle Assessment (LCA) which covers 16 environmental impacts, such as greenhouse gas emissions, energy and water use. The general methodology has been under development since 2011, and since 2019 key players from the fashion industry including H&M, ZARA and Nike have been applying this method to textiles. The European Environmental Bureau (EEB) is participating in the project as an observer.

The idea behind the PEF process is to identify a more complete picture of the environmental impact across a product’s whole life cycle. The draft method covers sub-categories of textile products, from t-shirts to swimwear and boots. Importantly, it will be possible to compare the results of products within the same sub-category, which could be the basis to rank performance or create a graded label.

Ranking fashion – to what end?

The PEF process has considered labelling as a possible application from the onset, but it is far from clear as to how the current process will be translated – if at all – into an eventual mandatory EU-wide labelling scheme that we see on fashion products, similar to the ones we see on white goods.

While the French government has announced its plans for a mandatory sustainability label for textiles, which may be based on the results of the PEF project, the European Commission has not revealed yet how it will use the PEF rules for apparel and footwear once they are finalised. 

It is also not clear how the new PEF rules will interact with existing EU and national voluntary schemes such as the EU Ecolabel.

It’s all about the details

The uncertainty over how it will be used aside, with so many industry players involved, the PEF results will clearly be a key part of brands’ sustainability efforts, so it’s important to take a closer look at the methodology behind it.

There are ongoing debates about the technicalities of the methodology, i.e. what should and shouldn’t be measured. Some important factors are completely out of the project’s scope, including biodiversity loss, microfibre release – a major driver of marine microplastics – as well as human rights and animal welfare aspects. This raises doubts amongst campaigners about how appropriate the PEF alone can be for a sustainability label.

Other factors which determine the environmental footprint of an item of clothing such as how repairable or durable it is, the size of the item, or whether the manufacturer produces and potentially destroys unsold stock are, however, being discussed.

Concerns about how the method will rank different types of clothing or materials have raised alarm amongst some industries. The Make the Label Count campaign, recently launched by a coalition of international fibre groups, NGOs and brands, argues that the scope of the method means that natural fibres (such as wool and cotton) will be penalised relative to synthetic or fossil-based fibres, as microplastic release and the full impact of oil and gas production are seen not to be considered. Changing Markets Foundation highlights that synthetic fibres are the backbone of the overproduction associated with fast fashion. Use of synthetic fibres in fashion has more than doubled since 2000, and they represent over two thirds of total global fibre production.

At the same time, Make the Label Count argues that more environmentally-favourable attributes of natural fibres such as requiring less frequent washing are not measured. Natural fibre producers also have concerns that the method favours synthetic fibres by only using a garment’s physical strength to determine its durability, ignoring emotional durability (typically based on consumer data). In other words, just because a garment lasts a long time does not automatically mean you will keep it in your wardrobe.

The PEF project for textiles is anticipated to run well into 2022. A recent consultation allowed for public scrutiny of the draft methodology for the first time. Now the method will be tested on a number of real products by the brands. 

Less labels, more regulation

The EEB will continue to participate in the project, though given the current scope of the PEF method we remain hesitant about its suitability for developing a consumer label. To be meaningful, a labelling scheme will have to be complimented with additional information. The Commission’s work on addressing unsubstantiated green claims will be welcome but it should not result in ‘blind spots’ of environmental and social impacts which can be exploited by one of the world’s most polluting sectors. 

Ultimately, calculating and then communicating about a textile product’s sustainability credentials will not stop the overproduction that continues to push us to the brink of climate chaos and biodiversity collapse, while exploiting millions of workers worldwide.

While environmental labelling of products based on robust methodology can play a key role in making it easier for us all to make more sustainable shopping choices, the reality is that labelling must only ever play a complementary role to strict rules and standards on product design and production practices. 

The burden for change should not be on consumers. Curbing overconsumption must mean reducing the amount of textile products put on the market each year and putting a stop to environmentally harmful and exploitative business practices. This will involve setting clear rules on product design to ban the worst products from the market, new laws on corporate accountability, banning the destruction of unsold goods, setting EU-wide resource use reduction targets, and using fiscal and economic measures so that the fast fashion business model is no longer viable.

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