Cradle: Edition Six

In this issue of Cradle…

How and why did a flawed standard for sustainability get so close to becoming the de facto global benchmark underpinning laws to make fashion green. Why weren’t questions over the capabilities of this index heard until now? As autumn dictates a new fashion cycle, Cradle makes the case for learning the biggest lesson from the summer.

Welcome to the autumn issue of Cradle. Famously September into October is fashion’s busiest month, and signals the start of a new fashion cycle through international shows. In the international climate regime, late September also heralds New York Climate Week, arguably now the most significant international stocktake on progress. These two occasions usually have nothing to do with each other but at Cradle we think they ought to be connected.  It is high time the traditional September fashion hoopla: a round-up of  the international shows, new launches heralding the birth of yet more product, took on some of the grave realities of the climate and nature emergency.

So we start this September bucking a trend, and looking back to the very recent past.  In order to have a future, we must learn lessons, and this summer the teachings from Planet Earth came thick and fast. From a climate and nature point of view (and why have any other?) the summer of 2022 has taught humanity much, if only we’d care to listen and act accordingly. In the last few weeks alone, China has experienced an epic drought, one third of Pakistan ended up under water following devastating floods, the Arctic has experienced another unprecedented heatwave and the appalling fossil fuel financed Ukraine conflict continues.

If we care to listen, we’ve also been taught some pivotal lessons about how we regulate, monitor and progress sustainability in our industry. Since its inception, we have used this newsletter, Cradle, to explain the granular issues around ‘Greenwash’ rather than just the headline grabbing outrage. But this summer those two things collided. The Norwegian Consumer Authority deemed marketing based on general data as illegal and a seminal New York Times piece spotlighted the preferential treatment of plastic fibres and exposed the skewed system that promotes this as a sustainable future. In both cases the Higg Index, marshalled by the Sustainable Apparel Coalition, was at the centre of the storm.

Were we surprised? Not at all. As we’ll discuss, and many readers will be aware from previous issues of Cradle, we have spotlighted deficits in this index time and time again. We are also relieved. To take a stance and speak truth to the power of a brand backed entity is often a thankless task. You can feel as if you are shouting into the wind. In this case two careful investigations, from different sources and different processes found the same thing: the use of generalised data on LCAs creating terrible outcomes.

The greenwash deserves to be exposed because as we have discussed before, the stakes are incredibly high. A flawed standard was on its way to becoming a ‘de facto global standard’ despite the fact that it was not fit for purpose. If that had been achieved (and it may still be achieved) then where does that leave us and our industry? A powerful global standard would be used to underpin investment in the form of ESG and dictate direction of travel for the whole industry. It would leave those that are not favoured by the standard – in this case natural fibres – out in the cold. We would therefore find ourselves in the shocking situation of greenwashing the entire sector through a standard based on poor data, discriminating against the materials that arguably we ought to be moving toward in many cases. Materials and processes that are genuinely lower impact, regenerative and sustaining for local economies and livelihoods.

But this time we got away with it. There needs to be time now for a reappraisal and a grown up conversation about how you plug data gaps with real data and how you standardise traceability and life cycle analysis so that it is real, verifiable and comprehensive. Read on and we’ll discuss the two major fissures in the Higg Index and how our experts have helped to unpick these issues, and the Eco-Age view on how we change and avoid repeating mistakes.

We are not out of the woods yet – powerful entities pedalling myths have a way of forcing their way back to the top position. Neither have we got away with it. Make no mistake, damage has already been caused to our sector. But we do have a chance to correct course, and our hope for the year ahead is that we grasp that opportunity with both hands.

Fashionscapes: A Circular Economy

The Back Story

What happened and why?

