More than 900 farmers and farmer alliances from around the world have signed a letter to the European Council expressing their overwhelming concern that the environmental footprint-substantiating methodology underpinning its proposed green claims directive “unfairly” favors synthetic and fossil fuel-derived materials over natural fibers, posing what they say is a “significant risk of injustice” to those whose livelihoods depend on the production of the latter.
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The letter was made public just as the European Council recommended the use of the Product Environmental Footprint, or PEF, to evaluate the environmental impacts of apparel and footwear—despite what appeared to be its abandonment last year by the European Commission due to the absence of indicators such as durability, repairability, recyclability, microplastics and use of natural content.
In a general approach that it posted on Monday, the European Council agreed that the PEF should be employed to substantiate environmental claims “especially” where PEF category rules have been established, such as with apparel and footwear, albeit with a caveat. If the PEF method doesn’t yet cover an impact category deemed relevant for a product group—say, microplastics in textiles—the adoption of category rules should take place “only once these new relevant environmental impact categories have been added,” it said.
But farmers in Australia, India, Mongolia, South Africa, the United Kingdom and the United States say they worry that the methodology’s so-called “inadequacies” when it comes to sussing out the environmental performance of agricultural products will enable greenwashing by fast fashion brands that typically opt for cheaper and more abundant synthetic materials. They say that while they support meaningful sustainability labeling for clothing, they’re not involved in the voting process because of the “prohibitively” high cost of membership in the technical secretariat for PEF category rules for apparel and footwear.
“My farm has grown wool for more than 1,000 years [and] it looks as it does today because of that,” said Lesley Prior, principal of Tellenby Superfine Merino in Devon, England. “If the EU ratifies [the] PEF, wool products will be seriously disadvantaged, even forced to carry a ‘red’ label. What brand will risk this? My farm and my care for this precious environment will end if no one wants my wool, and the synthetic textiles industry will be the winner.”
While the technical secretariat, which the then-Sustainable Apparel Coalition convened at the invitation of the European Commission, declined to comment on the letter, it said that the category rules for apparel and footwear, which are based on life-cycle assessment methods, are still being developed, and that the “most influential factor” determining the impact of natural and synthetic fibers is defined by the European Commission’s environmental footprint database, which was independently developed with the assistance of international experts and peer reviewers.
The technical secretariat also comprises “many stakeholders,” including organizations that represent natural fibers and their producers, such as the Alliance for European Flax Linen & Hemp, Cotton Inc. and, until recently, the International Wool Trade. All decisions are adopted either by consensus or a vote, meaning that “these organizations contributed actively to the outcomes of decisions,” it said.
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The issue recalls a similar tension that played out over the then-SAC’s Higg Materials Sustainability Index, a.k.a. Higg MSI , which critics said promoted synthetic materials as better-for-the-planet options at the cost of their natural counterparts—something that the multi-stakeholder organization now known as Cascale denied. A bigger problem turned out to be a scarcity of comprehensive—not to mention current—data, which resulted in generalizations about a material’s sustainability that stoked the ire of regulators such as the Norwegian Consumer Authority. Cascale has since dropped its plans to use the MSI as the basis of a consumer-facing labeling scheme . Neither will it be used as a stand-alone tool without the context that other primary data-gathering Higg tools such as the Facility Environmental Module can offer.
Supporters of the PEF, such as Andrew Martin, executive vice president at Casacle, say there is a need for a “clearly defined framework based on clear scientific foundations,” without which there would be a fragmentation of regulatory implementation in the world’s largest single market. Since last January, for instance, France has required apparel purveyors with an annual turnover exceeding 50 million euros ($53.7 million) to have verified environmental labeling. Smaller companies will soon have to follow suit.
“As the PEF continues to evolve, the positive impacts will only grow,” Martin said. “Developed collaboratively and democratically, with a cross-representation of industry experts, the PEF remains the most comprehensive and scientifically robust framework for assessing the environmental impact of products. By reducing inconsistencies in life cycle assessments, it provides a reliable foundation for making informed and credible sustainability claims.”
Others disagree. Besides individual farmers, the letter to the European Council includes some prominent organizations, including Fibershed, the Sustainable Fibre Alliance, The Sourcery and model Arizona Muse’s Dirt Charity.
“For me, it’s not a question of fibers or materials, but a question of consumers being misled by a tool of the EU’s own making,” wrote sustainability consultant Tanja Gotthardsen on LinkedIn on Monday. “The inclusion of [the] PEF is truly premature, as it does not account for how apparel is actually, functionally worn and used—and use is, by far, the most important indicator for a garment’s environmental impact.”
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