Ola Bakowska
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Extended Producer Responsibility isn’t enough to tackle the global ‘fashion waste mountain’. Here's why

The Netherlands will be the second European country to launch an EPR for textiles—but will the policy end waste colonialism?

Extended Producer Responsibility isn’t enough to tackle the global ‘fashion waste mountain’. Here's why
This article was first published by FashionUnited 

Textile waste is one of the world’s fastest-growing waste streams: globally, upwards of 100 billion garments are produced each year, a huge portion of which don’t even reach consumers, while used textile exports from the European Union have tripled over the past two decades. Millions of tonnes of cast-off clothing are shipped around the world yearly, with most ending up in the markets, shores or informal landfills of less affluent countries—mainly in Africa (46%) and Asia (41%). This phenomenon is termed ‘waste colonialism’

Now, the Netherlands is making moves to mitigate fashion’s staggering impact with the introduction of an Extended Producer Responsibility (EPR) scheme for textiles. The EPR, which is set to launch in mid-2023, will require all manufacturers to take the reins on the collection, sorting, recycling and reuse of the products they bring to the Dutch market. 

As only the second European country to roll out an EPR for textiles, the policy will likely position the Netherlands as a frontrunner in textile recycling. But this is not without faults, with several organisations—notably the Or Foundation—quick to point out potentially problematic points. 

Second European EPR for textiles in the making: Dutch launch set for 1st of July

As clothing consumption grows, mountains of textile waste in lower-income nations broaden global inequalities while harming both human health and the environment, with fashion even referred to by some as ‘the new plastic’ for its growing infamy. While the export of plastic waste is to be banned in the EU, the Changing Markets Foundation assessment suggests that more than one in three pieces of used clothing shipped to Kenya contains plastic and is of such a low quality that it immediately becomes waste. Similarly, research from the Or Foundation has found that 40% of the average bale of clothing opened in Accra’s Kantamanto second-hand clothing market, likely the largest second-hand clothing market in the world, leaves the market as waste.

Policy to combat textiles’ impact has been in the works worldwide, from the EU’s Waste Framework Directive and Textiles Strategy to the UK’s Textile 2030 commitments and similar efforts by the American Circular Textiles policy group. The former has mandated that each EU country must launch a separate textile collection scheme by 2025—which the roll-out of EPRs across Member States could help fund. EPRs put a price on all environmental consequences caused by a product throughout its lifetime, effectively transferring responsibility from municipalities and their citizens back to the producers.

However, legislative efforts so far—including EPRs themselves—have proven to be insufficient in tackling the continuously growing climate and social burden caused by growing textile waste volumes. 

While EPRs are intended to prevent producers from making others bear the burden of their waste and poor design, this ‘has largely been driven by concerns in the Global North regarding the high cost of waste management and the scarce landfill space in their own countries,’ the Or Foundation has noted. ‘EPR has, to date, not been concerned with the impact on communities [affected by such waste], “downstream” from the Global North in the global flow of waste streams. In other words, EPR has largely avoided addressing Environmental Justice and Waste Colonialism, in any sector.'

First applied to textiles by the French government through the executing body Refashion, the Dutch government has now called for the scheme to be created and executed by the UPV Textiel Foundation, in line with its broader goals for a fully circular economy by 2050. Current predictions place the levy between €0.24 and €0.57 per kilogram of textiles, with all funds raised expected to be funnelled into the achievement of other goals: that 50% of textile products on the Dutch market are recycled or reused by 2025, gradually increasing to 75% by 2030. Currently, approximately 35% are reused and recycled.

EPRs may fail to stimulate a truly circular and inclusive textiles industry 

At first glance, the EPR philosophy seems simple enough: reminiscent of the polluter pays principle, it appears to be a common-sense approach to mitigate environmental damage. But is it too simple? According to the draft, the levy will be calculated solely based on product weight, treating clothing made of synthetic, natural, organic or recycled materials identically. This erases all incentives to incorporate more circular design practices, from design for recyclability to better material choices.

Used textiles choke second-hand markets around the world. 
Used textiles choke second-hand markets around the world. 

France’s EPR aims to change this: its scheme for textiles and footwear, launched in 2008, introduced eco-modulated fees in 2012 and has reviewed them every year since—lowering levies for durable products, those made with recycled materials and those with other environmental certifications. However, while garments can qualify for a fee of up to six cents, the average fee paid by brands in 2021 was one cent per garment, with 81% of clothing items classified as eco-modulated based on durability. At its current rate, the fee represents ’an infinitesimally small amount, doing nothing to encourage eco-design,’ according to the French EPR Waste Scheme Commission’s president, Jacques Vernier. 

What’s more: this fee fails to incentivise reuse and repair practices, which Circle Economy’s Putting Circular Textiles to Work report notes is the most beneficial for people and the planet: more circular than recycling, with employment benefits to boot. However, setting up large-scale repairs in the Netherlands is currently not commercially viable due to both high labour costs—partly caused by the high tax on labour—and exceedingly low prices for new products. For many, it’s more logical to buy new clothing, instead of seeking out expensive repairs on cheap clothes. Subsidising textile repairs through EPR fees, as well as cutting taxes on circular labour practices such as repair and reuse, could help bridge this gap.  