When the Higg Index Sustainability Profile was launched in 2021, the Norwegian brand, Norrøna was an early adopter. By this summer, the brand’s marketing had attracted the interest of the Norwegian Consumer Agency (NCA), the public body that enforces the country’s Marketing Control Act. Most countries have a version of this organisation – in the UK the Advertising Standards Authority has traditionally policed brand claims, but more recently guidelines on greenwash have been put into play by the Consumer Markets Authority (CMA) suggesting this will be more heavily regulated. Similar legislative moves have followed in France, Australia and some US states, as we have covered in previous issues. Unsurprisingly the rise of this ‘policing’ of environmental claims mirrors the rise of ‘greenwash’, particularly unsubstantiated claims about a product or service’s preferential environmental qualities. If we return to the Norwegian example, the NCA implements Norwegian marketing law, which in turn states that ‘a product’s main qualities must be easily accessible and understandable for the consumer. Claiming that a product is ‘sustainable’ when it is not immediately clear what in particular about the product makes it ‘sustainable’ will more often than not be misleading.’
So how did Higg Index and by association, Norrøna fall foul of these rules? (H&M was also ruled against by the watchdog under the same terms). To understand this we must go back to the use of generalised data to inform lifecycle analysis (LCA), and then to communicate these to the consumer. In this case, as Ecotextile news put it ‘Norrøna uses Higg data to claim its organic cotton products use 87 per cent less water, cause 46 per cent less water pollution, create 13 per cent less carbon emissions and use eight per cent less fossil fuels’ [than conventional production]. The NCA was concerned that these percentages were a reflection of global average figures for cotton production in relation to its climate and environmental impact. In short, Higg had used generalised data (seemingly from two different studies) and the brand had used this to substantiate a green claim to consumers. However, those claims did not stand up to scrutiny.

By extension this moved the spotlight on to the Higg Index as a whole, with the NCA wondering aloud and in public whether it could be used at all  ‘in marketing specific products with a view to saying something about the climate and environmental impact of the product in question,’ as Ecotexile News reported.

By last month, the NCA had reached a firm conclusion: no, the Higg Index could not be used in this way, and furthermore to use it for this purpose is deemed illegal. The SAC was forced to suspend the global use of sustainability data from the Higg Materials Sustainability Index (Higg MSI) on consumer-facing product labels.

This is the theme that is picked up on and examined carefully in a New York Times piece also from this summer. Indeed the piece by Hiroko Tabuchi, electrified the debate over discrimination against natural fibre producers such as silk producer in favour of oil based synthetics, based on skewed data. Here is a an excerpt:

‘The [Higg] index rates polyester as one of the world’s most sustainable fabrics, for example, using data on European polyester production provided by a plastics-industry group, although most of the world’s polyester is made in Asia, usually using a dirtier energy grid and under less stringent environmental rules. The Higg rating for elastane, also known as Lycra or spandex, draws on a study by what was at the time the world’s largest elastane producer, Invista, a subsidiary of the conglomerate Koch Industries. (Invista sold its Lycra business in 2019.)’

If you want to know what happened next, well there was quite the reaction. Not least from the US-based Natural Fibers Alliance (NFA), which called the immediate suspension of the global use of all Higg Index data. At the very least, it will hopefully have provided a point for reflection, especially from emerging regulatory systems and coalitions that might have been minded to take the Higg Index as gospel and use to benchmark future work.

The Eco-Age View

At Eco-Age we are famously unafraid to call out fashion’s dependency on oil-based synthetics and the use of skewed data on cotton and other environmental impacts. We have been campaigning on precisely these issues over the past decade and we partner with independent researchers and academics to model real data for real change. A prime example of this is our affiliation with researchers Veronica Bates Kassatly and Dorothee Banmann-Pauly and their series of reports The Great Greenwashing Machine.

In The Great Greenwashing Machine Part II, the authors take an exhaustive look at the grip that participating brands (in this case those who are part of Textile Exchange) really have on traceability in their supply chain. The reality is sobering. Data from Textile Exchange’s own insight report from 2020 for example reveals that ‘54% of participants, accounting for 77% of uptake volume, did not know which country their polyester came from (page 99).’ On other fibres, ‘42% of the uptake volume of cotton came with no known country of origin, and the same applied to 65% of polyamide, 60% of the feedstock for manmade cellulosics, 55% of wool, and 60% of leather’.

