The Sustainable Apparel Coalition (SAC) announced Monday that it will be commissioning, “with urgency,” an independent third-party expert review of the data and methodology behind the Higg Materials Sustainability Index (MSI), a module of the popular Higg Index suite of tools that scores the environmental impacts of materials. A review was last conducted in 2016, it said.
The trade group, which counts on its roster more than 250 brands, retailers and manufacturers, including Adidas, Gap Inc, H&M Group, Patagonia, Norrøna and Walmart, will also be “pausing” its Transparency Program, a consumer-facing platform it introduced last year to provide at-a-glance information about the impact of apparel and footwear items across factors such as water, greenhouse-gas emissions and fossil fuels.
Both moves come on the heels of the Norwegian Consumer Authority’s (NCA) decision that Norrøna is “breaking the law” when it markets its outdoor wear as environmentally friendly based on MSI data. The watchdog authority also warned H&M of doing the same, saying that using Higg MSI data in sustainability claims will be considered “misleading” and a breach of greenwashing laws.
Both Norrøna and H&M were among a handful of brands that piloted the Higg Index Transparency Program with the goal of providing shoppers with “unprecedented visibility” into a product’s “real” impact, according to the organization.
“Transparency itself is not the end game, but it’s a critical step for transforming the industry and establishing a new era of accountability,” Amina Razvi, executive director of the SAC, which spun off its Higg platform in 2019 and is officially positioned as a strategic partner, said at the time. “By leveraging the Higg Index—starting first with environmental data and then expanding to include social impacts—we can help both businesses and consumers make better decisions, and drive collective action at scale.”
The SAC’s actions aside, the implications of the ruling are bound to reverberate beyond Norway as regulators apply increasing scrutiny to brands’ green declarations, which have thus far escaped formal policing. The attention on the Higg Index is especially meaningful because of the size and stature of the instruments, which are widely employed and frequently referenced.
Most of all, the NCA’s conclusions have raised vital questions that fashion must come to grips with: is it better to use partial data or no data at all? To what extent should different fibers be compared? The answers will determine the trajectory of future sustainability efforts.
‘Comfort zone of soft information’
When Norrøna originally employed the transparency platform to tout the improved sustainability profile of some of its products, it included a visual scorecard indicating that its organic cotton T-shirts produced 14 percent fewer emissions, used 9 percent less fossil fuels, required 88 percent less water and created 47 percent less water pollution than their conventional counterparts. This, the NCA said, misled consumers because the information supplied referred to the average environmental attributes of the cotton fiber, not those of the specific finished items, meaning there was insufficient proof that the claimed impact reductions were “true and correct.”
“The main problem with using global average number is that they fail to capture local variations in resource usage and environmental impact,” the authority wrote in its June 16 ruling. “There are significant differences in the way cotton is grown and how much water farmers use, as well as how and if they use these inputs efficiently. For example, climate, rainfall and irrigation technology vary greatly from one farm, country and/or region to another.”
The NCA also slated Higg for using partially outdated data that it said was never meant for comparative purposes, as well as for failing to take into account factors such as emissions from manure in their calculations of organic cultivation. When such information is missing, it said, gaps emerge between marketing claims and reality.
“If the Higg MSI included emissions from manure in their GHG emission calculations, the outcome could thus change drastically and the difference between organic and conventional cotton could be smaller or potentially disappear,” it said, using an acronym for greenhouse gases. The agency said that Norrøna must change or remove all marketing referencing the Higg MSI from its product pages by Aug. 14.
Norrøna CEO Jørgen Jørgensen said the company chose the Higg Index because it believes its customers have the right to know as much as possible about the environmental impacts of their purchases so they can make more informed choices.
“To our knowledge, the SAC developed [the] Higg index to help measure the overall social and environmental impact of our industry based on the best available information,” he told Sourcing Journal. “We have not found any perfect tools and recognize we are [at] the beginning of a long journey that requires consent improvement. Norrøna is interested in using and communicating the best possible information and invites anyone with a better solution to help us.”
As a small company, Norrøna can’t afford to do all the assessments itself, Jørgensen said, adding that it’s important that SMEs are not left behind when it comes to analyzing and communicating environmental impacts.
