At the Sustainable Apparel Coalition’s annual meeting in Singapore earlier this month, Amina Razvi, the organization’s executive director, immediately addressed the elephant in the room.
“I think we all agree that data needs to be trusted, it needs to be accurate, it needs to be credible, it needs to be substantiated,” she said. “Which means that we have a shared objective, which is how do you put trusted, credible data in the hands of decision-makers, whether it’s from a business perspective or whether it’s with consumers?”
Razvi was speaking about the Materials Sustainability Index, or MSI, a module of the popular Higg Index suite of tools that rates the environmental impact of materials across categories such as global warming potential, water scarcity, fossil-fuel depletion and chemistry. For years, the trade group’s members, which include Adidas, Gap Inc, H&M Group and Patagonia, have been using the MSI’s wealth of life-cycle assessment (LCA) data to justify so-called “sustainable” sourcing decisions, both within their companies and to their customers.
But the Higg MSI has long had its detractors. Because its cradle-to-gate approach excluded recyclability, biodegradability, microfiber pollution and other factors, it provided an incomplete—and more important, misleading—picture of a material’s true impact, its critics said. Natural fiber producers publicly fumed that the tool appeared to frame synthetic materials such as polyester, acrylic and polyurethane as better for the planet than silk, wool and cow-based leather, which the SAC attempted to address in 2020 by nixing the aggregated single score it was using to grade materials, though the individual category scores remained.
All of this came to a head earlier this year when the Norwegian Consumer Authority (NCA) ruled that Norrøna, an SAC member that was piloting a consumer-facing platform based on MSI data, breached the country’s greenwashing laws when it used the scheme to market its outdoor wear as environmentally friendly. It also warned H&M of trying to do the same. In response, the SAC announced that it would be commissioning, “with urgency,” an independent third-party expert review of the Higg MSI’s data and methodology. It also hit pause on the program.
This wasn’t enough for the Netherlands Authority for Consumers and Markets (ACM), which in September ordered Decathlon and H&M to adjust or withdraw from their clothing and websites any “eco” or “conscious” designations because the claims weren’t being sufficiently substantiated. Both companies have since dropped their eco-labels. H&M is also phasing out the green “Conscious Choice” hangtags that have physically signposted its “sustainable” offerings for nearly a decade, a move that led at least one commentator to declare the “end of an era.” The “Conscious Choice” collection of products is itself at the center of not one but two lawsuits.
The NCA singled out Norrøna because the brand happened to be headquartered in Norway, NCA assistant director Tonje Drevland said at a later session at the SAC conference. While it made a convenient target, the “real” responsibility to communicate accurately lies with the major retailers, who make up the bulk of the “problem.” This isn’t an SAC-specific issue, either, she pointed out.
“This is an industry problem and an industry challenge,” Drevland said. “Many traders do not have sufficient knowledge about the claims they’re making and the context they’re making them in and so we saw a need to make a guidance together with the ACM that could also reach beyond the MSI…and lead to change.”
The guidance, which debuted in October, offers the SAC advice on how to continue using the Higg MSI to make environmental claims without flouting consumer-protection regulations under current European Union law. One sticking point is that the use of global average data does not “constitute documentation” for a product-specific claim.
“The global average numbers presented to the consumer should be based on representative data,” the ACM and NCA wrote. “This means that if there are significant variations from country to country or region to region in the numbers presented to the consumer, this should be reflected in the data constituting the basis for the global average numbers. For example, if it is likely from a scientific point of view that water usage for organic cotton and/or conventional cotton varies from country to country and/or region to region, the data underlying the averages should reflect this. If not, the data underlying the numbers will not be representative. Presentation of these numbers to consumers may then be misleading.”
Discussions between the SAC and the consumer authorities have been a “really positive step forward” and a “good thing,” Razvi said.
“Because what it means is that we are starting to engage a much broader group of stakeholders in this conversation that is so critically important to the industry to move forward,” she said. “We believe it’s important to be part of that conversation, to also ensure that policymakers understand what work the industry has already done around data collection and substantiation…and to make sure that there’s consistency for the industry…from a policy perspective and a legislative perspective.”
Norrøna’s sustainability chief Brad Boren, speaking at the same panel as Drevland, admitted he didn’t like the term “eco-label” to begin with.
“I think we need to make it more about impact transparency,” he said. “I think that would be a better name. We should not be talking about [whether] products are friendly for the environment [or] bad for the environment. We need to make products that last longer. Hopefully, in the future, we can make fibers from methane gas or use better dyes.”
This requires more robust data, Drevland said, and not just for a handful of categories. And it will have to take more than one company to throw its money behind generating this.
“We need to have better information on the processing or the dyes. We need to look at biodiversity, and we need to look at microfiber leakage,” he said. “We want to be honest about it. And we want to show [that] the impact of a product isn’t [only] about what’s going into a product. It’s also about how long that product’s being used.”
The fact of the matter is that LCAs are expensive and time-consuming, said La Rhea Pepper, co-founder and CEO of Textile Exchange, a multistakeholder organization dedicated to the uptake of more responsible fibers that includes many SAC members. The average LCA costs more than $200,000, and a single one involving cotton can take at least three years.
“LCAs is are a significant investment, and…they’re not something a lot of the smaller brands can do,” she said. “So what MSI has been able to do is take LCAs that are provided by the industry in order to provide a baseline.”
What is needed, Pepper said, is “another level” of investment, which is what Textile Exchange has been doing with alpaca, cashmere, mohair and wool. Next year, it’ll be shelling out half a million dollars on LCAs involving cotton, polyester and leather. The organization also maintains a number of standards, including the Organic Content Standard and the Responsible Wool Standard, that can “pull more information” while adhering to best practices.
“And so when you make an attribute claim rather than an impact claim that this product was made from responsible or organic cotton or whatever the case may be, it is about those best practices,” she said.
Pepper dubbed the recent controversies a “wake-up call” around setting realistic expectations. “There’s a number of ways to effectively communicate to consumers, we just need to make sure it’s backed up with data and verification and quality control,” she added. “I think this is going to be an area for us to kind of push a reset button…so that consumers ultimately can make informed decisions.”
While green claims for products are not a “human right” for brands, added Jeremy Lardeau, vice president of Higg Index at the SAC, there needs to be a balance between requiring perfect data and striving for better data.
“Otherwise we’re going to have a chilling effect on the industry,” he said. “We can’t wait for this ideal vision of what product labeling should look like to have some level of consumer communication, because the climate crisis is upon us and need to accelerate these efforts. …Consumer engagement can help with that.”
Differing interpretations of the EU’s consumer-rights directive by various jurisdictions in the bloc don’t help, Lardeau said. France, for instance, is developing a carbon labeling scheme based on an LCA database that includes many global averages, which by the ACM and NCA’s guidance “would not be acceptable.”
“So for us, I think this discussion is really important in order to have a more harmonized approach to and a common bar set for what is required to substantiate green claims in an acceptable and appropriate way,” he said. “Obviously, we’ll continue to evolve the tools in order to meet the spirit of the guidance.”
There’s been a “lot of reflection” across the industry about how to best present existing data because “there’s a lot of interesting, rich information that we want to surface to consumers that can drive change up the supply chain,” Lardeau said. The challenge right now is figuring out how to communicate all of that in a way that every stakeholder agrees with.
For Drevland, it is “wrong” to talk about sustainability in the fashion industry. Rather, the focus should be on best practices. Zeroing in on sustainability “creates expectations that the industry cannot meet,” she said. When brands talk about best practices, however, they’re putting their efforts into context for consumers.
“That’s helping the consumer instead of confusing,” Drevland added.