Everything You Need to Know About the Current State of Sustainability in Fashion: EAC 2019 Report

A Review of the Environmental Audit Committee’s 2019 Report: “Fixing Fashion”

Is fashion broken? The Environmental Audit Committee thinks so. The language used in their February 19th report, “Fixing Fashion: Clothing Consumption and Sustainability,” is nothing short of apocalyptic. “This is an ecological, economic and social disaster,” they write (29). “Fashion shouldn’t cost the earth” (3). The scariest part of this apocalyptic portrait is the fact that it’s not exaggerated or overdramatised; it’s true. The way we are currently making and disposing of clothes has serious negative effects both on garment workers and on the environment. The solutions recommended in this report are positive and necessary steps toward fixing an industry that is inherently broken. Below we investigate the EAC report: the problems it identifies, the solutions it proposes, and question of where we go from here.

Introduction: Fashion and Sustainability

Fashion is a huge industry and one that actually outperformed all other markets in terms of profitability between 2003 and 2013. Unfortunately, it is also a market engaged in a “race to the bottom in terms of wages and environmental standards” (6). The rise of “fast fashion” has been celebrated as making fashion more democratic and accessible than ever before; however, it has also contributed to a rise in low-quality goods and a sense that clothing is disposable. What is needed is a “cultural change,” according to Professor Tim Cooper as the consumer mindset must shift away from a demand for cheap short-lived garments toward more sustainable solutions (10).

As populations rise, the Pulse of Fashion Report projects that by 2030, global apparel consumption could rise 63% (from 62 million tonnes today to 102 million tonnes) (9). The path we are on will have major consequences for wildlife and communities around the world. The fashion industry needs to change now if the UK is to meet the United Nations’ 17 Sustainable Development Goals. This report is especially clear on one message: “The fashion industry’s current business model is unsustainable” and “we need to fix fashion” (11). The remainder of the report explores how we can do that.

Chapter 2: The Social Cost of our Clothes

Problems identified: The garment production industry has historically been characterised by corner-cutting and “chasing the cheap needle” (sourcing clothing production from countries with low labour costs). Most garments sold in the UK were made in Asia, and “a 2016 report into Corporate Leadership on Modern Slavery found that of 71 leading retailers in the UK, 77% believed there was a likelihood of modern slavery occurring at some stage in their supply chains” (12). The abuse of foreign labour especially impacts women and girls who face the brunt of exploitation. The Rana Plaza disaster of 2013 (an incident in Bangladesh in which a building collapsed, killing hundreds of garment workers inside) is symptomatic of a lack of regulations with regard to production factories.

In part, the problem is caused by the fact that retailers demand unrealistic prices from suppliers that compete to offer the lowest prices and shortest lead times. This unrealistic demand directly contributes to corner cutting in terms of worker wage and welfare. This demand for low prices will only become more extreme as many UK retailers revealed they were not prepared to adjust their prices in response to exchange rate fluctuations after Brexit. Garment workers’ access to trade unions is minimal and they are often without any real power to negotiate their wages. Corporate Social Responsibility (CSR) programs which are voluntary and non-binding have overwhelmingly failed to address this issue.

On UK soil, there is also a shocking amount of labour exploitation, especially in factories in Leicester. The report suggests online retailers are playing suppliers against each other in an effort to drive down costs. A 2015 study found that some factories in Leicester were not paying their workers the National Minimum Wage. The exploitation of these workers is an open secret among local and national Government and among retailers, who often pit suppliers against each other in order to drive pricing down. However, the HMRC has done little to enforce the issue. The current level of fines for not paying the minimum wage does not offer a strong enough incentive for companies to comply and inspections rarely occur.

The Ethical Trading Initiative (ETI) “is an alliance of companies, trade unions and NGOs that promotes respect for workers’ rights around the globe” (18). Since signing onto ETI, companies such as Missguided have reduced the amount of factories in Leicester producing their goods from 80 to 11. However, other companies such as Boohoo have failed to sign onto the ETI, claiming that they are “struggling to see where the benefits would be to some of our suppliers” and noting that they “are not doing anything differently from the ETI” (19). However, this was later found to be false as Boohoo were refusing to engage in negotiations with Usdaw (Union of Shop, Distributive and Allied Workers).

Solutions proposed: The Modern Slavery Act of 2014 currently requires companies to disclose the steps they have taken to ensure they are employing no forced labour. However, concerns have been raised that the Public Accounts Committee (PAC) does not monitor whether these statements actually comply with legislation and has never actually penalised companies that haven’t complied. This Act needs to be strengthened. It needs to demand a higher level of transparency from companies and it needs to actually penalise companies that don’t comply. One way of increasing transparency would be for the Government to publicise a list of all the retailers required to make a modern slavery statement.

