Cradle: Edition 12

Welcome to our September issue of Cradle.

This summer will be remembered for a mix of reasons. Many of those are at the sharp end of the climate and nature crisis, in the form of extreme weather events. Increasingly global heating can be attributed, if not as a cause, definitely as an amplifier. We have been shocked and stunned by wildfires – disturbing in their ferocity and legacy – and as we publish, a tragic huge-scale loss of life in Libya. As we always knew would happen, the humanitarian crisis is merging with the climate crisis. As we approach the fixtures of the international climate regime – Eco-Age brings a debate on Fossil Fuel Fashion to the New York Climate Week – and COP28, there is only one direction to move: forwards and with unprecedented levels of engagement, commitment and focus. Lives literally depend on action, particularly on fossil fuel phase out.

So we return from the summer at Eco-Age asking how on earth the fashion industry can be chivvied into real, authentic progress. It is true that there are some pretty disturbing signals that the industry continues to move in the wrong direction; if we look at decarbonisation alone, it is abundantly clear that despite many plans, pacts and programmes from the industry we are moving in the wrong direction. Fashion is failing on its pacts and promises. Manufacturing is actually increasing its reliance on fossil fuels for fibre by a couple of percentage points every year. You don’t need me to tell you that this is moving in the wrong direction. But the question is, what are we doing about it? Well the answer, revealed in this edition of Cradle, is quite a lot! While a considerable portion of the fashion industry remains hooked on fossil fuel and a linear approach to design, business, waste and emissions which threatens to deepen the nature and climate crisis, there are signals of something completely different. It’s these signals that we are invested in. We’ll be turning this drum beat into a relentless rhythm of change. This summer has also yielded some regulatory intervention that should form the bedrock of system change. In this newsletter, we take a deeper dive into EPR (extended producer responsibility), one of the emergent pieces of legislation that could bring seismic change to our industry.The Eco-Age view is that all of this hard-won emergent regulation is both welcome and overdue but that we need to keep alert to how it can be easily watered down, lobbied against and subverted by greenwash ‘solutions’ that are anything but. That’s why we review a barnstorming recent report from Changing Markets Foundation, Take back Trickery (the clue is in the title!).

Finally we end with a short interview from the newest member of our team, George Harding-Rolls, our Director of Policy and Advocacy. George gives great insight into the opportunities we see here at Eco-Age and the reasons we have created our new policy and advocacy division. I’ll end by echoing these sentiments: we are now experiencing a wave of new regulatory work that is hard won. Much of it is promising. I hope together, we can now work on making it as ambitious as possible. The era of fossil fuels is drawing to a close. Let’s use our power, our work, our expertise and collaborate to make sure that this is the beginning of the seismic shift we have all been working so hard to realise.

Livia Firth

One thing is clear: Fashion and waste are inextricably linked

If you’re in the fashion business, you are also in the waste business. Now, fashion might not like to acknowledge this – a mindset that has caused some significant issues – but facing up to its waste responsibilities is becoming an inevitability. At Eco-Age where we have always taken a holistic view of the value change and impact reductions, we have long made it our mission to expose fashion’s role in the waste crisis. Historically this has all too often been hidden or passed on to the shoulders of the ‘consumer’.

Recently we’ve seen long awaited policy emerge that – if engineered well and applied properly – could go some of the way toward making sure that the industry owns the waste crisis that has, for a long time, been both externalised and normalised. It is to the credit of every campaigner, brand, policy leader, official and all the other many stakeholders that there has been progress. But what progress has there been?

The Deeper Dive…EPR.

One thing is clear: Fashion and waste are inextricably linked. If you’re in the fashion business, you are also in the waste business. Now, fashion might not like to acknowledge this – a mindset that has caused some significant issues – but facing up to its waste responsibilities is becoming an inevitability. At Eco-Age where we have always taken a holistic view of the value change and impact reductions, we have long made it our mission to expose fashion’s role in the waste crisis. Historically this has all too often been hidden or passed on to the shoulders of the ‘consumer’. Recently we’ve seen long awaited policy emerge that – if engineered well and applied properly – could go some of the way toward making sure that the industry owns the waste crisis that has, for a long time, been both externalised and normalised. It is to the credit of every campaigner, brand, policy leader, official and all the other many stakeholders that there has been progress. But what progress has there been?
On 5th July 2023, the European Commission published its long-awaited proposed updates to the Waste Framework Directive, which until then, was only referenced in the Strategy for Sustainable and Circular Textiles (published March 2022) Why is this important? Because while there are several legal measures that relate to textiles (such as REACH and Textiles Labelling Regulation), the Waste Framework Directive is the only legal instrument regulating all aspects of textile waste management. This includes the specific obligations to ensure separate collection, treatment and reporting requirements. What updates does the European Commission propose to the Waste Framework Directive in order to target textiles? The EC proposes developing harmonised Extended Producer Responsibility (EPR) schemes – these would make big business and SMEs physically and financially responsible for the waste generated by their operations. The amount producers would be required to pay into EPR schemes will depend on the environmental performance of textiles, generated via an ‘eco-modulation’ principle. The funds collected through EPR would be used to collect and sort textile waste, in order to tackle any illegal shipments of textile waste disguised as used products. This will work alongside measures under a proposed new regulation for waste shipment. Are there any gaps identified by Eco-Age that could be problematic? Absolutely. The funds collected from EPR schemes could add up to a negligible amount for some big brands and therefore they will not serve as sufficient deterrence for continuing overproduction. The WFD proposal does not feature targets for textile reuse and recycling, crucial circularity principles that are key for overall industry impact reduction. Is there anywhere in the text that Eco-Age consider works particularly well? Yes. We’re pleased that the importance of design has been addressed in the text, a send-of-life impact can be mitigated in part through good product design. What happens next? Under typical legislative procedure, the WFD proposal will now be considered by the European Parliament and the Council.

