The European Commission’s proposed greenwashing ban could have its work cut out for it, a new report claims.
Certification labels and multi-stakeholder schemes, meant to guide the fashion industry on a more sustainable path in the absence of robust environmental legislation, have only served to provide brands and retailers with a veneer of accountability while pushing their own damaging business agendas, the Changing Markets Foundation said.
“While fashion brands double down on production and environmental destruction, they’re using sustainability certification schemes and voluntary initiatives as a smokescreen,” said George Harding-Rolls, campaign manager for the corporate sustainability watchdog. “These schemes are unambitious, unaccountable, compromised talking shops that result in an industry-wide decoy for unsustainable practices, enabling sophisticated greenwashing on a vast scale.”
The Changing Markets Foundation scrutinized 10 platforms frequently used by fashion firms to assess their sustainability efforts: EU Ecolabel, Bluesign, the Cradle to Cradle Products Innovation Institute, the Ellen MacArthur Foundation, Oeko-Tex, Textile Exchange, the Microfibre Consortium, the Sustainable Apparel Institute (SAC), Waste & Resources Action Programme (WRAP) and the ZDHC Foundation.
After looking at their level of ambition, scope for continuous improvement, independence, transparency and track record of performance, the organization determined that no scheme is “fit for purpose.” Most of the programs, the organization said, fail to set strict requirements and timelines for their members to “progressively raise their ambition,” but instead provide different modules with different requirements for accommodating companies with weaker ambitions.
Many schemes, the report said, lack comprehensiveness by focusing on only a single material, product or “seemingly arbitrary” selection of a product’s life-cycle stages, requiring brands and retailers to use several labels and initiatives to cover the environmental impacts of their entire supply chain. Picking and choosing this “patchwork” of certifications and programs can shape a “vision of sustainability” that avoids difficult conversations about fast fashion, overproduction or reliance on fossil fuels and distracts consumers from the true scale of the industry’s footprint, it added.
Other areas of concern include their lack of autonomy and accountability, the Changing Markets Foundation said. The majority of the initiatives, the report said, are susceptible to “high levels of influence” through the companies that funded the schemes or were otherwise involved in their governance. Large schemes such as the SAC and its Higg Index, for example, “sit in a web of influence” with other initiatives, brands and retailers, creating an “interwoven network” that “stifles debate and alternative models” while compromising accountability, since there is little incentive for them to enforce compliance from paying members. What amounts to “reputational greenwashing” generates a win-win for both the schemes and the companies that embrace them, it said.
The Changing Markets Foundation also called out the dearth of transparency in most of the programs, likening them to, at worst, “black boxes” with “no external scrutiny” despite informing “major decisions about fiber and material use.” The report said that some schemes, such as Cradle to Cradle and the Higg Index, confuse voluble communication with transparency, resulting in pages “filled with empty words” that obscure their lack of accessibility to data or necessary level of detail. WRAP and ZDHC, it added, employ aggregated reporting that makes it impossible to analyze a single company’s performance.
By failing in their performance and purpose, these initiatives give brands and retailers a “license to greenwash,” the Changing Markets Foundation said. Research by the organization found that one in three (34 percent) of British consumers “frequently” or “always” opt to buy items with green labels or certifications. One in three also said that they view certification schemes or third-party initiatives as trusted sources of information on brands’ green credentials.
The report denounced the fashion industry’s “decades-long experiment in self-regulation” as having “run its course,” and that as long as progress remains voluntary, sustainability will “remain optional.” By acting as “sustainability placebos,” brands, customers and policymakers will be misled into thinking action is being taken and that more systemic measures such as regulation are unnecessary, it added.
“We don’t need any more voluntary schemes,” Harding-Rolls said. “Certification and initiatives such as those in the report act as a placebo, creating a false promise that the industry will address sustainability voluntarily. We urgently need comprehensive legislation to change the course of the fashion industry onto a greener path.”
Critiquing the criticism
The SAC said there is little doubt that the fashion sector must transform to better serve the needs of people and the planet, but that it also believes in the “power of collaboration and collective action.” Its members, it noted, are able to access “trusted, credible and scientifically rigorous tools,” which evolve to align with the latest science and data, to measure the impact of their product production.
“Empowering change is key—we live in a climate emergency and deep change needs to happen, and fast,” a SAC spokesperson said. “If organizations are promoting their sustainability credentials to customers and stakeholders, it is vital [that] the action sitting behind these stands up to scrutiny. We work in active partnership with many others in the sector to advocate for greater transparency and substantiation of claims.”
Bluesign said it welcomed the criticism because it is these “commentaries that push the industry as a whole to improve operations, reduce its impact and encourage collaboration.” It noted that one organization alone cannot make the systemic change needed. “At Bluesign, we work with our system partners to develop individual roadmaps to continuously improve environmental performance, working conditions, and resource consumption to create the highest level of safety for people, [the] planet and consumers,” a spokesperson said.