The Companies Act of 2006 is also ineffective. It requires companies to make a statement on human rights issues “only ‘where necessary for an understanding of the development, performance or position of the company’s business.” (24). This act needs to be updated to include explicit references to “modern slavery” and “supply chains.” These statements must also become mandatory rather than voluntary for companies.

As further measures, the HMRC’s National Minimum Wage team needs greater funding in order to increase their inspection and detection work. The report suggests that the Financial Reporting Council (FRC) Corporate Governance and UK Stewardship Code should amend its rules to require modern slavery disclosures by 2020. The report also recommends that retailers operating internationally should sign onto the Global Framework Agreements (a series of standards regarding trade union rights, health, safety and environmental practices).

The report is right to condemn the insufficiencies of the Modern Slavery Act and the Companies Act. A greater level of transparency would certainly be a step in the right direction. However, it is important that as the requirement to disclose reports of modern slavery becomes more stringent, these are also closely monitored. Transparency is only half the battle; the other half is following through on consequences for companies that fail to comply.

Chapter 3: Fashion’s Environmental Price Tag

Problems identified: Every piece of clothing has an environmental cost. That cost usually takes the form of CO2 emissions, water waste or pollution and destruction of land. Textile production creates a significant amount of CO2, contributing to climate change. The production of natural fibres can lead to deforestation and biodiversity loss. For instance, cotton production near the Aral Sea in central Asia has diverted so much water that the area has been renamed the Aralkum Desert.

Both natural fibres and synthetic fibres are environmentally problematic for different reasons. Producing natural fibres, such as cotton, requires the use of land, water, feed and chemicals. Organic cotton is one sustainable alternative. Synthetic fibres such as polyester (PET) are usually made from plastics, meaning they have less of an impact on water and land, but emit more greenhouse gases. Recycled PET (rPET) is one solution to excessive plastic waste. Still, new virgin plastics are significantly cheaper than rPET. This means there is minimal market demand for rPet.

Another environmental issue is microplastic pollution. The emission of microplastics during garment production is harming factory workers and emission during garment washing is polluting oceans. It is certain that some textiles shed microfibres a lot more easily than others; therefore, this problem is best solved at the design stage, as designers consider weaving more environmentally-friendly textiles into their original designs.

However, we need a lot more research before we can say which textiles are best. It is important that we avoid a reactionary jerk from synthetic to natural fibres as we don’t yet know the extent to which natural fibres are capable of polluting. Different measurement standards (such as the Higg Material Sustainability Index and MADE-BY Fiber Benchmark) have been introduced to measure the environmental costs of different fabrics. Still, there is concern about what these measurement systems do and do not include.

Solutions proposed: The Sustainable Clothing Action Plan (SCAP) was launched in 2012 by the Waste & Resources Action Programme (WRAP) as a voluntary framework for companies to reduce their carbon, water and waste impacts. Although some companies have signed on, the report suggests SCAP targets should be made mandatory for all retailers with a turnover of over 36 million as part of a new Extended Producer Responsibility scheme (this EPR scheme is discussed in more detail in Chapter 4). SCAP is also in need of more funding to become more accessible. Finally, the report calls for SCAP ambitions to increase and to focus more on production and supply-chains rather than just end of life issues.

The report recommends that the Government provide tax breaks that incentivise the use of organic cotton and rPET so that sustainable materials are more affordable. The Government should also accelerate research into the performance of different materials regarding microfibre pollution. The Government is already planning to implement a tax on virgin plastics in 2022; it should, therefore, consider whether this tax should be extended to textiles. Finally, it should adopt the EU Design Directive (an aim to create a more circular economy through product durability and recycling) into its upcoming Environmental Act.

Again, this investigation has proven that voluntary measures are failing to address the current unsustainable state of the industry. Therefore, the recommendation to make SCAP mandatory is a good one. Still, the report is vague on how to address the issue of SCAP’s funding cuts. In its recommendations, it notes that “The Government must ensure that WRAP’s Sustainable Clothing Action Plan (SCAP) is adequately funded” (38). It also notes that “To ensure the scheme continues we recommend that retailers pay for the funding of SCAP” (38). Although these ideas are not necessarily mutually exclusive, confusion about funding responsibility is escalated when the report notes that the British Retail Consortium has called on the Government to fund SCAP (38). Future legislation should clarify where the monetary responsibility for the funding of SCAP lies in order to ensure that the funding is actually generated.

Finally, the recommendation that the Government should consider including textiles in its 2022 tax on virgin plastics is far too tenuous. Given the fact that PET is used in approximately 60% of our garments and that this quantity has doubled since 2000, a tax on virgin polyesters is certainly warranted and undoubtedly necessary.

