Game changing legislations looming over the apparel and footwear industry

In 2020 the EU Commission has launched a Circular Economy Action plan1,
aiming at making sustainable products the norm in the EU, support the 2050
carbon neutrality target of the EU, and to push for sustainable growth.
The textile sector has been singled out by the EU commission, together with
four others, as one with the highest environmental impact and less
sustainable one.

Practically, this means that the EU Commission will deploy an array of
regulations that will be impacting the way this industry designs, produces,
markets and disposes of their goods. Some of those regulations will be
implemented in the next few years, and their impact will be potentially
massive. This is unprecedented.

This series of contributions aims at providing information,
insight to some of the most impactful conversations currently happening for
the apparel and footwear industry. This contribution will first aim at
giving a general overview of the breadth of those EU regulations, outlining
how they will impact virtually every actor (of the value chain), from sport
to luxury brands, from manufacturers, fiber to product, to waste
collectors. It will be followed by more detailed pieces, outlining for each
key topic addressed the propositions on the table, their future journey and
potential direction, how they will be impacting the industry strategies and
operations, and what are the opportunities to have those regulations
technically supporting the shift of the apparel and footwear sector to a
sustainable and circular one. The main pieces discussed will be around the
Sustainable Product Policy Initiative, transparency, both at European and
French level, and finally waste and EPR.

As a starting point we have an extremely dispersed sector, both in terms
of number of actors and in terms of countries involved. There is no
equivalent of Apple, Samsung or Foxconn when it comes to T-shirts and
trousers. Instead, you have a myriad of brands, retailers, interacting with
a vast network of often small and medium size manufacturers and farms,
scattered all around the globe, making it one of the sectors that could
collectively benefit the most from impactful and well-designed regulations.

Some of the solutions discussed today will require strong coordination
between the industry and policy makers, may this be for the development of
new solutions, like fiber-to-fiber recycling, or to support building new
infrastructure for the exchange of information all along its complex value

Looking at all of the regulations in the pipeline today, they will
impact each stage of the life cycle of a product, starting from the very

It will change the way you design your goods

An upcoming regulation is coming, the sustainable product initiative.
This regulation, considered as the mother of all sustainability
regulations, will impose requirements on how you design a product, from
minimum quality levels to minimum recycled content of raw material. It will
have a direct impact on what your products are, and will be.

Having completely integrated that on the side of sustainability, the other
key transformation for apparel and footwear will be digitalization, it also
integrates the creation of a digital twin for all garments put on the EU
Market, the Digital Product Passport, accelerating information flow between
all different actors, from manufacturers, brand consumers or

It will change the way you source your goods

A draft regulation on Due Diligence2 has just been released. In its
current status it virtually requires any brand doing business in Europe to
have implemented solid programs to prevent and mitigate all potential
issues (global warming, water scarcity, forced labor, poor working
conditions, etc.) all along their value chain, from raw material (the
cotton field) to end of life. It will require permanent improvement, and
clear pathways to show how you will be able to do tomorrow what you can’t
do today.

The effort required in terms of enhanced traceability, particularly
upstream, monitoring and betters’ programs is significant. And the
potential liability will be in percentage of turnover.

It will change how you market your goods

The textile sector has often been accused of Greenwashing. At the same
brands, retailers and manufacturers are equally asking for stricter
regulations to end this practice. To this end, The UCPD3 (unfair commercial
practice directive) has been updated in December of 2021. In 2022, two
additional pieces of regulations will be published, one on Substantiating
Green Claims, aiming at normalizing how to measure the environmental
performance of your product, for instance its carbon emission, and one on
Consumer empowerment.

Those regulations are meant to accelerate comparability of claims, and
accelerate the amount of robust information provided to consumers.

If you have or plan to have a message around the sustainability
performance of your product or of your brand it is important to integrate
those to avoid investing today into something soon obsolete, or potentially

Finally, it will change the way you think of the end of life of
your products. By 2025 all waste in Europe has to be collected and sorted.
To treat this waste and turn it into resources, a package of regulations
are being discussed, and many countries are developing EPR schemes, to
enhance the accountability of the brands and retailers regarding the
products that they put on the market, to support the deployment of new
sorting and recycling infrastructure, and to accelerate the transition
towards a more circular business model.

All of those regulations will have a dramatic impact on the operations
all along the apparel and footwear value chain, it has the means to really
deliver an efficient transformation.

To make sure that those regulations are effective, and can lead to real
impact, to actual decrease in carbon footprint and betterment of working
conditions, the Policy Hub actively harvest all of the knowledge of the
apparel and footwear sector to be able to build and deliver one ambitious
industry voice to support policy makers into pushing for a circular and
sustainable apparel and footwear industry.

This article is written by Baptiste Carrier-Pradal, Chairman
of The Policy Bub. The Policy Hub- Circularity represents more than 700
apparel & footwear stakeholders including brands, retailers, and
manufacturers. The Policy Hub for Apparel and Footwear is working to
accelerate change by bringing the industry together to voice ambitious
policy recommendations that promote a circular economy in the apparel,
footwear, and textile industry. The Policy Hub was launched in 2019 by the
Sustainable Apparel Coalition, Global Fashion Agenda, and Federation of the
European Sporting Goods Industry and was later joined by two other partner
organisations Textile Exchange and ZDHC Roadmap to Zero Programme.

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