“That said, we are obliged and desire to stay within all applicable laws and we in no respect want to misguide our customers and consumers in their important choice when, or if, they choose to purchase one of our products,” he said. “We will continue to engage with both the NCA and the SAC to see what is required to create the right balance between simplifying verified information and ensuring the customer is provided with information that cannot be misunderstood or encourage the wrong buying decisions. It is because we are pushing outside the comfort zone of soft information that this case is so important.”
‘False sense of causality’
For Tone Skårdal Tobiasson, a Norwegian journalist and author who has written about the flaws in the application of life-cycle assessments, or LCAs, the NCA’s ruling is a validation of what she has drummed about for years: that companies cannot say one product has a better environmental footprint than another if global averages are underpinning the comparison.
“This also gives a false sense of causality,” said Tobiasson, who had previously emailed Norrøna about its organic cotton claims before bringing her concerns to the NCA’s attention. “This became blatantly obvious in this specific case, as an organic T-shirt isn’t 88 percent less thirsty than a conventional tee. The data just wasn’t there, and SAC couldn’t document the claims.”
Jørgensen disagrees with the NCA’s stance that using generalized data to provide information on a specific product is unacceptable, noting that LCAs use global data to “provide a reference, not specific information taken from a specific farm in a specific season.” He conceded, however, that the Higg Index and other similar tools are in their “early days” and must evolve to include other impacts involving biodiversity, durability, end of use and plastic pollution.
“We use these in our material and product assessments today and would like a consistent and science-based method for measurement to include them in consumer-facing information as well. It is this transparency toward the consumer that we believe will help eliminate greenwashing, not cause it,” he said. “Price alone does not provide enough information to make an informed decision.”
To help drive improvement in measurements, Norrøna is in discussions with sustainability nonprofit Textile Exchange to see how it can best support its efforts with bolstering data accuracy and robustness around material feedstocks.
“There is no more time for inaction so we hope the entire community will stand with us in supporting data improvement that meets the demands of all stakeholders,” Jørgensen said.
H&M: MSI a ‘starting point’
The SAC said in its statement on Monday that it takes the NCA’s notification “extremely seriously” and is working with the NCA and other consumer agencies and regulators to “better understand how to substantiate product level claims with trusted and credible data.” While the group remains committed to the use of standardized data to inform decision-making among its stakeholders, it added, it also recognizes the “additional challenges” that come from translating LCA data to consumer-facing information.
“We will be working with our program partners directly to determine how this will work operationally and hope to reactivate the program upon alignment with the NCA and other regulatory bodies,” the SAC said. “It is critical we seek to understand how to improve this work and act urgently and decisively to ensure the changes that are needed both in the industry and at [the] consumer level are accelerated, and not delayed by the lack of harmonized legislation and clear guidance from regulators.”
In a previous statement published on the Higg website, CEO Jason Kibbey said that the Higg Index was built with the premise that transparent data is essential for accelerating change and urged regulators to quickly agree on a unified approach to data-backed consumer product claims.
“While we are excited to see a growing consensus around the need for more publicly available data…the ongoing debate risks slowing the ability of consumers to use sustainability information in their purchasing decisions,” he said. “Higg is a technology platform that enables consumer goods companies to measure, manage, and share their environmental and social impact. We provide science-backed data to manufacturers, retailers, and other industry stakeholders to inform their sustainability decisions–and we incorporate new methodologies and datasets as alternatives become available.”
H&M Group, for its part, said that it isn’t deploying the Higg Transparency Program in Norway, though it believes in the Higg Index’s value in providing standardized and verified third-party information on sustainability performance.
“We believe that the MSI, which is the method behind the Higg transparency layer, is the most developed industry-wide method available at scale today,” a spokesperson told Sourcing Journal. “We see this as a starting point for the industry, not the end destination. We also would like to see primary data being used and we are encouraging our suppliers to gather and share their primary data that is necessary to fill the gaps. But the industry is not there yet. In order to create progress, the industry needs to start taking collective action now.”
While the NCA’s conclusions are only legally valid in Norway, the ruling ‘paves the way” for “more of us” to demand that brands and legislators stop using “unrepresentative, outdated and misleading” numbers to make sustainability claims, said Veronica Bates Kassatly, a London-based sustainability claims analyst and a leading detractor of the Higg MSI.
