by Fashion Declares & Bates Wells
Recent developments in sustainability legislation by the European Union (EU) and United States (US) impact the fashion and textile industry. Although opinions vary on this legislation’s effectiveness, the United Kingdom (UK) lacks its own cohesive regulatory framework. Therefore, there is an urgent need for effective policy recommendations to guide domestic legislation, learning from other experiences to ensure UK laws effectively incentivise sustainable, regenerative, and circular business practices.
This white paper builds on excellent research by various organisations in the fashion and textile industry, particularly:
The Extended Producer Responsibility (EPR) Sandbox Project, led by WEFT and QSA Partners with support from the UK Fashion & Textiles Association (UKFT), British Fashion Council (BFC), British Retail Consortium (BRC), and Innovate UK’s NICER programme.
WRAP has contributed expert research into EPR and established Textile 2030, the UK’s leading initiative supporting fashion and textiles businesses.
The Ellen MacArthur Foundation, Textile Exchange, Common Objective, and Fashion Roundtable have produced significant research and tools advocating for sustainable fashion.
We are encouraged by the recent establishment of the UK’s Circular Economy Taskforce (CET) and hope that this white paper will help foster a more collaborative approach amongst stakeholders in the fashion and textile industry and inform the CET’s decision-making.
About this white paper
We interviewed a wide range of stakeholders, including supermarkets, high street brands, exporters to Europe and the US, advocacy groups, and textile experts. With cross-sector support, these policies can transform the fashion and textile industry into an engine to build a circular and regenerative sector, helping the UK meet climate targets, create jobs, and enhance social impact.
Summary of proposed policy recommendations
We are proposing three key policy recommendations to help shift the fashion and textile industry onto a more sustainable and level playing field which are summarised below and set out in more detail in the attached full document.
We suggest that all of these should be enacted together as part of a holistic and systemic approach:
The de minimis customs threshold on imported purchases should be reduced to zero. This is currently being used by overseas fast fashion brands as a loophole to avoid tax. It is prompting a race to the bottom in terms of pricing and is effectively pushing sustainability off the agenda for many British fashion brands. Further work should be undertaken on how to protect small and sustainable firms from being penalised by the removal of the de minimis threshold. For example, in the short term this could initially apply only to large companies based on number of employees or turnover. However, a more permanent solution lies in updating global tariff codes and aligning import duty to a ‘harm’ based taxonomy (see point 3). Customs or VAT relief could then be offered on those products that achieve best practice in ethical and sustainable production.
The UK should mandate an Extended Producer Responsibility (EPR) for all textiles in the UK with fees tiered according to a product’s circular design, durability, fibre composition and production methods. The fees should be ring-fenced to fund the infrastructure needed to create a circular economy. The EPR system should be simple and flexible for brands to adopt. The monetary incentive should be significant enough to encourage brands to engage with circular design practices rather than to ignore it and/ or see it as a problem to circumvent. Fees should be used to fund a holistic range of solutions, including community clothing hubs in high streets across the country focused on educating and developing skills around the repair and reuse of clothes.
The UK should mandate a Digital Product Passport (DPP) system. It should leverage its position as a global data and tech leader to drive standardisation of data and enable the easy flow of fashion related data internationally. This could ensure scanning a simple QR code could be all that is required to determine any EPR fee or customs duties to be paid on a product. We argue the data should be organised according to a ‘harm’ taxonomy/classification of clothing and textiles. Longer term, this information could be translated into a simple traffic light system for consumer labelling on clothing to drive better purchasing decisions and eliminate greenwashing.
For the WHITE PAPER – please download HERE
There will be meetings to develop further and drive this process – if your organisation would like to be involved, please email: info@fashion-declares.org
