Finnish Textile and Fashion’s views on proposal for Ecodesign for Sustainable Products Regulation

At best, the actions in the proposed regulation would increase the number of more environmentally sustainable products in EU, but the actions would also set significantly more requirements for products and companies. For this reason, it is difficult to asses the impacts for business in advance. The preparation and enforcement of the regulation should particularly account for the resources of small companies, since 88% of European companies in the textile and clothing industry, for example, are micro enterprises (fewer than 10 employees) and 11% are SMEs. In addition to targeted support, companies should be guaranteed a sufficient transition period to fulfil the new requirements.

ECODESIGN REQUIREMENTS MUST BE PLANNED CAREFULLY FOR DIFFERENT PRODUCT GROUPS

Textile products are a very heterogenous product group. In addition to clothing and home textiles targeted at consumers, for example, textile products include health care and hygiene textiles, work and protective clothing, textiles for public spaces and geotextiles. The ecodesign requirements should primarily be targeted at the product groups with the largest environmental impacts, such as consumer products, which constitute over 50% of textile production in the EU. It is important to account for the perspectives of textile industry companies when preparing the criteria for specific product groups.

The goal at the heart of ecodesign requirements should be to improve the products’ durability. According to estimates, 89% of the Finnish textile and clothing industry’s indirect (scope 3) emissions are caused by textile fibre and material production. Doubling the life cycle of products could reduce the industry’s global emissions by almost half.

Assessing the environmental impacts of products requires harmonized  and product-specific calculation methods that enable comparable and reliable communication. This benefits both consumers and companies in the green transition, provided that environmental databases are kept open for economic operators.

The European Parliament has proposed that social sustainability criteria should be considered in the regulation alongside environmental sustainability. Human rights, labour rights and occupational safety are essential parts of the textile and fashion industry’s operations. That said, it is our view that the promotion of social responsibility must be targeted at the entire business, not individual products, and it should be developed through the EU’s corporate social responsibility legislation.

The quality of textile products is directly connected to product reusability and reparability. However, repairing products is not currently an appealing prospect to consumers due to the high price of repairs. Instead, many would rather buy a new product. Repairing products should be made more worthwhile for both consumers and companies. The emotional sustainability of consumer products should also be equally considered alongside technical quality.

RECYCLED FIBRE GOALS SHOULD BE KEPT REASONABLE

The ecodesign requirements propose obligations related to the use of recycled fibre. Increasing the use of recycled fibre supports emission reductions and tackles biodiversity loss. Equal obligations accelerate the industry’s transition towards a circular economy.

Nevertheless, it should be noted that not all recycled fibre in the market is suitable for all products, so using recycled fibre may be in conflict with product quality and durability. Currently, recycled fibre in the textile industry is still mostly mechanically recycled whose quality is not equal to virgin fibre. This should be taken into account when creating quality criteria. As such, the goals related to recycled fibre in products should be kept reasonable. Regularly using even a small amount of recycled fibre has positive impacts. In addition, more focus should be placed on different recycling methods, such as chemical recycling, if there is a desire to establish mandatory requirements for the use of recycled fibre in textile products. At the moment, the availability of recycled fibre is limited.

FAIR PLAYING FIELD FOR ALL OPERATORS

If a product does not fulfil the product and information requirements outlined in the proposed regulation, the product should not be allowed to enter the market in the EU. We are concerned about how the planned product and information requirements can be extended to operators who are outside the EU but sell their products in the EU market. Clarifying this matter is very important to ensure the competitiveness of companies operating in the EU.

We are also concerned about how products’ compliance with the regulation will be verified once the regulation is enforced without unreasonably burdening companies. In our view, verifying product compliance cannot require independent third-party verification or paid certification for all products, as these actions are expensive and have a significant impact on lead times in production. In our opinion, this matter is presented unclearly in the proposed regulation.

PERSONAL PROTECTIVE EQUIPMENT AND THE CE MARKING OUT OF THE SCOPE

We believe it is unnecessary to include regulations on personal protective equipment and their compliance verification in the proposed regulation. Personal protective equipment, which includes items such as protective clothing, is already closely regulated in terms of product features and information requirements. As a result, personal protective equipment should be left out of the proposed regulation, and ecodesign requirements should not be targeted at them.

DIGITAL PRODUCT PASSPORT

The proposed regulation also functions as a framework for providing information on the environmental sustainability of products. We support the proposal to implement a digital product passport for textile products to improve the transparency and traceability.

At best, implementing the digital product passport may promote the transition to a circular economy and improve information exchange and management in the industry’s supply chain. To achieve the envisioned benefits, actions should be planned in a way that accounts for the challenges related to the textile industry’s long and multidimensional supply chains and the actual capabilities which micro enterprises and SMEs have to comply the information requirements. Furthermore, questions related to the accuracy and reliability of information must be resolved before the regulatory process moves forward.

The digital product passport should only include product information that is material to the product’s environmental sustainability, so the use of the passport does not pose unreasonable burden on companies. The technical implementation should be easy to use and benefit existing product management software as much as possible. It should also lean on standardised data management and decentralised data solution.

Implementation should take place in stages, with consideration given to companies’ abilities to respond, and the implementation should start with the collection of existing abd accessible product information. This approach makes it possible to get started on resolving a challenging issue and identify potential problems early. The digital product passport should be planned together with industries to ensure that the extensive expertise on value chains and existing systems as well as the knowledge of practical execution can be utilised. The final implementation must also be beneficial to companies to ensure that the passport achieves its role as a tool for reliable product information and to facilitate a comprehensive commitment to the change.

We have a positive view of the different access rights proposed for the digital product passport, which ensures that confidential business information is protected. However, the production of various language versions regarding information requirements is viewed as challenging. In addition, the information that is entered should be as harmonized as possible to enable information comparison between actors.

National support measures should particularly be targeted at industries that are planned to be the first to implement the digital product passport, such as the textile and clothing industry.

PROHIBITION ON THE DESTRUCTION OF UNSOLD CONSUMER PRODUCTS

The prohibition on the destruction of unsold consumer products is, in principle, supported, and the industry is ready to commit to it. However, our view is that it should not be included in the ecodesign proposal, but it should be addressed in the Waste Framework Directive.

PUBLIC PROCUREMENTS THAT PROTECT THE ENVIRONMENT

Extending sustainability criteria to public procurements is a supported proposal in the textile and clothing industry. The textile industry’s low-carbon roadmap identified that public procurements have a significant impact on creating demand and increasing the market for solutions that support low-carbon and circular economy operations. If large, public procurement entities began buying repair services or demanding that products use recycled materials, industry operators say that it would immediately increase the supply of such products and services. To extend the life cycle of textiles in public procurements, the emphasis on low prices should be reduced, while the emphasis on environmental criteria should be increased.

Finnish Textile and Fashion provided a statement to the Finnish Parliament’s Commerce Committee on 20 September 2022.