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EPR is not enough

The OECD Environment working paper “Extended producer responsibility in the garments sector” aims to assess the potential of an extended producer responsibility approach to achieve the goal of a circular economy in the apparel sector.
Source: Michal Jarmoluk; pixabay.com
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Garments cause environmental pollution at every stage of the product phase. The extended producer responsibility approach makes the manufacturers responsible for the post-consumer products. Textiles and garments constitute a significant proportion of the waste generated. It is estimated that in 2015, 92 million tonnes of such waste were generated worldwide. However, a distinction must be made between waste generated during the manufacturing process and that created after use. A significant proportion of the material is lost during production, estimated at 10 to 30 per cent. This is due to the product design, the type of product and the precision of the manufacturing process. The waste
generated during production is usually mixed and subsequently disposed of. However, the material is a potentially high-quality resource for recyclers. With better handling, it could be kept clean. In addition, manufacturers know exactly what the composition is, which makes recycling easier.

Households frequently dispose of their clothing waste through separate collection. This method keeps the material relatively clean and facilitates reuse or recycling. However, an increasing proportion of used clothing is being found in residual waste. According to the OECD, this is due to the increase in production and the short useful life. The clothing and textile sector is also a major factor in the generation of plastic waste. The amount for 2019 is estimated at 20 million tonnes.

The ecological advantages of reuse and recycling would primarily result from the hypothetical displacement of the use of primary resources. However, there is a risk of a rebound effect with reuse. In general, it is still unclear as to what extent reuse actually contributes to savings in primary resources. The separate collection includes items of clothing that are suitable for reuse. However, in most cases only the high-quality part is used domestically, while the rest is usually exported. Most of the exports go to the Middle East and Africa.

The net ecological benefit of exporting garments for reuse is still unclear. Although the period of use is extended, the importing countries are also responsible for the waste at the end of the garments’ lifespan. In addition, the imports compete with domestic production.

There are significant obstacles to recycling. Many garments consist of fibres made from different materials, which can only be separated with great effort. In addition, there are frequently other elements such as buttons or zippers, which in turn are made of other materials. Accordingly, the proportion of fibre-to-fibre recycling is currently only around one per cent.

The marketability of recycled fibres is limited. Mechanical recycling shortens the fibres in their composition, which limits their usability. The limited scope of secondary production also makes it difficult to achieve price parity with primary materials. For these reasons, there are still few economically viable mechanical recycling options for garments. Although there are new chemical and biological recycling technologies, they would require significant investment.

So far, France is the only OECD country with fully implemented extended producer responsibility for garments. In some OECD countries, however, there are voluntary EPR programmes.

Exporting used goods for repair, refurbishment or reuse raises the question of how to deal with the environmental impacts of these products when they become waste. Therefore, it is being considered how the export of second-hand goods can be included in EPR systems. Typically, EPR policies only aim at recycling products that become waste in the domestic market. Producer responsibility ends at the point where they are exported.

EPR systems can improve the collection for reuse and other forms of recovery of clothing. Mandatory take-back and collection targets could offer new opportunities for reuse and targeted recycling. Experience in France showed that the introduction of EPR was accompanied by increasing collection rates. However, the 50 per cent collection target has not yet been met. This is due not least to the increasing volume of products being brought onto the market. Therefore, the question arises as to whether additional measures are needed to curb the growth in clothing production.

Households can help to reduce the environmental impact of textiles during their use phase by extending that use phase. The repair of garments contributes to this effect. The repair and reconditioning industry has been largely abandoned due to competition from the availability of low-cost replacement products. Barriers to repair include customer expectations, labour costs, particularly the labour required for care and repair versus the manufacturing of new products. France has adapted its EPR system to strengthen circular business models that extend the use phase through domestic financing and sorting.

The question arises as to whether manufacturers have the necessary expertise to extend the useful life of products, or whether they simply want to generate revenue. For example, under the French programme, households and social enterprises are remunerated directly, so there is little additional incentive for manufacturers to offer to repair their own products. There is a possibility that policymakers will encourage brands to collect and sell their own high-quality garments for reuse.

In theory, EPR can create incentives for manufacturers to change the design of their products to reduce their environmental impact, which is also to be achieved by implementing a sliding scale of fees. However, this is difficult to achieve with garments because the fees are small in relation to the product price. Therefore, there is little motivation for manufacturers to change their behaviour.

Another problem regarding design is the international supply chains. A large proportion of clothing production takes place outside the OECD countries. Nonetheless, there is evidence that EPR can identify and promote best practices in international supply chains.

An EPR approach alone is not enough to address all the environmental impacts caused by clothing. Supplementary measures are needed, such as the regulation of harmful chemicals, green public procurement, environmental labelling, the right to repair and economic instruments to promote reuse and repair. Other complementary measures include the mandatory separate collection of clothing waste, a ban on the disposal of separately collected materials and investment in sorting and recycling.

Regulation and economic incentives could also play a role in the production phase. Governments can create standards by defining clothing waste, recycled ingredients and their suitability for reuse. Regulations could also be enacted to improve the chemical composition of products. Economic incentives to promote demand for recycled materials are also a possibility.

Extended producer responsibility is a promising approach to reducing the environmental impacts of garments. As it focuses on manufacturers and post-consumer products, it is well suited to reducing impacts at the end-of-life stage and in the production phase. However, complementary measures can increase their impact. Furthermore, complementary guidelines are also helpful in the use phase to change household behaviour and extend the use phase of garments.

Source: RECYCLING magazine

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