Policy Paper in response to the Environmental Audit Committee’s call for evidence on fast fashion

“News to Reuse” and “I have a voice” submission to the Environmental Audit Committee’s inquiry on the progress made on the environmental and social impact of the fashion industry since the 2018 Fixing fashion: clothing consumption and sustainability. It was originally published here. A blog post on this issue is published on the Young Fabians blog.

Executive Summary:

1. “News to Reuse” is a youth-led anti-fast-fashion campaign that sits within the social enterprise “I have a voice”. The campaign aims to chiefly advocate for clothing companies to create product labels that inform customers about their clothes’ environmental footprint and the human rights conditions of workers in their supply chains. It is also working to educate young people about the consequences of fast fashion and include it in the National Curriculum.

2. According to the World Bank, the fashion industry comprises 10 percent of all global carbon emissions annually. Without intervention, emissions from the fashion industry  will increase by 50 percent by 2030. Furthermore, according to The Waste and Resources Action Programme, roughly 350,000 tonnes of clothes go into landfill each year. It is urgent that the fashion industry drastically changes the way it produces clothing, waste management systems do more to recycle textiles, and consumers are encouraged to avoid fashion as it is not sustainable. 

3. In light of the Covid-19 pandemic, we believe that supporting second-hand shops will benefit the UK’s economy and those households who have been particularly affected by the pandemic’s negative economic impact. On the one hand, the pandemic has caused an exceptional amount of fashion waste, with 73 percent of British fashion brands experiencing cancelled orders from wholesale partners. UK clothing sales fell by 34 percent in March 2020 alone, resulting in an unprecedented inventory crisis. On the other hand, the bottom three deciles of UK households have lost a significant amount of household income due to job losses and being furloughed. This makes it more difficult to afford suitable and warm clothes, especially as the winter season is approaching. We urge the Committee to call for the Government to allocate financial subsidies to second-hand stores and independent companies which focus on sustainable fashion in order to tackle fast fashion and fashion waste. Furthermore, companies should be required to either donate unsold stock for charity purposes, or recycle them for their future products. That way, companies will also receive an incentive to use textiles that can be well recycled. At the same time, this will ensure that the UK is shifting to a more sustainable economy and supporting the households hit hardest by Covid-19.

4. The Sustainable Clothing Action Plan is a key instrument for fostering the transition to a more sustainable fashion industry. Its revised version should consist of criteria defining a sustainable and ethical supply chain. The plan should also encourage companies to focus on educating the public, especially people under 35, on the impacts of fast fashion and its sustainable alternatives. Following other fashion companies, stakeholders of the plan should include QR codes on clothing labels that inform the consumer about the environmental impact and human rights conditions of workers. Benchmarking for measuring the carbon footprint of goods and human rights within the supply chain already exist and provide a useful starting point.

5. We have limited our response to those questions where we have evidence or views.
   

Q2. What impact has the pandemic had on fashion waste?

6. According to The British Council’s Institute of Positive Fashion and research undertaken by Oxford Economics, the Covid-19 crisis has led to 73 percent of British fashion brands experiencing cancelled orders from wholesale partners. Furthermore, UK clothes sales fell by 34 percent in March 2020 alone, resulting in an unprecedented inventory crisis. 

7. As retail stores depend heavily on seasonal fashion, the question arises as to what companies will do with the incredible amount of ‘deadstock’, meaning clothes that have not been sold. On the one hand, the pandemic has caused an exceptional amount of fashion waste. On the other hand, the bottom three deciles of UK households have lost a significant amount of household income due to job losses and being furloughed, which makes it more difficult for families to afford suitable and warm clothes, especially as the cold season is approaching.

8. News to Reuse urges the Committee to call for the Government to implement incentives to recycle and upcycle fashion waste and deadstock as it is a more urgent and pressing issue than ever before. We have included examples of how this could be achieved throughout our response.
   

Q6. What would be the most effective measures industry or Government could put in place to ensure that materials or products made with forced or prison camp labour are removed from the supply chain?

