Leah Riley Brown, sustainability policy advisor at British Retail Consortium (BRC), in partnership with the UK Fashion & Textile Fashion Association (UKFT), QSA Partners and British Fashion Council (BFC), wants to ensure producer responsibility for fashion and textiles is effective as possible.
There is little doubt our relationship with clothing and fashion has radically changed in recent decades. For many the days of make do and mend are gone, replaced by “more ditch, less stitch” (coined by BRC).
Increasing climate change awareness might mean some of us think twice about our purchases, but we still live in a culture in which the longevity of our clothes is engineered for seasons rather than lifetimes. Indeed, the climate non-government organisation, WRAP, estimated in July 2017 that £140m worth of clothing goes to landfill every year in the UK alone, due to underutilisation of clothing and lack of recycling.
That's why retailers, from M&S to Next to Primark, have been actively working together through the BRC's Circular Clothing & Textiles Working Group, a collective of retailers and manufacturers brought together by the BRC to lead the industry towards a circular economy, since summer 2021, and WRAP's Textiles 2030 initiative, a voluntary agreement that aims to engage the majority of UK fashion and textiles organisations in collaborative climate action, which was launched in April 2021.
We have also been working with government departments such as Defra, and with manufacturers through our partnerships with UK Fashion & Textile Association, QSA Partners and British Fashion Council, to put the right incentives in place that will ensure more durable, repairable, reusable, and recyclable garments are put on the shelves, at the right price.
But there is no silver bullet that will move the industry to an effective and sustainable circular economy. A complex cocktail of policy initiatives is required to ensure the right balance between encouraging best practice by businesses without unduly impacting consumers.
This starts with ensuring the new Extended Producer Responsibility (EPR) regime is set up correctly. EPR is a common green policy, already in place for packaging since 1997 for electrical and electronic goods in the UK, designed to shift part of the bill currently paid by taxpayers onto the producers, to ensure they are responsible for the environmental impacts of the products they sell.
These EPRs schemes are undergoing substantial reforms, with new packaging EPR rules due to come into force in 2024. The government is now looking to extend the concept to more products and will be launching a consultation phase for an EPR for Fashion and Textiles by the end of 2022, which means getting feedback from a range of industry stakeholders on various policy proposals.
And while the fashion and textile industry is supportive of an EPR for fashion and textiles – the industry should pay for the environmental impact of the products it puts onto the market – the cost of EPR must ensure the path of least resistance is also the most sustainable one. This should involve eco-modulation, incentivising manufacturers and producers to use environmentally sound materials by penalising the use of those harmful to the environment or harder to recycle.
Here at the BRC, we are leading the industry towards a sustainable future through our Climate Action Roadmap – the BRC’s framework to guide the industry to net zero and beyond, launched in September 2020. The roadmap has five pathways that cover key target areas: greenhouse gas data at core of business decisions, operating efficient sites powered by renewable energy, moving to low-carbon logistics, sourcing sustainably, and helping employees and customers to live greener lifestyles. Building a circular economy is integral to reaching our net zero goals, and effective EPR will lead us on our way.
Alongside the Roadmap, we have brought together a broad coalition from across the industry, from manufactures to designers, through the BRC’s Circular Clothing and Textiles Working Group set up last summer. The Working Group sets out our ambitious, industry-leading position, creating the conversations and relationships needed for when the government consultation on EPR for Fashion and Textiles comes into fruition. The mere formation of the group shows that retailers are willing to work together in a pre-competitive space.
We want to see businesses encouraged to create clothes that last, and that use the most sustainable materials. EPR needs to be about more than externalising waste management costs, it needs to be about discouraging consumers from throwing away their clothes in the first place.
Not only is it about design but also about eco-labelling, which would seek to provide consumers with a standardised label on clothes, raising customer awareness on how the garment is more durable, how it can be repaired, or how it can be recycled at the end of its life.
Of course, EPR needs to raise government revenue: with those who create the materials responsible for the costs of disposal. What cannot happen is that those funds are siphoned off for other priorities.
Instead, the funds raised by EPR should be reinvested into supporting the industry to innovate on further measures such as eco-design principles to make clothing more durable, or easier to disassemble and repair or recycle, or to help fund a mandatory kerbside collection of clothing.
It should also help build a corresponding infrastructure to ensure all items are properly collected and sorted before being resold or recycled. Such work would support and complement the work the industry is already doing with InnovateUK, the national innovation agency forming part of UK Research and Innovation (UKRI), which focuses on investing in science and research in the UK. Innovate UK has looked to invest directly into circular economy innovation projects since April 2018.
There is also another role that government policy can play beyond the fees: helping people dispose of their damaged and worn-out clothes. When there is no more wearable life in a garment, it should not go to landfill; it needs to be collected, sorted, and sent on to industries that can use it.
Innovative recycling practices are already in use in other industries, ranging from recovering material to minimise use of virgin raw material, to the use of recycled textiles in automotive and construction. The UK Fashion and Textile industry already has the capacity and capability to adopt these practices.
We need to put in place a ban on sending textiles to landfill and instead promote all the relevant sectors that textiles can be sent to. However, to move from throwing items away to reusing or recycling them will require significant investment to put the right recycling infrastructure in place.
As Caroline Rush, chief executive of the British Fashion Council, concurs, the industry can play a leading role in shaping future legislation to be both “workable and transformative” and - using its experience in other territories - can help the UK lead this agenda. She notes that a partnership with the Department for Environment, Food and Rural Affairs (Defra) in the development of the fashion industry’s approach will ensure that both ambitions of industry and government are met.
None of this is easy, nor can it be done without involving industry in the design. The BRC wants to see an industry-led model that incorporates responsible businesses into the conservation around building a circular economy. This will ensure the system supports those who are doing the right thing.
The fashion and textile industry is one of innovation and creativity; EPR is a unique opportunity for the industry to become a global leader in sustainability. It is therefore vital that industry, government, and the public create and maintain momentum around this agenda.
As Adam Mansell, CEO of UKFT, says, regulation through EPR is an “important mechanism” but to unlock the opportunities ahead we need an industry-led approach, one that “leads to an increase in value and margins and delivers a meaningful growth in onshoring”.
Retail is an industry that recognises its vital role in moving to a circular economy as part of the wider movement to a sustainable modern economy. Together, we can make an EPR that responds to the needs of the customers. The BRC is working with government to one ultimate end: less ditch, more stitch.