Furthermore, current EPR schemes do little to benefit the communities around the world that have historically been harmed by the Global North’s fast fashion addiction. Both the French and Dutch EPRs will see the largest portion of textiles collected then be exported abroad—yet fees will remain within and therefore benefit the EU.

An EPR fit for the future: Inclusive dialogue is needed to ensure a just transition worldwide

The upcoming Dutch EPR won’t be the last: we need inspired and accountable policymakers across Europe to innovate on current schemes and build an EPR fit for the future. 

A potential path forward has already been sketched. Ghana-based Or Foundation, nested at the epicentre of the global second-hand clothing trade at the Kantamanto market in Accra, is calling for the French EPR scheme to create an Environmental Fund to support the remediation of current disposal sites such as the Korle Lagoon in Accra, and also:

1. Truly internalise the cost of waste management, aligning with eco-modulated waste management costs throughout the global reverse supply chain. This means a fee of a minimum US$0.50 per newly produced garment.

2. Secure global accountability by distributing funds around the world to enable circular infrastructure in the Global South as well as the Global North—and to cover losses and damages stemming from excessive textile waste shipped around the world.

3. Drive circularity targets that require companies to publicly disclose production volumes to achieve eco-modulated EPR fees. Companies may aim for a 40% reduction in production over five years, balanced with increased reuse and remanufacturing processes.

The Or Foundation is also calling for the French Ministry of Ecological Transition and Refashion to make reparative payments to Haiti, Lebanon and all the African Countries that France exported clothing to in 2021 to the equivalent of no less than €80 per tonne, in line with the fee paid to sorters in France. This amounts to roughly €5.7 Million. 

In conversation with Circle Economy, Liz Ricketts, founder of the Or Foundation, notes that ‘a one-sided conversation will never give rise to a circular economy—so we hope that the Stop Waste Colonialism campaign introduces new voices, beyond ours as an organisation, to inform policy frameworks that benefit everyone working across the second-hand supply chain. EPR must be globally accountable to ensure that the transition to circularity is not subsidised by continued human exploitation and debt in the Global South.’ 

While the Or Foundation’s requests are directed at the French government, our ‘new voice’ hopes to call on policymakers worldwide—including those in the Netherlands—to take responsibility for their country’s contribution to the global fashion waste mountain. In addition to their points, we recommend that: 

1. Reducing the consumption of (new) textiles and extending the lifespan of existing textiles should be explicit objectives of all EPR schemes. The solution won’t be to halt used clothing exports entirely, but to reform them, so that items can be given a second life both within Europe and abroad. This can be done by raising prices on new clothing and cutting costs for repair and second-hand goods, for example, while increasing EPR fees proportionally to the number of items put on the market.

2. Stricter sorting criteria, improved waste directives and strict international trade regulations are executed and mutually respected between exporters, importers, sorters, traders and resellers of clothing from the Global North and Global South equally, to ensure that the global flows of second-hand textiles are consensual rather than repeating post-colonial patterns of exploitation.

3. Funds collected through the EPRs are used to scale fibre-to-fibre recycling and fibre-based sorting infrastructure in Europe. Truly circular end-of-life management for textiles will require investment: currently, textiles are largely exported to places with limited or no capacity for textile-to-textile recycling. 

All eyes on the Netherlands ahead of the EPR launch

The Netherlands is a major European hub for post-consumer textile imports, sorting and export for reuse, open-loop recycling and downcycling.  

Circle Economy and Fashion for Good’s joint project Sorting for Circularity Europe, launched last year, found that 74% of post-consumer textiles are suitable for either mechanical or chemical recycling. However, because sorting based on fibre composition is only done on a very limited scale, these textiles can’t currently be used as feedstock for fibre-to-fibre recycling. Investments in fibre-based sorting will not come from businesses alone, as the financial added value of sorting won’t outweigh the investment itself as long as chemical recycling is not available on a large scale, according to the Sorting for Circularity project. 

However, the business case for sorting in the Netherlands is under pressure due to rising labour costs and a growing share of low-quality, non-rewearable textiles collected. Research by EigenDraads, conducted for the municipality of Rotterdam in 2022, shows that the minimum contribution from the EPR to sorters should be €0.30 per kilo, to compensate for the combination of rising costs and falling income. This is more than the currently-intended contribution from the EPR to Dutch sorters indicated by the Rebel Group report (2021).

The groundwork has been laid, and the Dutch government’s coming launch should be lauded for its potential—but in order for the EPR scheme to be a success, tweaks must be made. Textile products’ end-of-life brings severe impacts that must be addressed—and a revamped EPR could do just that, by prioritising a just and circular economy approach, raising adequate funding for recycling infrastructure and setting bold targets to limit production in the sector.

Learn more

Circle Economy’s Textiles Programme aims to nourish a culture of change amongst businesses and social enterprises on a local and regional level to scale responsible circular economy practices and boost constant improvement in the textile and apparel sector. Learn more about the programme and get in touch here.

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