EPR in a UK context

In March 2023 WRAP the waste resources action programme produced two reports outlining the UK case for EPR and what that might look like, with extensive policy options that could help the UK government cut the amount of waste and carbon emission associated with the UK textiles industry. In a UK context, the conversation with legislators is driven by the principle aim of halving textiles in residual waste over the next ten years. To achieve this 50% cut the report contends that a significant increase in reuse and recycling is needed. While that is undoubtedly true, if we just concentrate on textile volumes going into residual waste on a national basis (this might be characterised as a ‘not in our bin’ approach) that could lead to lack of oversight of dumping and flooding of other textile waste hotspots overseas.This is an issue raised by the recent Changing Market report we discuss below. While earlier this year Therese Coffey, Environment Minister, ruled out EPR for textiles in the UK, there have been recently rumblings and discussions around textile waste in the House of Lords.


A new timely report from the Changing Markets Foundation shows how brands are deploying take back schemes that fail to fulfil promises to save returned clothing. By sewing Apple airtags into items of clothing that were dropped back to mainstream retailers in the UK, Belgium, France and Germany CMF was able to track clothes and see if the retailers’ promises to consumers were fulfilled. Spoiler: mostly they were not. The experiment showed that the majority of the clothes, including those in perfect condition were destroyed, or dumped in countries with little to no waste infrastructure, never mind dealing with fashion discards, this included items sent to Mali. Clothing that wasn’t dumped, was shredded for industrial use, and in one case burned for fuel in a German cement plant. This unmasking of take back schemes by major brands serves as a timely reminder that brands continue to introduce ‘solutions’ that are the opposite. The report accuses several brands of outright greenwash. No doubt readers of Cradle would have read the report with less shock than the general public. But rather perhaps a feeling of intense frustration that warnings have not been heeded. After all comparing the available infrastructure, investment in textiles reprocessing, collecting and sorting with the unprecedented levels of waste and it’s immediately obvious: these schemes cannot be all they promise. At Eco-Age we think the CMF report has many lessons, especially in light of the backdrop of the WFD text and move towards EPR from the European Commission. Against a backdrop of unprecedented waste, natural capital exploitation, and extended producer responsibility schemes, post-consumer textile recovery is set to become an increasingly prevalent part of our lives as we transition to true circularity. This research shows there is still a significant way to go, and highlights the problems with self-governed industry initiatives and self-defined sustainability. We also think that it further illustrates the need for take-back schemes of any kind to be part of a holistic and robust sustainability scheme that looks at all parts of the value chain from design right the way through. In short, take back schemes should not be used as an end-of-pipe fix.

If brands have take back schemes, what sort of questions should we be asking?

If brands have take back schemes, what sort of questions should we be asking? Despite brand rhetoric, takeback schemes can never be a complete solution to over production. Post-consumer textile recovery will be key for industry waste reduction but they are too often used as an empty vehicle for greenwash. Here are the questions you should be asking: What happens to the volume of post-consumer clothing that is recovered? What proportion of garments are repaired or resold in nation of donation, downcycled, shipped as waste, incinerated or landfilled, or simply lost in transit? Are brands using takeback schemes to try and assuage their well-reported links to linear business models, overproduction, and planned / perceived obsolescence? How are brands actually addressing waste reduction through design, repairability, and production volumes? How are brands considering the social impact of all areas of the garment lifecycle Are SMART targets in place for degrowth and elongating the useful life of garments and preventing them from being perceived as waste in the first place? If a brand can’t provide satisfactory answers to these, they are in all likelihood greenwashing and fooling us into thinking our clothing will be repaired, resold, recycled.

George Harding-Rolls

Continuing with this theme, Eco-Age is delighted to welcome a new member of the team as George Harding- Rolls joins from the Changing Markets Foundation. George will head up a new Eco-Age division on Policy and Advocacy. We caught up with him as he prepared for his first Eco-Age event at New York Climate Week.

George tell us about your new role.

Well I’m director of policy and advocacy which is a third division we’re setting up at Eco-Age, on top of the strategical comms and sustainability strategy work that we do. As my job title suggests, there’s two bits to the role! One is to run any pro bono campaigns that we are interested in and we think will help shift the needle. The first one of those is the FOSSIL FUEL FASHION campaign. We will run that kind of work from a campaigning perspective and the idea is to raise the tide of pressure within and on the industry. Plus it will give us the opportunity to engage with NGO partners and other organisations in a holistic way, where we’re all calling for change in an aligned way.