Chapter 4: Textile Waste and Collection

Problems identified: Clothing consumption in the UK is higher per capita than any other European country. As fast fashion is leading to an increase in cheap short-lived garments, more and more clothes are ending up in landfills or incinerated. One key way to reduce this environmental footprint would be to promote the repair of garments we already own. The problem here is that the general public aren’t motivated or skilled enough to repair their clothes. Overall, there is a dire need for education, both in terms of showing the public the importance of sustainability and teaching them the skills to repair their own garments.

The second-hand clothing industry is also a positive step towards reducing garment waste. In 2017 charity shops diverted 330,000 tonnes of textiles from landfills (44). While there has been an increase in clothing donation, this has not been matched by an increase in market demand for second-hand clothing. The issue of oversupply will only increase if countries such as China start matching the UK’s supply of used garments (a target they are on track to reach). An unwanted oversupply of used garments means these garments will either be exported to developing nations (affecting the cultures and economies of these nations) or incinerated, generating CO2 emissions, air pollutants, and microfibre emissions.

In order to recycle these textiles, the UK needs a large-scale textile recycling infrastructure that does not currently exist. Many textile recyclers have been pushed into bankruptcy because of oversupply. The UK has a community of artisans and small businesses that upcycle used textiles. However, there is no formal system for them to acquire used textiles. Charity shops often find it easier to send garments to “the ragman” (incineration or exportation to developing countries) than to develop a relationship with upcyclers.

Pre-consumer waste is another problem. When clothing patterns are cut from textiles, as much as 15% of the fabric can be wasted. While there is a moral impetus for companies to recycle that material into other garments, there is currently no legal requirement.

Solutions proposed: One solution is increasing education regarding why and how to repair garments. This report proposes that such lessons be introduced at Key Stage 2 and 3 of the National Curriculum. Still, the main takeaway from this section is the recommendation for a new EPR (Extended Producer Responsibility) scheme.

The report notes that “clothing companies are not yet required by legislation to take responsibility for end of life recovery of the products they put on the market place, unlike electrical and electronic goods” (45). An EPR would change that, forcing fashion retailers to take responsibility for the pre-consumer and post-consumer waste they generate. The proposed EPR includes a levy of 1p per garment (which could raise over £35 million a year) to improve the textile recycling infrastructure in the UK. This money would go directly into supporting the collection, processing and sorting of used clothing.

The 2011 Government Review of Waste Policy promised to review the amount of textiles being sent to landfills. However, it never followed through. The Government’s 2018 waste strategy, Our Waste, Our Resources: A Strategy for England, has promised to consult on textile waste by the end of 2025. The report is clear: this promise is “too little too late” (49).

On that count, they are right. The UK is in desperate need of an EPR scheme for clothing. In 2007, a similar scheme was introduced in France. Since then, “The scheme has nearly trebled clothing collection points from 15,621 in 2011 to nearly 42,000 by 2016 and collection rates have increased by more than 50%” (46). Further, the scheme has created 1,400 new full-time jobs. An EPR scheme in the UK is clearly a vital step towards fixing fashion.

Chapter 5: New Economic Models for the Fashion Industry

If sustainable clothing is to ever be the default purchasing option, the Government needs to level the cost discrepancy between sustainable and unsustainable clothing. It can do this by taxing materials with high CO2 emissions and rewarding the upcycling of textile waste. It should also reduce VAT rates on repairs and incentivise companies to offer repairs as part of the initial purchase.

Retailers should adopt new models that support a circular rather than linear economy. Models like this might include hiring or renting clothes to customers or allowing them to subscribe. These sharing models are important because they maintain the excitement involved in purchasing new items while eliminating the waste. Fast fashion has been celebrated as making the industry more democratic; sharing and subscription models keep that level of accessibility. In this way, “we can reduce consumption while still promoting growth” (54).

The “Fixing Fashion” report from the EAC is a bold and comprehensive step towards reforming the fashion industry. Its recommendations for legislation are extensive and certainly overdue. Still, it is worth noting that these are just recommendations. Acknowledgement does not always equal legislative change. When the Government promised to review textile waste policy in 2011, a review was never actually completed. How can we ensure the Government follows through on these recommendations? If the report celebrates consumers who pick up a needle and thread to mend the rifts in their own garments, how do we as a society pick up the collective needle and start to mend our broken fashion industry? We have to make sure that this report is not forgotten. We have to keep talking about the issues: about labour exploitation, environmental pollution and waste. We must hold the Government accountable for its promises in a public discourse. Most importantly, we must change our mindset. We must stop viewing clothing as cheap, short-term and disposable and start seeing the labour value and environmental value in everything we wear.

Environmental Audit Committee. (2019). Fixing Fashion: Clothing Consumption and Sustainability (Report No. 16). Retrieved from https://publications.parliament.uk/pa/cm201719/cmselect/cmenvaud/1952/report-summary.html

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