why the government's new policies won't make fashion sustainable
The clothing industry is unarguably exploitative, highly wasteful and a major contributor to climate change. However, effective legislation to address these issues has been frustratingly lacking so far. Government has instead preferred to rely on voluntary industry initiatives that deliver only incremental change, falling far short of the transformative action needed.
Happily, new governance for the industry is being actively considered by policymakers. This year, DEFRA consulted on a new Waste Prevention Programme aimed at reducing the environmental impacts of the textiles industry. An Environment Bill expected to become law during this parliamentary session will enable government to force companies to switch to more sustainable production.
This represents a welcome change in tone from a government which in 2019 rejected the Environmental Audit Committee’s proposals to ‘fix fashion’.
But the new policy framework fails to grapple with the systemic nature of the challenge of reforming the clothing industry. DEFRA’s proposals still rely on voluntary industry action. What’s more, policy proposals overlook the fundamental problem of massive overconsumption of clothing, which has become a defining feature of fashion in the twenty-first century. Also absent from the agenda are garment workers’ rights, despite calls from the industry itself to tackle exploitation.
Why is legislation the only sure way to make fashion sustainable?
Without legislation, we’re reliant on voluntary industry action. Its downfall is that targets set by industry are seldom sufficiently ambitious. And the voluntary nature of schemes means no real sanctions result for companies which don’t make good on their commitments. The Sustainable Clothing Action Plan (SCAP) – backed by DEFRA – asked signatories to commit to a modest waste reduction target of -3.5% by 2020. Participants achieved just -2.3%, but faced no repercussions for not meeting the target.
Voluntary action has defined success in terms of reducing environmental impact per item of clothing – improvements often cancelled out by the increasing volume of garments produced. SCAP participants agreed to reduce both carbon and water footprints by 15%, per tonne of garment sales. ASOS was among the signatories, but the brand’s growth meant that its absolute carbon and water footprints are likely to have increased substantially: ASOS reported that in 2018/19, total carbon emissions grew by 14% compared to the previous year.
It is true that voluntary programmes have delivered some real achievements: Under SCAP, Whistles switched to BCI cotton, a change which contributed to a 70% reduction in water footprint. Even so, opt-in initiatives simply do not go far or fast enough to address the gravity of the environmental degradation caused by fashion.
For their part, consumers favour government intervention (Figure 1). While they want to buy clothes that are sustainable, finding affordable and accessible options isn’t easy, and consumers know that greenwashing can make identifying truly sustainable clothing difficult.
Figure 1 – Public opinion on the role of government. Source – Fashion Revolution, 2020
what is the government proposing?
The government has backed a new voluntary agreement, is consulting on an Extended Producer Responsibility (EPR) scheme, and may use the Environment Bill to force industry to adopt more sustainable design practices.
The true test of the value of the government’s approach is whether it will resolve the greatest environmental sins of fashion: its contribution to global warming through carbon emissions, its untenably high demands on natural resources such as water, the wasteful ‘throwaway’ culture of fast fashion, and the tiny proportion of used clothing that gets recycled.
Carbon emissions and demands on natural resources will be tackled by a new voluntary scheme, ‘Textiles 2030’ , led by WRAP and launched in April 2021. Participating companies have pledged to reduce GHG footprints of their new products by 50% and water footprints by 30% by 2030. Importantly, this means cutting aggregate reductions, a critical improvement on SCAP. Yet depending on a voluntary agreement is risky. DEFRA’s talk of ‘encouraging’ industry to become more resource-efficient leaves room for the least responsible companies to continue business as usual. And companies that fail to meet targets could go unpunished.
Textiles 2030 also targets the problems of waste and miniscule clothing recycling rates, which are responsible for much of the environmental impact of fashion (figure 2).
Figure 2 – Global Material Flows for Clothing Source – Ellen McArthur Foundation, 2017
Participants have agreed to move towards circularity, through an increase in use of recycled materials and experimentation with circular business models. However, no quantified targets on circularity have been published to date.
Another policy tool that aims to reduce waste and promote circularity is an Extended Producer Responsibility (EPR) scheme for the textiles industry. This is currently under consultation. An EPR could promote greater longevity of clothing by fostering design for longer clothing lifespans, tackling one of the biggest problems with fashion: cheap fast fashion simply isn’t designed to last, and clothes are often worn only ten times before being discarded. Such a scheme could also be used to scale up used clothing collection services and increase fibre recycling rates, while supporting circular business models such as clothing rental.