The second part of my role involves delivering on advocacy strategy and advising Eco-Age Partners, including existing clients and bringing in that advisory part of the equation. That’s really important because we’re entering an unprecedented stage in the fashion industry that’s come around almost suddenly in the last two to three years. We’re beginning to experience a tidal wave of legislation. Therefore regulatory compliance issues take on increasing significance and of course many people are fluttering around trying to work out what this might mean for their business.There can be a tendency just to think ‘well how do we comply with this’ and nothing more. That’s not going to work. Clearly the backdrop – the climate and nature crisis – means that we need to really ladder up change and create system change. This is an opportunity to do what we’ve been talking about in fashion for a long time. But to take that opportunity you need to go beyond compliance, way beyond. Hopefully that is where our new division comes in. Any sustainability brand that’s really wedded to the mission, ought to see an opportunity to influence how the rules are changed to make sure we get a shift to true sustainability.

You’ve worked for Forum for the Future, and join us from Changing Markets, what attracted you to a very different sort of business, Eco-Age?

I really like the way EcoAge uses its convening power. Eco-Age is incredibly well connected and it has a reputation of its own as an agency, which I think is comparatively rare. In effect you have an agency that is known for saying interesting things itself, rather than just what its clients are saying. To me that’s pretty interesting. Added on to that, you can see the way Eco-Age is able to bring many perspectives together (for instance Sharing the Table literally convenes young climate leaders, creatives, investors etc) and it has the ability to get so many eyes on content and issues. I think there’s some great ingredients that my work can capitalise on to be really effective.
So how do you persuade businesses and brands to go beyond compliance and take advantage of a more robust regulatory environment rather than being cowed by it?
For me it’s beyond question that if you are already further ahead than content of the proposals, you should be trying to influence how ambitious that policy can be. Because then a lot of your competitors are going to have to scramble around spending time complying with that new level of ambition whilst you’re already there; you’re on your way and you can spend the money and time on other things – such as getting ahead of the next policy or getting your product to another stage. It gives you time and that’s what a lot of businesses lack; time to breathe, time to innovate.
Then there’s that critical link between policy and innovation and financing and investment. Everyone wants to know what the investor angle is. Well the investor angle as far as I’m concerned is that you’re going to be far more interested in investments which have favourable regulatory winds. Therefore, businesses offering these solutions, or genuinely interested in shifting the system away from an unsustainable path, should see policy advocacy as a core part of their busy strategy (knowing that policy endorsement = more investment opportunities).

In New York you will launch the first part campaign from the Eco-Age policy division with an event on Fossil Fuel Fashion. Strikingly this takes place as part of New York Climate Week rather than Fashion Week. Why is that?

To have a Climate Week panel on fossil fashion feels very direct and that is what we need right now. It’s a chance to face some of these issues head on, and discuss them more widely than talking to each other within the fashion industry all the time. For example, we will have panellists from the Global South and have direct evidence of impact and loss and damage.
As we know fashion touches on so many different industries and issues – whether that’s agriculture, worker rights, end of life, the clothing you literally have on your skin, self actualisation – all manner of things. Whereas climate change can be quite intangible, fashion couldn’t be more tangible, so it is also able to lend insights to the climate debate.
The result of putting fashion in the climate zone is to make it a much more vital conversation.

That’s important obviously because as we try and tackle the issues around fashion and get it on to a more sustainable footing, we can’t do that without the fundamental shifts you need from a climate change perspective. The manufacturing side, for example, is clearly dependent on the shift to renewables; without a decent renewable grid in Cambodia, for example, many fashion brands won’t be able to shift away from pernicious fossil fuels like coal in their supply chains. And you can’t do that unless you are having a holistic, international conversation involving production countries as well as fashion brands headquartered in the Global North.

So expect to see us and our policy and advocacy work contributing to all of the major conversations on fashion and decarbonisation. Aside from Climate week, we’re planning events at COP, the EU Parliament, and Davos, among others.

And a lot of your time will obviously be in Brussels?

Yes, the EU is a key focus given the ambition of their proposals on fashion. In the EU it’s about trying to puzzle out that question of: what is the missing piece here? From a policy perspective, I try to think beyond what’s on the agenda, and instead to what it is we are not talking about. What will cause a real systemic shift in the fashion industry? I think that combines well with Eco-Age’s track record in finding the gaps that need to be highlighted, and plugged with well-worked-out, evidence-based solutions.

How hopeful are you about the EU’s developing regulatory strategy for fashion?

I’ve been really encouraged by the fact that, earlier this year, there was a degrowth conference in the EU. The fact that policymakers are talking about degrowth, and the fact that it is on the agenda for discussion is super promising; we cannot really tackle any of this without combating overproduction. That sits at the heart of the ultra fast fashion business model. If you think about it, really every single one of fashion’s issues and impacts tracks back to overproduction and overconsumption.

Thank you George, we wish you the best of luck as you get this division up and running and we look forward to checking in future issues of Cradle!

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