9. One idea that we have to ensure that no fashion companies make use of forced or prison camp labour within their supply chain is for all clothing labels to have a QR code. When consumers scan the code, they would be able to see in which countries the clothes were made, and in which factories. Over time, this could include a quality mark or rating system that provides consumers with assurance that the working conditions throughout the supply chain meet a pre-agreed definition of human and worker rights, e.g. number of working hours and whether it pays a living wage. Clothing companies such as Another Tomorrow or ASOS have already introduced the QR code on labels to inform its customers about the clothes’ country of origin, carbon footprint, and the story behind the design. The Corporate Human Rights Benchmarking Alliance provides a comparative snapshot year-on-year of the largest companies on the planet, looking at the policies, processes, and practices they have in place to systematise their human rights approach and how they respond to serious allegations. The results and methodology are made a public good for all stakeholders.

10. That way, consumers receive the opportunity to make informed decisions rather than relying on brand marketing and the cost of clothes. The majority of consumers would not expect their clothes to be made by forced or prison camp labour. It is our view that consumers will put pressure on fashion brands by moving away from those brands that are knowingly using factories with forced labour, or in regions known to violate human rights.

11. We believe in many instances this information is already available as advocacy groups have the ability to hold companies accountable on their actions based on publicly available and easily accessible information. For example, Uyghur rights groups have put pressure on clothing companies in July 2020 by publishing a press release and a list of companies who have benefitted from Uyghur forced labour. Jasmine O’Connor OBE, CEO of Anti-Slavery International said, “Now is the time for real action from brands, governments and international bodies – not empty declarations. To end the slavery and horrific abuses of Uyghurs, Kazakhs and other Turkic Muslim peoples by the Chinese government, brands must ensure their supply chains are not linked to the atrocities against these people. The only way brands can ensure they are not profiting from the exploitation is by exiting the region and ending relationships with suppliers propping up this Chinese government system”.

12. An independent public body comprised of elected positions, and people with experience in fashion as well as human rights should scrutinise the information that companies provide through the QR code. That way, the UK will uphold its responsibility to protect human rights internationally and not allow companies to make profit off of forced labour. Only if companies are being held accountable by the public through thorough audits and transparency for consumers will fashion brands feel the urgency to end supply chains connected with forced labour.
    

Q7. How can any stimulus after the Coronavirus crisis be used to promote a more sustainable fashion industry?

13. Firstly, “News to Reuse” is convinced that the Government needs to implement economic stimulus now. If financial incentives and support are provided after the economy has already suffered, it will reach people after they have already lost their jobs and businesses, and the economy has contracted significantly. Furthermore, the Government will have to invest even more, as the more damage will already have been done. As Carolyn Fairbairn, outgoing Director General of the Confederation of British Industry, said, “By the time you put in place all the sensible measures you might want, people will have already lost their jobs”.

14. People have been cleaning out their wardrobes during lockdown. As a result second-hand and charity shops have experienced a surge in donations up to the point where they had to stop accepting clothes due to a lack of storage. This is the right time for the Government to focus on supporting second-hand and charity shops in order to promote sustainable consumer behaviours. “News to Reuse” strongly believes that with the right financial support, second-hand shops can provide an effective way to promote sustainable fashion among a large part of society and fundamentally change the way we consume fashion.

15.  The Government can play a substantial role in facilitating a transition towards a sustainable fashion trend through stimuli such as significant rent reductions, no incidental wage costs, and free advertising space, for example on public transportation. These incentives could be reserved for second-hand and charity shops, as well as those retailers who can clearly demonstrate a commitment to sustainable fashion and with a very limited stock of fast-fashion. If these retailers have the means to offer their clothes at a competitive price, repair them if necessary, and advertise their stores prominently, we believe that charity and second-hand shops can become real competitors to major fashion companies. Research by the Ellen MacArthur Foundation suggests that “77% of the UK population wants to shop second-hand, but only 27% actually do”.