“Climate change with climate justice requires a net reduction in apparel consumption by the global North,” she told Sourcing Journal. “We must have legislation that can demonstrate that it will achieve this, not just some ‘measurement’ based on meaningless values that reflect no reality.”
Bates Kassatly is at the frontlines of what has become a contentious battle for the soul of the sustainable fashion industry, with much of the conversation centered around the question of what makes one material more sustainable than another and who gets to make that distinction.
Her criticisms, together with those from trade groups representing natural fibers such as wool and silk, helped push the SAC to “retire” the Higg MSI’s aggregated single score for materials in 2020, though she told Sourcing Journal at the time that because the individual impact area scores were still “unsubstantiated and misleading,” the move served only to make the SAC’s “bias in favor of plastic fibers less apparent.”
The problem, as many of the Higg MSI’s challengers have said, is that most of the information it uses is highly localized to certain regions or climates and therefore not meant for extrapolation. The data, they say, also tends to be cradle to gate, meaning it doesn’t consider the use and end-of-life phases, eliding issues such as microplastics, which could tip the scales in a different direction. Those that promote the tool and others like it, on the other hand, question how granular the information needs to go. Is representative data good enough, they ask, to give consumers an indication of a product’s impact?
‘Paralyzing the industry’
The debate is an urgent one, particularly as the European Union gets closer to regulating green claims through a standardized system of measurement known as the Product Environmental Footprint (PEF). In New York, a bill that seeks to hold the biggest names in fashion accountable for their impacts on people and the planet is also brewing.
Both defenders of Higg and its opponents have clashed over what they say are fundamental misrepresentations of the other side’s position. The conversation recently came to a head with the publication of articles in The Intercept and The New York Times, both of which cast doubt on whether Higg—and by extension, the SAC—is fit for purpose.
Natural fiber producers say that the Higg MSI’s methodology frames synthetic materials made from fossil fuels as better-for-the-planet options, which the SAC has denied. Following the recent Times article, the Natural Fibers Alliance (NFA) called for a “suspension” of the tool, arguing that natural fiber-derived products should be the norm, not the exception.
“It’s simple, natural biodegradable fibers including leather, wool, fur, silk, etc., are more sustainable and better for our planet than plastic clothing,” Mike Brown, head of sustainability and public affairs for the NFA, said in a statement. “The culture of fast fashion is as much consumer-driven as it is a direct result of corporate greenwashing. The only way to lower environmental costs and impact is to buy clothing that lasts, repurpose older pieces and support a culture of slow fashion based on high-quality, long-lasting materials.”
The SAC has taken issue with this narrative, which the Times threw into relief when it said that Higg rates polyester as one of the world’s most sustainable fabrics. The Intercept, too, accused the SAC of using “dubious data” to promote polyester because its fast-fashion members have a stake in proliferating the use of cheap, petrochemical-derived synthetics.
“Stating that the Higg MSI favors synthetic materials over natural ones is incorrect. It does not favor synthetic over natural fibers, and it was not designed to compare the two,” Razvi wrote on LinkedIn following the Times’ story. “The purpose of the MSI is to show designers and developers where environmental hotspots are in the production of a material, by breaking down impact categories such as greenhouse gas emissions.”
Product designers and LCA experts, she said, use the datasets to inform decisions about how they can improve the impact of a material they’re using for a product—for instance, by comparing the impact of different spinning, knitting, dyeing and finishing processes—not as a “generalized measure” of a material’s sustainability.
“To suggest that LCA tools should not be used at all risks paralyzing the industry and hindering progress at a time when action must be accelerated,” she said. “This would result in brands, manufacturers and consumers having less access to robust and credible data to inform their decisions, and instead, promote disparate and potentially less credible data sets.”
Indeed it is data—how rigorous it is and how it is wielded—that lies at the crux of the dispute. SAC’s communication guidelines for brands specifically prohibit them from making comparisons across material types, but there’s nothing stopping “everybody” from doing it anyway, said Bates Kassatly, who until recently sold some silk products through her slow-fashion brand, Commun des Mortels. Though the company is in the process of being wound up, it was Bates Kassatly’s entreé into fashion entrepreneurship that prompted her to take a closer look at LCAs.