The goals of the EPR are commendable: designing clothes for longevity, and collecting and recycling them at the end of their longer life would go a long way to reducing fashion’s environmental footprint. However, detailed requirements of producers under an EPR are not yet known and the consultation text refers to ‘encouraging’ and ‘supporting’ producers to improve. This implies that an EPR could turn out to be a soft option.
The EAC recommended harder measures in 2019, including a ban on landfilling and incinerating clothes, and a tax to fund recycling. Additionally, the timeframe for an EPR is disappointingly slow with consultation with stakeholders not due to be completed until the end of 2022.
The government does have one further policy tool in hand with sharper teeth – an Environment Bill. Currently progressing through the House of Lords, this bill includes clauses that will enable the setting of compulsory product design and information requirements. These powers could force, rather than encourage, companies to design fashion for longevity and oblige them to inform consumers of the environmental footprints of their purchases. However, this is a power that government appears to be holding in reserve, to be used only if all else fails. Meanwhile, the bill has been criticised by leading environmental groups for its lack of specific and binding measures to protect the environment.
Worryingly, none of the government’s policy tools fully address the unsustainable growth in demand for fashion. One reason why clothes are often quickly discarded is that poor quality means that they wear out quickly, but it’s far from the only reason. Consumers’ desire for novelty, facilitated by frictionless online shopping and cheap prices, is a key factor. Overall, the volume of clothing sold in the UK has risen relentlessly over time, bar a dip in 2020 due to coronavirus. It is projected to reach over 4.5 billion pieces by 2025, up from 3.9 billion pieces in 2012. This unsustainable growth in production underlies the environmental disaster of fast fashion. Policymakers need to consider not only how to design clothing for longer life and how to drive up recycling rates, but also how to ensure less clothing is produced in the first place. We cannot recycle our way out of the environmental and social disaster of fast fashion.
wages and conditions for garment workers
Environmental sustainability is inseparable from social sustainability. The EAC’s 2019 report drew attention to a list of abuses here in the UK, including illegally low wages, hostility towards trade unions, and serious breaches of health and safety laws. The EAC recommended a more proactive approach to the enforcement of the national minimum wage and recognition of workers’ unions, but little action has been taken since.
A group of fashion retailers and the British Retail Consortium calculated in 2020 that exploited garment factory workers are being denied £2.1 million a week by wages that fall below the legal minimum. This was followed in April 2021 by calls from ASOS for the implementation of mandatory human rights due diligence legislation in the UK, in order to strengthen the 2015 Modern Slavery Act. That a fast fashion company, not government, has taken the lead on this issue is telling.
The EU, meanwhile, has passed a resolution to enforce human rights due diligence throughout the global supply chains of European companies. Noting that multinational companies have been encouraged to take responsibility for their supply chains on a voluntary basis, the European Parliament has concluded that ‘the voluntary approach is not enough’. In fact, half of European companies fail to meet any of the five basic criteria for human rights due diligence, based on the UN Guiding Principles on Business and Human Rights. The resolution aims to level the playing field, since companies doing the right thing are currently at a competitive disadvantage.
NGO The Circle in April 2021 called on the European Union to go further still and ensure that garment workers in global supply chains are paid a living wage. Minimum wages in many countries are nothing more than poverty wages that do not provide for a basic decent life. Given that most clothing sold in the UK is produced in Asian countries, confronting worker exploitation globally is necessary for clothing sold here in the UK to be socially sustainable.
what does this all mean?
Overall, the government’s new policy framework has strengths: it acknowledges the scale of the environmental challenge, and the corresponding need to reduce GHG emissions and demands on natural resources, while extending the lifespan of clothing and enhancing recycling. Policies have been built around the right set of goals.
Even so, the government’s approach is simply not rigorous enough. To make a real difference, we need policymakers to implement binding targets for reductions in emissions and water usage, ban landfilling clothing and make producers adhere to ambitious waste reduction targets. Instead, too much rests on unenforceable voluntary programmes and the ‘encouragement’ of a circular economy approach. The government still seems reluctant to take the action necessary to stem the ecological catastrophe of fast fashion.
The lack of action by UK government to tackle garment workers’ right to fair pay and decent working conditions is inexcusable, particularly given demands from industry itself to tackle these egregious practices.
Unless policymakers think again, the structural problems that define the fast fashion industry will persist. The system is predicated upon cheap labour and resource extraction. Government must deliver radical change now.