16. The Government should use similar financial incentives as introduced above, for independent stores or companies who offer to rent clothes in order to tackle fast fashion. As thousands of UK households have experienced a significant income loss due to the pandemic, renting clothes, especially for children, is a cost effective and sustainable way to approach fashion. Censuswide, on behalf of Barnardo, reported that in 2019, Britains would potentially spend £2.7 billion on clothing that will only be worn once. Many people still don’t feel comfortable wearing the same outfit twice, for example, if they had already worn it to a wedding. Many clothes are also bought to go on holiday, and Censuswide finds these clothes are never worn again. Renting clothes would counter this trend and encourage more sustainable behaviours while appreciating that some people might not want to repeat outfits for special occasions or in the case of young children they may grow out of them quickly. 

17. Government subsidies should only be given to those companies and shops who comply with at least one of the following criteria:

1. Predominantly producing fashion products using biodegradable (such as Pinatex), or recycled materials, or those with a low environmental impact such as Lyozell or bast fibres; selling predominantly second-hand items or renting out clothes.
2. Clothing companies who accept the return of clothes in order to recycle them. For example, companies such as H&M, Charles Tyrwhitt, and M&S already do this. However, big fashion corporations should be exempt from Government subsidies due to their high revenue. 

Companies would also need to show proof of an ethical supply chain; including no child labour, living wages, and sufficient breaks.

Q8. Is the Sustainable Clothing Action Plan adequate to address the environmental impact of the UK fashion industry? How ambitious should its targets be in its next phase?

18. “News to Reuse” does not believe that the current Sustainable Clothing Action Plan (SCAP) is adequate. The statistics mentioned in the plan are from 2007 and therefore outdated, and no measurable targets have been set.

19. We believe that the targets for the plan’s next phase should comprise the following: 

1. Gathering the latest evidence, and setting quantitative targets for companies to achieve within a certain timeframe. For example, companies wishing to be stakeholders should pledge to achieve zero carbon emission in the production of their clothing products within the next 20 years and provide evidence of the steps they are taking in their annual reports.
2. Stakeholders of SCAP should aim to use predominantly environmentally compatible fibres for their products. The steering and expert groups will be responsible for identifying which fibres fall under this category and setting the percentage of how much environmentally compatible fibres should be used in each product category. 
3. In order to incentivise fashion companies to become stakeholders of SCAP, Defra should grant certified sustainable labels for fashion companies that fulfill at least one of the points introduced in Q7.17. of this response, and that pledge to follow SCAP’s roadmap.

3. The project steering group’s category of “Public Understanding of Sustainable Clothing” should introduce projects that research how the public can be educated on sustainable clothing. We would particularly appreciate it if the steering group introduced presentations and workshops for high school students to learn more about sustainable clothing in order to change their consumption behaviour at an early stage. This age group will be the most effective to target, as currently, people aged between 18 and 34 throw away their clothes after wearing it fewer times than those aged 35 and above. At the same time, Deloitte reported that in 2019, “42 percent of millennials said they have begun or deepened a business relationship because they perceive a company’s products or services to have a positive impact on society and/or the environment; and 37 percent said “they have stopped or lessened a business relationship because of the company’s ethical behavior.” In conjunction with the global Friday for Future protests as well as our own perceptions representing Millennials and Generation Z, we strongly think that educating high school students on sustainable clothing as well as how to repair, reuse, and recycle clothes, will make a significant and long lasting positive impact. 
4. “News to Reuse” would also appreciate it if SCAP included a target for companies to publish information on the environmental impact and labour conditions within their supply chain on their clothes labels, as introduced in Q6.9. of this response.