Only a tiny percentage of brands had confidence in the full accuracy of the data they were using. This leads us to conclude that most parts of our industry don’t really know where the majority of their fibre and fabric is coming from. Yet the rhetoric does not match the reality; and that means that most are in danger of pretending that they are measuring and reporting real values.
Philippa Grogan is one of our in-house experts on policy, fashion and textiles. She reminds us that LCAs are a useful tool ‘to be used behind the scenes to help guide businesses decisions to measure and improve sustainability performance. They are more useful however, primary data gathered is gathered from a producer’s own operations.’ When the picture gets more complex, that’s when the risks mount and Philippa goes on to explain, ‘When LCA data is presented to consumers on product info to encourage comparisons between products at the point-of-purchase that’s when regulators are inclined to step in. Because this is the threshold where data is being used as a marketing tool instead of a sustainability tool. It risks giving consumers information that is not accurate and that could lead to a charge of greenwashing’.
In short, Philippa sees LCAs as performing an important but limited role, she says, ‘Use LCAs to guide material selection choices at point of purchase, but don’t let Higg MSI data cross the threshold of the consumer. They must be kept out of marketing and comms.’ We think this is a fair and considered assessment. Of course, what happens next will depend as to whether a powerful body such as SAC will admit limitations and show restraint. The pressure of filling data gaps is considerable. But bad science and greenwash is not acceptable. Ultimately much of the pressure is caused by the desire to retrofit business as usual, and as we know it is that very business that needs to change as a matter of urgency.

Earlier this month, Eco Age held an important roundtable event with Equiception and The Geneva Centre for Human Rights covering precisely these issues (we provide more detail and links to the roundtable below). Researcher and expert and co-author of The Great Greenwashing Machine Report, Veronica Bates Kassatly made this point on LCAs, ‘The first thing to realise,’ she told roundtable participants, ‘are that LCAs are not absolute. They are not a sausage machine, they are not a cookie cutter. From any given set of raw data, there is no single unique value that will automatically be generated for greenhouse gas emissions, water consumption, eutrophication, etc. Vastly different purported impacts can be obtained from exactly the same data by using different models, different methodologies and or different boundaries.’

When we put all of this evidence and information together and apply scrutiny, what becomes clear is that this is crunch time. New and upcoming regulations from the EU and the US – New York’s Fashion Sustainability Act – rightly seek to prevent greenwashing and regulate claims. This drives a hunger for data and metrics but that must not mean that the fashion industry accepts all and any data. Only comprehensive, credible and verified data has any place in the metrics that help us make better choices. Otherwise, those choices will be fake. We can all pretend to measure and report something real, but to what end if we know that that is not the case?


We will continue to unpick and interrogate precisely these questions as we move forward. Because we must move forward. (Our recent Roundtable is an example of how we are challenging an over reliance on LCAs and nonsensical data, and spearheading fact-based, evidence-based pathways to change). At the moment, much of the pushback seems to take the form of  ‘don’t let perfection be the enemy of progress’. Meanwhile the question of how much true traceability and safe data costs continues to be a vexed one. Indeed, we are constantly told that we cannot afford the true cost of sustainable fashion (as we have been told that brands cannot afford the true cost of living wages). But as ever, we cannot afford not to act now. Before we move forward with this fashion-calendar-year, we must learn the lessons of this summer, and we must implement them now.

The Great Greenwashing Machine Roundtable Discussion

The Roundtable

September 8th marked the first in a series of roundtables designed to equip brands on fashion and current affairs in a transforming world, in partnership with Equiception and The Geneva Center for Human Rights. Livia Firth chaired a panel comprising legal, data and global value chain experts Auret Van Herdeen, Tone Skårdal Tobiasson, Dorothée Baumann-Pauly, Veronica Bates Kassatly, and David Perry of the Competition and Markets Authority, designed to address the realities of greenwash in today’s fashion landscape. The session was framed around the questions, ‘What does greenwashing mean today in the wake of escalating regulatory and consumer vigilance? And how can well-meaning brands navigate an environment of often opaque requirements?


The roundtable showed clearly how flawed data and one-size-fits-all LCAs are driving greenwash and malpractice and as well as highlighting the risks to fashion business by falling foul of emerging efforts to police ‘greenwash’, also offered plenty of corrective insights. You can watch the panel HERE, or pick up the highlights HERE.


But we close this issue with the final sign off from this Roundtable from Veronica Bates Kassatly, who elected to quote the fashion lawyer Allen Baer, ‘The key learning is, unless you and you alone, really can be sure that what you are doing is better for the environment, it is far too early in all this to start boasting about it in your marketing materials’.


If there is one single lesson that we all bear in mind, perhaps make it this one?

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