Following the conclusion of its investigation into the sustainability of the UK’s fashion industry, the Environment Audit Committee has published its final report, which seems to lack any concrete solutions that tackle the issue. The Committee’s recommendations are split into four themes, which feature very few immediate and practical steps for brands to implement to improve their environmental impact. Instead, there are calls for the UK government to amend legislation, conduct further research or improve the funding of regulatory bodies. All of this is unlikely to occur soon, given the current focus on Brexit, and may not make any real difference to the problem. The proposed 1p tax on garments, which has generated various headlines, is not sufficiently detailed and risks the growth of SMEs and those who are doing their bit to tackle sustainability issues.
Labour conditions
The practical recommendations which brands can implement, to improve their labour practices, are:
- engage with, and recognise, trade unions;
- textile retailers operating internationally should sign up to the Global Framework Agreements which put in place the highest standards of trade union rights and health & safety and environmental practices;
- retailers should invest in technology that allows them, and their customers, to track where their materials and products are sourced and made; and
- greater control should be exerted over subcontractors’ behaviour to ensure that corners are not cut along the supply chain.
The Committee recommends certain legislative changes to bring within their scope companies reporting on any human rights issues and to oblige large companies to perform due diligence checks across their supply chains. It recommends that the UK government publish a public list of all retailers who are required to produce a modern slavery statement, with an appropriate penalty for non-compliance. Clearly, the hope is that public opinion will then encourage good behaviour by retailers.
If such legislative changes are not possible, the Committee recommends the introduction of a Corporate Duty of Vigilance Law, which would require brands to implement an effective plan to address environmental, health and safety and human rights in their operations, and the operations of their suppliers and subcontractors.
Manufacturing standards
The practical recommendations which brands can implement, to improve their manufacturing standards, are:
- considering sustainability at the design stage is likely to be the most effective way of reducing the environmental impact of garments;
- using sustainably sourced materials and providing decent livelihoods to individuals within their supply chains; and
- being mindful of potential health risks to workers during the manufacturing process and reducing their exposure to airborne synthetic fibres.
Alongside these suggestions, the Committee recommends that the government reforms taxation to reward companies that design products with lower environmental impacts and penalise those that do not. The Committee suggests that all retailers should pay for WRAP’s Sustainable Clothing Action Plan (SCAP), which researches the impact of fashion consumption. Compliance with SCAP’s targets should be mandatory for any retailers whose turnover is more than £36 million.
The Committee suggests more research is needed to understand how design can be used to limit harmful emissions. Fashion retailers should be testing new synthetic garments for fibre release and publishing the figures of their findings. Fashion retailers, water companies and washing machine manufacturers should also collaborate to investigate the problem of microfibre pollution further. The report does not, however, go as far as recommending mandatory research, enforced by legislation.
The Committee also suggests that the government should investigate whether its proposed tax on virgin plastics, which comes into force in 2022, should be applied to textile products that contain less than 50% recycled PET to stimulate the market for recycled fibres.
Textile waste and collection
The practical recommendation which brands can implement, to improve textile waste, is reusing and recycling unsold stock, with incineration only being used as a last.
The Committee recommends that the government ban the incineration or landfilling of unsold stock that can be reused or recycled, and make fashion retailers responsible for waste by introducing an Extended Producer Responsibility scheme for textiles companies. Rewards and incentives should be given to companies that take positive action to reduce waste, alongside a new investment fund to stimulate the market for recycled fibres.
The Committee also suggests a tax of 1p per garment on producers, which could raise £35 million to invest in better clothing collection and sorting in the UK. The report does not give any detail as to the make-up of this tax, for example, whether it is a flat fee and whether it would take into consideration environmental efforts made by brands. This could be troubling for SMEs and those brands who work very hard on their sustainability practices.
Finally, it recommends that clothes alteration and repair lessons should be included in schools at Key Stages 2 and 3.
New economic models
The report discusses new business models, which are emerging within the retail industry, such as companies which rent clothing to customers. In order to encourage these types of businesses, the report recommends that the government should amend the tax system, for example by reducing VAT on repair services.
The Committee also suggests that retailers should: use their “market power” to demand higher environmental and labour standards from suppliers; offer rental schemes and lifetime repair services; and provide further information about the sourcing and true cost of their clothing.
Given the well documented and appreciated impact which the retail industry is having on the environment, there are disappointingly limited practical steps which brands can immediately implement to improve their sustainability practices. Instead, the report relies heavily on the government to legislate. The government will need to be mindful of any legislation which it implements, to avoid rendering any compliant companies at a disadvantage to their competitors or risking the business health of some brands.
Whilst the Committee and its investigation should be commended for drawing attention to the issue, the final report does not offer any tangible and effective solutions to the problem. Examples of solutions, which were discussed during previous hearings but hardly detailed in the report, were the scope and regularity of brands' auditing of suppliers; the nature of conversations between brands and workers' representatives; encouraging brands to share learnings with each other; and increasing consumer awareness of the sustainability issue.