RREUSE Response to the Public Consultation on the EU Strategy for Sustainable Textiles

As an international network of social enterprises active in re-use, repair and recycling, collectively handling around 260,000 tonnes of used textiles annually, RREUSE awaits the publication of an EU Strategy for Sustainable Textiles with anticipation. We believe that developing eco-design requirements for textiles will be a milestone in the development of products that are fit for a circular economy. To ensure textile products still hold value when reaching the second-hand market, the first step is to make them as durable as possible.

The three pillars of sustainability, including environmental responsibility, social inclusion and economic viability, developing a Strategy for Sustainable Textiles in cooperation with social enterprises – operators in the social economy whose primary objective is to have a social, societal or environmental impact over profit – would be particularly meaningful. This would present considerable opportunities to create local, green and inclusive jobs in the EU. According to recent social enterprise estimates, collecting and sorting 1.000 tonnes of textiles with a view of being re-used is creating between 20 to 35 jobs.

RREUSE wants to ensure that the EU Strategy for Sustainable Textiles does not focus on recycling but instead prioritises activities related to waste prevention and preparation for re-use of waste textiles. To promote the implementation of a strategy that truly implements the waste hierarchy and fosters the creation of meaningful employment and training opportunities, RREUSE calls on the Commission to implement the following recommendations:

• Help social enterprises active in the collection, sorting and resale of post-consumer textiles to safeguard and develop their activities
• Before encouraging consumers to purchase “sustainable” new textiles, support them to repair or purchase second-hand textiles in the first place
• Provide consumers with sufficient information about the negative impacts of purchasing new textiles, as well as about the positive environmental and social impacts of repairing or purchasing second-hand textiles instead
• Ensure that EPR schemes do not threaten social enterprises’ activities, notably through developing waste prevention and waste management targets following the waste hierarchy alongside social objectives
• Make textile products longer lasting, with less complex fibre blends (facilitating both re-use and recycling) and with standardised sizes
• Finance and facilitate the development of collection systems for post-consumer textiles
• Develop skills related to the prevention and sustainable management of waste textiles
• Avoid considering that investments in R&D and treatment facilities are only needed in the recycling sector (they are also needed for textile waste prevention and preparing for re-use)
• Ensure that the development of new business models do not compete with re-use operators and with consumers and independent repairers’ right to repair
• Clarify the end-of-waste status in a way that facilitates collection and helps prioritise re-use over recycling
• Severely sanction producers/designers of products that are non-compliant with EU’s legislative requirements (e.g. the same way planned obsolescence is sanctioned in France)
• Control and measure (rather than limit) the export of post-consumer textiles for re-use, reducing administrative burden while ensuring that the waste hierarchy is respected

In addition to these demands and those that can be found in the “Recommendations for the EU Strategy for Sustainable Textiles” developed by the Wardrobe Change Coalition (of which RREUSE is a member) and in “The Civil Society Shadow European Strategy for Sustainable Textile, Garments, Leather and Footwear” (co-signed by RREUSE and a number of its members), 

Picture credit © Cooperativa Sociale Insieme