“LCAs are complicated but there is a very simple rule: You cannot compare LCAs unless they have been produced using identical boundaries and methodologies,” she said. “The SAC was created by some of the world’s richest. If the intention of the Higg MSI was indeed to provide robust, credible data, they would have commissioned a suite of such LCAs from the get-go. They certainly had the funds to do so. So why didn’t they?”
‘Planetary cost of inaction’
In the decade-plus that Kibbey has worked in fashion, first as a Patagonia intern, later as the CEO of Pact Apparel and now as the CEO of Higg, one fact has struck him: the data is imperfect and will never be perfect.
“Fashion companies need to reduce the impact of their materials immediately,” he told Sourcing Journal. “Before the MSI, there were no universally comparable tools that allowed companies to understand and benchmark the impact of their material choices. The MSI represents the first attempt by the industry to pool data for collective benefit. While any tool that leads to comparisons will by nature be imperfect, that imperfection must be weighed against the planetary cost of inaction.”
Most public LCAs have come from trade associations for commodity fibers or companies behind a proprietary material because funding and maintaining a “complete, credible, open, public” set of LCAs “exceeds the resources and capacity of any trade association working in the space,” he said. “It is impossible to independently gather data on a fiber without value chain support because the value chain is the source for the underlying data. A centralized LCA effort requires an incredibly large continuous investment which can’t recoup the maintenance costs if the outputs are public. This is why, to date, most of the databases are private.”
Kibbey said that the long-term solution to providing credible, continually updated public LCA data that fills gaps for commodities would require some manner of a public-private partnership between governments and cooperations that includes a funding model. Creating this kind of partnership has been elusive, and even the European Commission has had to cobble its public PEF-linked database, which is independent from the Higg MSI, from a variety of sources, he added.
Krystle Moody Wood, principal consultant at California-based materials consultancy Materevolve, said that the SAC and Higg have been able to rally an “incredible group” of brand and industry leaders to measure and target the overall reduction of the industry’s impact and she would hate to see that momentum derailed.
“That said, science is changing every day: we are learning more about healthy living systems and our impacts every day,” said Wood, who was previously a materials researcher for both The North Face and its parent company, VF Corp. “Through the lens of soil, sea and circularity, we have already seen massive shifts in the available science we have at our fingertips to consider as we design existing and future textile systems.”
As an early adopter and supporter of the Higg Index and a data-directed approach to decision making, Wood said she would like to see the industry work on closing data gaps such as those involving the benefits of region-specific natural fiber systems that help restore soil health, biodiversity and farmer livelihoods. She would also like to see a greater focus on the negative environmental impacts of highly persistent and pervasive polymers and “forever” chemicals.
“I’d really love to see more from SAC on how they are addressing and securing new data sets for these areas rather than reiterating the same facts—i.e., the intention that the materials are not supposed to be compared against each other,” Wood said. “What are the key areas that SAC sees a need for [the] industry to rally around and improve the data sets? How are they ensuring that synthetics are not improperly weighted over natural fiber systems? Have they shifted any of their processes since these concerns have been raised?”
The best strategy?
Peer-reviewed data is important, agreed Tara St. James, vice president of supply chain, sustainability and culture at New York sustainable luxury brand Another Tomorrow. In the absence of a perfect impact assessment method, however, it is imperative that the industry consolidates its efforts by improving the “admittedly less than perfect” systems that already exist but need continuous refinement.
“Where we would like to see enhanced scrutiny from critics of the Higg—and improvements within the Higg itself—is around product durability, longevity, and ultimately recyclability and end-of-use,” she said. “There is a need to assess the full life-cycle impact of a product and all relevant externalities.”
Still, even perfect data won’t solve fashion’s myriad environmental—and social—ills if nothing is being done about mass production and overconsumption, sustainability advocates say.
“Compound growth of fashion corporations outpaces any product eco-efficiency benefits,” Caroline Priebe, sustainability strategist and founder of New York’s Center for the Advancement of Garment Making, told Sourcing Journal. “If we want to reduce impacts like GHG emissions in time to meet the Paris Agreement timeline, tools like the Higg aren’t our silver bullet.”
“Our best strategy is to simply ensure a living wage throughout the supply chain and produce better and less,” she added. “Investing in labor has no environmental impact and all positive social impact. Producing better means products last longer, retain value for reuse and resale and have a lower lifetime impact. Producing less is much easier to calculate than complicated and time-consuming LCAs.”