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Australian Wool Innovation Ltd

AWI

Australian Wool Innovation (AWI) is a not-for-profit, industry services organisation that conducts research, development and marketing along the global wool supply chain on behalf of Australian woolgrowers that help fund the company.

Lobbying Activity

Response to Circular Economy Act

4 Nov 2025

We welcome the Commissions ambition to accelerate Europes transition towards a circular and regenerative economy and to strengthen the Single Market for sustainable products. As representatives of the textile sector, we strongly support this goal. The Circular Economy Act provides an opportunity to make the textile system truly circular and regenerative - keeping products and materials in use while allowing them to also safely return to nature. To achieve this, the Act should integrate both technical and biological circularity, recognising renewable, biodegradable and regenerative materials such as wool as essential to eliminating waste and restoring natural systems. Circularity in textiles must address not only product efficiency and recycling but also overproduction and overconsumption. Without tackling the overall throughput of materials, even the best recycling systems cannot deliver sustainability. The Circular Economy Act should therefore promote sufficiency and longevity - encouraging the design, production and use of fewer, higher-quality garments that last longer and retain their value. Reducing waste at its source is the most effective way to strengthen Europes resilience and competitiveness while supporting the goals of the Green Deal. For textiles, keeping products in circulation at their highest value for as long as possible is crucial. High-quality, durable garments that maintain comfort, functionality and aesthetic appeal are more likely to be cared for, repaired and reused. Natural fibres such as wool exemplify these qualities: breathable, elastic and comfortable, they provide long-lasting wear and support emotional attachment that keeps garments in use longer. Circular design should prioritise such qualities. Minimum recycled content targets should not compromise performance or longevity, as this risks increasing rather than reducing waste. A complete approach to circularity must also include the ability of materials to safely return to nature. Renewable natural fibres, when managed responsibly, are biodegradable and can contribute to soil health and biodiversity. The Circular Economy Act should therefore recognise biodegradability, renewability and regeneration as fundamental enablers of circularity, on equal footing with reuse and recycling. End-of-waste and product criteria should reflect these biological processes to ensure that circularity strengthens, rather than replaces, natural cycles. A just circular transition in textiles must also consider social and economic aspects. Renewable fibre systems such as wool support rural livelihoods, landscape management and traditional skills in Europe and globally. Recognising these contributions would align the Circular Economy Act with the EUs social and environmental objectives, strategies and commitments. By embedding biological circularity alongside technical innovation, the EU can make the textile sector a model for circular transformation - one that keeps garments in use longer, reduces waste, regenerates natural systems and supports rural communities. This will strengthen the internal market, reduce dependence on fossil-based materials, and ensure that Europes circular economy delivers not only recycling but true renewal.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

24 Oct 2023

We welcome the revision of the EU Waste Framework Directive and all efforts to inform and improve delivery of the EUs environmental strategies in the fashion and textile industry. The WFD's intentions are commendable; however, the revisions focus on waste prevention is too narrow, missing significant opportunities to inform and improve the delivery of a suite of EU environmental strategies in the fashion and textile industry. Instead of relying on insufficient evidence and assumptions, the EU must ensure appropriate information is captured on clothing labels and use the data from clothing waste stream audits to inform textile policies. WFD can use data from waste streams as a determinant for EPR fees, instead of an over-reliance on sales data. This approach would not only provide more accurate data but also significantly reduce administrative burdens. Please find attached our full response.
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Response to Revision of EU rules on textile labelling

20 Sept 2023

We share the Commissions concerns about labels missing key information that helps consumers make sustainable choices. Incomplete labels confuse consumers and lead to wasteful consumption. When reviewing the Textile Labelling Regulation, the EC should align it with other laws like the Waste Framework Directive, ESPR, and the Green Claims Directive. Textile labels must inform consumers about caring for garments, extending their lifespan through repair and recycling, and disclosing the true fibre content. Include microplastic warning A microplastic warning on textile labels serves as a critical reminder of the hidden environmental impacts associated with our clothing choices. Microplastics pose a significant threat to aquatic and food ecosystems. Including this warning alerts consumers to the potential shedding of microplastics from the garment, prompting them to take precautions or opting for natural fibres over synthetics. Clear and truthful product descriptions True fibre composition should be reflected on all product names, descriptions as well as labels. Removing misleading language such as silky or mesh should be replaced by truthful descriptions such as polyester or wool. This not only promotes transparency but aids citizens to make informed purchasing decisions. Myth-busting recycled synthetics The belief that recycled polyester clothing is inherently sustainable is misleading. Most rPET comes from plastic PET bottles, but downcycling rPET into the textile industry disrupts an effective closed-loop system, rendering it to a single-use linear model instead of a circular one. These clothes shed microplastics and end up in landfill. Promoting recycled polyester can unintentionally encourage greenwashing and divert attention from away from other eco-friendly alternative like natural fibres. Informing textile environmental strategies Information gathered at the waste collection facility provides valuable insights into the use phase and the causes of clothing reaching end-of-life and this information can provide robust evidence for improving EU strategies such as Ecodesign, Extended Producer Responsibility, Circularity and the Waste Framework Directive. Vital information to capture on labels or product passports (DPP) includes, year of manufacture, raw material type(s) and subcategory type (i.e. t-shirt, sweater or jacket). Include alternative care options Textile care symbols on labels can improve garment care, helping consumers prolong garment lifespan and reduce environmental impacts. For example, animal fibre-based products benefit from airing or spot cleaning instead of washing. Sharing such alternative care tips supports the EU's sustainability goals. Include information on repairability and recyclability Including information on repairability and recyclability can encourage consumers to keep products longer and properly recycle them at end of life. Extending the use phase can defer product replacement. nowing that a garment can be recycled can influence purchasing decisions in favour of more sustainable options.
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Response to Environmental claims based on environmental footprint methods

26 May 2023

The Green Claims Directive represents a promising and critical step against the propagation of unregulated claims and labels. A certification framework and verification mechanism will be effective in providing legal clarity and ensuring fairness when it comes to companies marketing activities surrounding the sustainability space. The proposed framework will not only limit the potential for greenwashing and misleading claims, but it will also facilitate more harmonised and effective enforcement across Member States. However, more information is needed on the procedures and tools the independent verifiers will use to certify claims and labelling schemes to prevent unfair trade practices and ensure consumers are not misguided in their sustainability choices. We are pleased to see that the Commission has listened to stakeholder concerns around the limitations of the Product Environmental Footprint methodology, especially for the apparel and footwear product category. The Commission acknowledges that PEF omits the consideration of crucial impacts, such as microplastic release. We believe that the impact of plastic waste generation and the circularity of materials should also be considered as they are all driving forces behind the fashion industrys huge environmental damage. The proposal must be strengthened to ensure that any future identification of a single harmonised framework, either in the Directive or delegated acts, is only included if it delivers EU consumers meaningful information on the sustainability of their purchasing choices. A single framework would prevent companies from cherry-picking the label or scheme most favourable to their marketing objectives, and help to fight greenwashing, and promote consumers responsible behaviours in the long run. Therefore, we support the Commissions commitment to improve the PEF methodology. However, the PEF should be considered in the context of the Directive only if it is amended to include the above-mentioned impacts of microplastic, plastic waste and circularity. More clarity is also needed on the role the Ecolabel will play in this context and whether the Commission intends to develop it further to become the preferred certification scheme for the substantiation of environmental claims.
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