20. The European Commission has established the Green Public Procurement (GPP) as a voluntary instrument to foster sustainable production, consumption, and innovation. In order for the GPP to be successful, the European Commission introduced verifiable environmental criteria for products and services in the public procurement process. The most recent updates have been made in July 2020 with its aim to continuously update the criteria according to latest research and innovations. Despite the UK leaving the European Union (EU) in 2021, “News to Reuse” urges Defra and the steering and expert groups to ensure the UK keeps pace with the EU GPP and its ongoing developments. This will ensure a level playing field for fashion companies across the European market and make it easier for UK companies to continue selling their clothes in multiple European countries. We believe that fashion companies would find it more efficient to sell their clothes in countries with similar quality standards, which the EU GPP aims to achieve. In light of Brexit and the UK’s ongoing trade negotiations with the EU, we see a risk that companies are less willing to sell their goods in the UK due to its potentially divergent environmental standards and the resulting higher costs.

Q9. What actions could the Government take to improve the collection of fashion waste?

21. “News To Reuse” appreciates that many UK councils have partnered with the charity Traid to collect used clothes in order to resell or recycle them in order to counter fashion waste. However, there are still major areas across the UK, especially in West England and north of Leeds, where Traid’s services are not represented at all. The Government needs to encourage more councils to further develop accessible public garment collection points in residential areas. That way, fabrics are not thrown away but kept in the system. 

22. While Traid puts a great emphasis on reselling clothes through charity shops, it lacks the possibility to reuse fabrics in the production of new clothes. The Government should offer fabrics for free to companies which will recycle them either through Traid or local councils. 

23. Furthermore, deadstock, as mentioned in Q2.7. of this response, is a major problem in the fashion industry. The UK should follow France in introducing a ban on throwing away unsold stock. Companies should be required to either donate these items for charity purposes, or recycle them for their future products. That way, companies will also receive an incentive to use textiles that can be well recycled.

Q10. What actions could the Government take to incentivise the use of recycled or reused fibres and materials in the UK fashion industry?

24. Production of recycled materials is more expensive than using new materials, therefore, the Government needs to implement financial incentives and policies that encourage companies to use recycled fibres for their production. One way is to give subsidies and allow tax relief to companies that use recycled garments for their fashion products. This could be financed by introducing a “fashion waste tax” on companies who sell their fashion products in the UK, but do not comply with the criteria outlined in Q7.17. of this response.

25. As mentioned in Q9 of this response, either on a local or a national level, governments should provide collected used textiles to companies which will recycle those fabrics for free.

Q11. How could an Extended Producer Responsibility scheme for textiles be designed to incentive improvements in the sustainability of garments on sale in the UK?

26. The UK Government needs to ensure that low tariffs apply on imports of sustainable materials and fashion products from the EU due to short transport routes and therefore low carbon emissions and well regulated labour rights across the EU.

27. The Government also needs to provide criteria on what defines a sustainable and ethical supply chain (such as low CO2 emissions, use of sustainble materials, no child labour, sufficient breaks during work and weekly working hours, fair payment, maintenance of industrial health and safety standards). The Government can then allocate funding and subsidies to stores and independent companies who comply with these criteria.

28. “News to Reuse” suggests that if fashion businesses are part of the Sustainable Clothing Action Plan as well as the Extended Producer Responsibility scheme, these companies and second-hand stores should receive a quality mark that allows consumers to make better and more informed decisions, as well as independent stores and companies to stand out and promote their products’ quality.

29. Producers should be given responsibility for either recycling their clothes or reusing them by donating them to second-hand stores, as opposed to them being able to externalise the environmental impact of their products. This can either be done through a partnership with local governments and Traid, as introduced in Q9 of this response, or through independent clothing collection points organised by the respective company or store. France translated a similar policy into law in 2006, and the European Parliament suggested a related idea in 2019. 

30. As introduced and outlined in Q7.16. of this response, the Government should provide financial incentives for companies and stores that offer to rent clothes in order to tackle fast fashion and for those following Government criteria regarding an ethical and sustainable supply chain.

31. “News to Reuse” would also like to see the same points as laid out in Q6 of this response in the Extended Producer Responsibility Scheme. Following other fashion companies, businesses should include QR codes on clothing tags that inform the consumer about the environmental impact and human rights conditions of workers. An independent public body comprised of elected positions, and people with experience in sustainable fashion as well as human rights should scrutinise the information that companies provide through the QR code.