The Higg Materials Sustainability Index isn’t the only impact-measurement tool facing questions.
Two different coalitions have written to the European Commission this month expressing concern over an eco-labeling methodology meant to gauge a product’s environmental cost from material acquisition through processing, distribution, use and end of life.
The so-called Product Environmental Footprint, better known by its acronym PEF, is currently “not fit for purpose” and could “give license to greenwashing,” according to Make the Label Count, a campaign whose members include 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.
The campaign’s main point of contention is the absence of three “key” indicators: microplastic release, plastic waste and circularity. While targeted strategies exist for each under the EU Microplastics Initiative and the EU Strategy for Sustainable and Circular Textiles, it said, targeted indicators to measure and report progress in these areas are “lacking.”
There is too much that is known about the harmful effects of microplastic pollution, for instance, to prevent this information from reaching consumers, Make the Label Count said. And given the “significant” contribution of synthetic clothing to fast fashion and plastic waste, a clearly defined plastic waste indicator that makes solid waste production the least preferred option should not be a “controversial idea.” Right now, only minimal weight, amounting to less than 1 percent of a product’s score, is given to fossil-fuel-derived fibers such as polyester, which will “not influence consumer choices,” the letter said.
Likewise, the commission is “under-weighting” processes such as biological circularity and input renewability, which fails to send a “strong market signal” that will help the European Union achieve its ambitious circularity goals.
“The evidence that the growth in cheap synthetic clothing is closely correlated to the growth of fast fashion is compelling,” the coalition said. “Omission of indicators linked to synthetic clothing, including microplastics, plastic waste and circularity will result in clothing made from fossil materials being shown as more sustainable, guiding well-intended consumers to buying more rather than less of the clothing primarily responsible for fast fashion.”
Another set of advocacy groups, including the Changing Markets Foundation, Clean Clothes Campaign and Fashion Revolution, worried that the PEF, as it stands, will give a “limited and unholistic picture” of product impact and therefore should not be used as a standalone method to justify corporate green claims, an issue that has drawn increasing scrutiny from regulators in recent months.
Like Make the Label Count, the organizations say that the full impact of a product’s life cycle isn’t being sufficiently captured and that the methodology risks rewarding recycling PET bottles into polyester fibers by not including measurements of microplastic release. Social impacts are likewise missing, they said, since LCA studies don’t shed light on the conditions under which products were made. Others that deserve more attention are hazardous chemicals, biodiversity and animal welfare.
Most of all, the PEF doesn’t address fast fashion, their letter said.
“The EU Textile Strategy draws a clear link between fast fashion and the growing use of fossil-based synthetic fibers,” it said. “At the same time, the PEF method has proved ineffective at capturing the non-physical durability (or ‘emotional’ durability) of a product, i.e. the idea that it is not only the physical properties of a product (such as fiber strength) that determine whether it will be used and worn for a long time; factors such as price and trend temporality play a role too. In this respect (and due to all lifecycle aspects not being covered as outlined above) there is a risk that the method favors the synthetic fibers which have driven overproduction.”
Baptiste Carriere-Pradal, chair of the Policy Hub, a think tank founded by the Sustainable Apparel Coalition, Global Fashion Agenda and the Federation of the European Sporting Goods Industry, as well as chair of the technical secretariat of the PEF project, said that the framework is still “evolving.” During its pilot phase, 14 indicators were included. Now in its second iteration, the PEF’s impact categories number 16, with a circularity formula that accounts for biodegradability and “other elements.” This is a welcome addition, he told Sourcing Journal.
“Make the Label asks for the inclusion of microplastic, while some NGOs are asking for biodiversity,” Carriere-Pradal said. “There is a consensus, from the industry to policymakers and civil society that, moving forward, more impact categories would benefit from being included in the PEF framework. All those points are being explored by the EU Commission and all players are eager to explore further broadening of the PEF scope.”
But there’s a reason not to delay the PEF’s rollout, he said. With the climate crisis escalating, “it is important to have, as soon as possible, an agreed way to measure product footprint intended to be communicated to consumers, starting with the identified 16 impact categories,” Carriere-Pradal said, adding that “time is of the essence.”
Because the “realistic inclusion” of new impacts will take at least five to 10 years to reach maturity, the development of such indicators needs to happen while the commission strengthens future PEF guidelines, he said.
“Consequently, it is important that the upcoming regulation on Substantiating Green Claims recognizes the PEF as the only approved method to communicate on the already identified 16 impact categories, while allowing additional impact to be communicated, such as microplastic, and while working collaboratively on the inclusion of future new impacts and refinement of the methodology for the future,” Carriere-Pradal said.