A representative from the Ellen MacArthur Foundation said that voluntary agreements are an “important starting point,” but it knows that they are not enough to address fashion’s waste and pollution, which is why it also works with governments and policymakers, most recently in helping secure a mandate for a United Nations treaty on plastic pollution. Sophie Mather, executive director of The Microfibre Consortium, said that the organization is “disappointed” at the report’s lack of recognition of its “significant” progress. “Not only does it misrepresent what the consortium actually does, but its references to the organization are out of date and simply inaccurate,” she added.
Textile Exchange said it sees its standards as “one instrument in a holistic toolkit of solutions” that together can drive positive change and that it’s committed to strengthening them, while Oeko-Tex said that the “path toward sustainability is a continuous and ever-evolving process” and that it takes the feedback in the report “seriously” and will “implement improvements in future developments.” A spokesperson for WRAP defended its use of business voluntary agreements as necessary in the absence of legislation “so that systems change can be delivered as quickly as possible,” though it also shared the report’s urgency to “accelerate and scale-up sustainability solutions.”
Cradle to Cradle CEO Christina Raab called the Changing Market Foundation’s characterization of its approach and impact “inaccurate” and based on “outdated and incomplete” secondhand information. “The institute continuously welcomes concrete suggestions for improvement and is fully committed to moving the industry to leadership at scale in [the] most accountable ways,” she said, adding that Cradle to Cradle Certified is built on “demanding ascending” achievement levels and a two-year renewal cycle that requires measurable improvements by companies.
Frank Michel, executive director of the ZDHC, said that the report “makes many good points,” but wondered if it was sending out the “right signals to the industry,” since calling engagement in multi-stakeholder initiatives greenwashing could provide an excuse for not taking action. “Waiting for legislation is not a good alternative from my point of view as it will always be limited to the borders of nations and their jurisdictions,” he said. “Further, it often comes with a big question mark as to how changes will be implemented and to whom they might apply. We believe that to create change, we need to start somewhere.”
A broader definition of sustainability
The Changing Markets Foundation published its report amid renewed urging for a longer, harder look at the “flawed definition of sustainability, unscientific methods and selective implementation” of tools used by brands and retailers to assess and track their sustainability performance, which tends to omit their impact on the “multidimensionally poor,” such as garment workers and farmers.
A follow-up to an earlier study on the fashion industry’s greenwashing problem, “The Great Greenwashing Machine Part 2” argues that there is no single brand, retailer or initiative that is measuring sustainability correctly. Nor do they consider the repercussion of their assertions on the livelihoods of millions of people, most of them in the global South, which is a “direct violation of commitments to the UN SDGs and has potentially profound adverse consequences for both [the] planet and people,” said Veronica Bates Kassatly, an independent analyst and co-author of the report, which was published on the Eco-Age website.
Dorothée Baumann-Pauly, director of the Geneva Center for Business and Human Rights and co-author report, said there is growing skepticism over “self-proclaimed sustainability” in the fashion industry for good reason.
“It is in the interest of [the] industry to develop science-based standards and metrics that are aligned with this original and comprehensive understanding of sustainability which explicitly includes human rights,” she added. “Clear standards can prevent greenwashing and allow companies to showcase that they are making progress towards sustainability. They can also serve as a guide through the dense jungle of sustainable fashion initiatives.”
Baumann-Pauly previously authored a paper arguing that multi-stakeholder initiatives can play a positive role, at least in promoting labor rights, by complementing mandatory due-diligence legislation where it exists and pushing for greater oversight where it doesn’t. The critical issue, however, is that these organizations need to be truly multi-stakeholder, meaning that businesses, trade unions and non-governmental organizations should be sitting at the same table. Many organizations don’t qualify but it’ll also be a mistake to “throw the baby out with the bathwater,” she said.
“There’s no silver bullet to ensuring that companies respect human rights and so we need multiple and overlapping mechanisms as well,” Baumann-Pauly said. “Let’s look at the models that have worked; let’s add some rigor to this debate and also define some criteria of what makes a meaningful MSI. I think that the few that meet those criteria should really get a boost now; they should be strengthened because we need them more than ever.”
A 2020 study of multi-stakeholder initiatives also concluded that centering rights holders is essential to their success. Until then, they will remain ineffective tools for holding corporations accountable for abuses, protecting rights holders against human-rights violations or providing survivors and victims with access to remedy.
“Rights holders hold critical information for ensuring that standard-setting and implementation processes respond to their lived experiences,” it said. ”For example, what rights issues and remedies are of greatest importance to be addressed? What sort of whistleblower protections or oversight systems are needed for people to feel safe reporting alleged abuse? Are interventions actually working? Top-down approaches risk failing to harness the knowledge or trust of those whose lives or rights are at stake.”