The European Commission plans to slap a sustainability label on every garment and shoe. A new coalition of industry groups argues that the “incomplete” scheme could contribute to fashion’s greenwashing problem.
While the Product Environmental Footprint (PEF) is meant to encourage consumers to make eco-friendlier choices at the point of purchase, the suggested methodology is narrowly drawn and doesn’t account for critical environmental considerations, claims Make the Label Count, an initiative whose roster includes Australian Wool Innovation, the Campaign for Wool, Changing Markets Foundation, Cotton Australia, Fibershed, the International Sericultural Commission, the International Wool Textile Organisation and the Plastic Soup Foundation.
Because the framework doesn’t account for the benefits of using renewable and biodegradable fibers or the effects of microplastic pollution, Make the Label Count said, fossil-fuel-derived synthetics such as polyester score as “greener” than their natural counterparts. Not only does this risk misleading customers about the impacts of their products, the campaign said, but it could also erode the system’s credibility and undermine the European Union’s overall sustainability goals.
“The EU’s labeling initiative is likely to set a global standard and could deliver great environmental outcomes if the PEF methodology is amended. It’s important to act now and get it right to help establish the system’s credibility and ensure well-intentioned consumers are not misled,” the group wrote in a report summing up concerns about the campaign. “We owe it to the planet to produce sustainable clothing, and we owe it to consumers to make sure they know how sustainable that clothing is—and the label on their products needs to reflect that.”
The European Commission proposed the scheme in 2013 as a way to provide a standardized means of measuring and validating environmental claims, creating a “level playing field” for competition between products made in different member states. PEF, which uses life-cycle assessments to crunch its numbers, has to date identified 16 environmental categories in its methodology, including ozone depletion, human toxicity, land use and resource depletion. The idea is to translate this data into a consumer-facing label that uses red, yellow and green “traffic lights” or an A to E grading scale to present an at-a-glance measure of a product’s environmental burden.
But relying on LCAs already puts natural and petroleum-based fibers on uneven footing, Make the Label Count said. PEF’s analysis of synthetic fibers begins at extraction at the wellhead, rather than during raw material formation. In contrast, all the impacts of creating natural fibers are “fully taken into account,” including greenhouse-gas emissions and land and water use.
“Given that textile fibers often show the greatest lifecycle impacts during the fiber formation stage, this limitation of PEF magnifies the inequity between products made from natural and fossil fuel-based fibers,” the coalition said. “It’s impractical to capture and account for the ancient environmental impacts of forming crude oil, so methodology improvement is needed to enable equitable comparison of fiber types.”
Make the Label Count asserts that natural fibers, which are grown or raised on farms, are inherently circular, yet their scores don’t reflect this. Instead, non-biodegradable fibers are “not penalized for continually adding solid waste to the world’s landfills and further releasing microplastics to the soil, oceans and air,” it said.
A representative from the European Commission admitted there was “still a long way to go” before a final PEF framework is released into the wild. “We have identified room for improvement along all the phases for the circular economy for design,” Paola Migliorini said at a panel marking the launch of Make the Label Count on Wednesday. She added that the “landscape of challenges” is complex, as is the “landscape of solutions.” PEF also has to come together with the EU Strategy for Sustainable Textiles to “enhance the coherence of all the measures that we have” and provide greater clarity.
The debate over PEF is reminiscent of the controversy over the Sustainable Apparel Coalition’s Higg Materials Sustainability Index, which Australian Wool Innovation, the International Sericultural Commission and others have criticized in the past for rating polyester, acrylic and polyurethane more highly than silk, wool and cowhide in terms of environmental impact. The SAC, which leads the technical secretariat facilitating industry alignment on PEF, responded by retiring the aggregated single score in favor of a more holistic consideration of a material’s use and end of life. The discussion also raised questions about the adoption of LCAs, which are often precise in scope, yet are frequently extrapolated to draw generalized conclusions.
Meanwhile, LCAs on textiles and clothing don’t typically include the use phase of the value chain, which is “half of the problem,” said Ingun Grimstad Klepp, a research professor at Consumption Research Norway, at the same panel. “If you have a labeling system, three things have to be there for it to be a functional system. First of all, it has to be known. Second, it has to be trusted. And third, it has to be fair, it has to do the job. It looks like PEF is failing on these three things, especially the last two ones. If PEF launches as it looks like today, it’s going to be the greatest greenwashing system on Earth.”
Livia Firth, creative director of sustainability consultancy Eco-Age, said that building a label on “misinformation and skewed science” at this point would be “unforgivable,” particularly if it incentivizes fast fashion’s model of quantity over quality and trendiness over longevity.
“It could potentially unleash billions more items made of non-biodegradable petrochemical plastic polymers onto a patchy global waste system that is already unable to cope,” she said at the panel. “But it goes further than that. These decisions scale: they affect where investment goes. ESG funds so badly needed to help tackle the climate crisis could end up underpinning more pollution. These decisions also have a bearing on millions of lives in the cotton fields of the global south for example.”
If the industry makes a mistake on the labels by not “following the science,” Firth added, then it loses its “moral authority” to combat other forms of greenwashing.
“There is an epidemic of greenwash in our industry. Overclaims on sustainability will damage all of us because we will simply fail to deliver on cuts we need to ensure a livable planet,” she said. “Making the label count is a wider issue than jostling for customer attention, or trying to latch onto an enthusiasm for sustainable fashion. It is about linking this garment to the science and protocols that will deliver us a livable planet. There is that much at stake.”