While the EU Commission announced it would consider PEF-CR as a way to substantiate and communicate environmental claims for apparel and footwear, the joint letter highlighted the associated risks of the foreseen measure.
In the open letter the organisations state that although the PEF method has been developed by the Commission to provide a common method to assess products’ environmental impacts, the associated risk is that it will give a limited and unholistic picture of product impact.
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They added: “It is our view that the PEF-CR for apparel and footwear should not be used as a standalone method for underpinning labelling, green claims made in marketing, or any other EU policy measures announced as part of the EU Strategy for Sustainable and Circular Textiles.”
The 12 civil society organisations, including Rreuse, summarised their concerns:
- Governance – The development of the PEF-CR for apparel and footwear is mainly driven by representatives from industry groups. Civil society organisations are involved in a limited capacity as observers without voting rights, MEPs and Member State authorities are underrepresented in the process, and actors from the whole global value chain are not fairly represented (for example, small, local, craft-based industry, suppliers, manufacturers, and consumers).
- Poor data quality – The PEF-CR are being developed by building on the comparison of data from different available life cycle assessments (LCA). However, comparing LCA data can be problematic if the same boundaries and methods of allocation have not been used. Equally, it can be problematic if sample sizes are too small and unrepresentative and/or based on outdated or self-reported data. In addition, the PEF method is to a large extent based on the use of global average secondary data which fails to capture local variations in environmental impacts.
- Full product lifecycle not covered – LCA studies also do not fully capture the environmental impact of the product’s whole life cycle. Highly toxic chemicals, such as PFAS, continue to play a major role in the production of textiles. Yet, the PEF method does not fully capture toxicity related to direct human exposure through the whole life cycle of the garment, including worker’s exposure through manufacturing, use and waste treatment. The PEF-CR for apparel and footwear contains no measurement of microplastic shedding. The impact of the textile sector on biodiversity as well as animal welfare are also not taken into account in the method.
- Social impacts not included – LCA studies tell us nothing about the social conditions that a specific product was produced in (for example, whether workers received a living wage). There is also no consideration given to the socio-economic, cultural, and health impacts of recommending one fibre over another. Such a narrow view of product sustainability is not coherent with the EU’s own commitments to the Sustainable Development Goals (SDGs).
- Method overly rewards fibres made from recycled PET bottles – There is a risk that the method would give a bonus for recycling PET packaging into polyester fibres. However, the EU Textile Strategy identified that using recycled plastic polymers from sorted PET bottles poses a risk of misleading consumers and that such a practice is not in line with the circular model for PET bottles.
- Method doesn’t address fast fashion – The EU Textile Strategy draws a clear link between fast fashion and the growing use of fossil-based synthetic fibres. At the same time the PEF method has proved ineffective at capturing the non durability (or ‘emotional’ durability) of a product, ie the idea that it is not only the physical properties of a product (such as fibre 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 favours the synthetic fibres which have driven overproduction.
The limitations mentioned are all the more significant in light of the Norwegian Consumer Authority (NCA) ruling in June that the global average data behind the Higg Materials Sustainability Index (MSI) does not constitute sufficient evidence for product-specific claims and that any claims made by companies building on this tool are seen by the NCA as misleading.
The civil groups demand a clarification from the Commission as to “whether there is any overlap between the secondary datasets and/or the methodology used by the Higg MSI and by the database which the Commission will provide for use with the PE CR (the EF 3.1 database).”
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