Why EPR for Textiles is Critical to a Truly Circular Fashion Economy

Mandatory fee-based extended producer responsibility policies may be necessary to forge a circular economy for textiles, but not all schemes are created equal, according to a new report from the Ellen MacArthur Foundation.

To put it another way, there is good EPR and there is bad EPR, the sustainability nonprofit said Monday. And good EPR takes into consideration the transnational boundaries of textile waste and the systematic issues that underpin the “leaky system” that is discarded clothing, footwear and household textiles.

The timing of the paper, which is targeted at policymakers, could not be better. The European Council has just agreed to begin its “targeted revision” of the European Union’s waste framework directive, including what could shape up to be the world’s largest trading bloc’s collective push into EPR for textiles. (So far, only France, Hungary and the Netherlands hold textile producers responsible for the collection, reuse and recycling of goods that they unleash into their respective markets.) EPR policy is also being bandied around in Australia and Colombia, where efforts are still voluntary, in Ghana and Kenya, and in California and New York in the United States.

Stemming the problem of castoffs flooding the coastlines of Ghana or piling up in the deserts of Chile requires a “dramatic” scale-up of textile collection infrastructure, most of all in the locales where none currently exists, said Valérie Boiten, senior policy officer at the Ellen MacArthur Foundation. And despite what may feel like growing momentum in the space, EPR for textiles beyond a few pockets of activity is still in a nascent stage, particularly when compared to, say, the beverage industry and its long-running deposit refund system.

One problem is—surprisingly enough—the lack of a universal definition for textiles, even among various governmental agencies, Boiten said. Another is the dearth of clear and reliable data that can suggest even a baseline for what collection rates in various parts of the world look like, let alone reuse and recycling numbers.

The Ellen MacArthur Foundation did its best to parse out what it had. Where information is available, collection rates hover at 14 percent on average and top out at 50 percent, it said. What this means is that even in geographies where separation collection is in place, more than half and as much as 86 percent of textile products made available on the market are discarded as part of the municipal solid waste stream, following which they are either incinerated or landfilled.

Even assessing the state of collected textiles is a tall order. More than 80 percent of reusable clothing gleaned through formal systems, for instance, is exported after sorting. In some cases, the country where the bulk of clothes are sorted for export isn’t even the same as the one that originated them, creating a “two-step process” that happens before the garments arrive at their final destination, Boiten said. All of this obscures textile waste’s true material flow, the visibility of which is not only important to convince investors that there’s something worth investing in but also to set reduction targets.

“What we’re seeing across the fashion industry is a huge amount of fragmentation,” Boiten said. “People are all doing all sorts of things, in different ways and they’re calling it different things. We need mandatory policies to create a common direction, common definitions and legally binding targets that everyone works toward.”

The economics of textile collection and recirculation shouldn’t work for only the reusable clothing fraction, either. Ultimately, the goal of EPR should be to take in all discarded textiles, including the non-reusable share that’s too worn out or damaged for resale.

A reason European textile recyclers—actually collectors and sorters—are struggling has to do with the quality decline in the goods that they’re receiving, which translates into lower viability for resale and lower prices, Boiten said. That, coupled with a Red Sea crisis that has jacked up shipping costs and extended delivery times, has put unprecedented pressure on their already-thin margins. Complementary legislation that establishes a minimum bar for the quality, durability, repairability and recyclability of textiles from the outset, such as the EU’s ecodesign for sustainable products regulation, a.k.a. ESPR, aims to do, could help with that, Boiten said.

“Governments are not doing nearly enough to really stimulate circular business models and to disincentivize linear ones,” she added.

The report doesn’t specify what fees EPR schemes should charge, only that they be sufficient to cover the net cost of collection, sorting, reuse and recycling at the minimum and not create a “perverse incentive” to reduce the volume collected to skimp on costs. Beyond that, governments might choose to start adding things that contribute to a more circular economy rather than merely managing waste in a linear one.

“For example, my country Belgium implements an EPR policy, but 80 percent of what that EPR scheme collects is exported out of the country,” Boiten said. “The principle of EPR isn’t fully effective because you’re supposed to fund waste management, but actually these textiles are becoming waste in a different country. ​​And the funding raised here is never reaching those countries.”

For countries like Ghana and Chile, which have become the “final sinks” for the world’s textile trash because they have neither the infrastructure nor resources to manage it, a regular cash infusion would not only help them cope with the effects of an overconsuming global North but also clean up existing damage.

In their relative domestic markets, EPR policies could also help fund textile-to-textile recycling plants, which are still badly in need of investment. More important, if EPR makes targets on textile reduction legally binding, targets on textile-to-textile recycling also become legally binding, sending a “strong demand signal” that will help such facilities thrive.

Even so, EPR is only a starting point, Boiten said. To transform the textile industry, other policies remain necessary. So is a platform for governments to come together and “talk to one another,” she said.

“All these countries are doing different things,” Boiten said. “But I think what we’re looking at is a mechanism whereby these countries come together on a regular basis and have the opportunity to learn and exchange best practices. Not saying that we need to be moving towards a treaty or anything of the sort in the near future, but I do think we’re lacking these consultation mechanisms that include reporting and data generation.”