Better Cotton Initiative
BCI
Better Cotton is the world’s leading sustainability initiative for cotton.
ID: 826985544179-84
Lobbying Activity
Response to Digital Product Passport (DPP) service providers
9 Dec 2024
Implementation of the Digital Product Passport on clothing presents an unparalleled opportunity to meaningfully measure and report the environmental footprint of textiles. DPP-derived data from waste collection facilities could report the average lifespan of clothing made by brands and this evidence-based measure of sustainability could then determine the environmental score and labelling of clothing currently being made by those brands. Such a system would highly motivate brands to produce long-lived clothing, and this in turn would help deliver the Green Deal and Strategy for Sustainable and Circular Textile goals such as putting fast fashion out of fashion. This end-of-life tool would take all the guesswork out of proposed rating schemes such as PEFCR for A&F which attempts to guestimate clothing lifespan at start-of-life. Furthermore the data is of value to any Extended Producer Responsibility (EPR) scheme. Vital information on a DPP to deliver this outcome includes: 1. Name of brand/producer 2. Year produced 3. Product subcategory type (i.e. tee-shirt, pants, socks, etc) 4. Product structure (i.e. knitted, woven) 5. Fibre type and ratio by weight The DPP should provide consumers with objective information to help inform their purchasing and use phase decisions. Vital information on a DPP to deliver this outcome includes: Good (and correct) size system and information about the measurements (that each size corresponds to) Functionality - waterproofing, windproofing, fading, pilling and shrinkage. % share of plastic Care labelling Other desirable information could include: Content of all chemical substances on the REACH database Traceability information - not just country of origin, but the garment journey The Digital Product Passport (DPP) can also serve as a transformative tool to improve Extended Producer Responsibility (EPR) schemes by addressing the root causes of overproduction in the textile industry. By capturing and analyzing real-world data, the DPP allows for evidence-based eco-modulation of EPR fees that incentivize waste prevention and discourage the production of short-lived, low-quality garments. The integration of DPP-derived data into EPR schemes would make it unprofitable for brands to overproduce disposable items while rewarding the creation of durable, recyclable, and biodegradable products, effectively contributing to the Green Deal's goal of "putting fast fashion out of fashion" and reducing waste volumes that go to landfill.
Read full responseResponse to Environmental claims based on environmental footprint methods
20 Jul 2023
Better Cotton welcomes the proposal for a directive on substantiation and communication of explicit environmental claims (Green Claims Directive), to ensure that consumers are protected and empowering them to contribute actively to the green transition by tackling false environmental claims. There is a strong need for clear guidance on how claims can be made in a credible, accurate and relevant manner. Better Cotton is the largest cotton sustainability programme in the world. Our mission is to help cotton communities survive and thrive, while protecting and restoring the environment. One of the pillars of the Better Cotton Standard System is our Claims Framework, which was created through a multi-stakeholder consultation process and is subject to an annual review. As an ISEAL Code Compliant organisation, our Claims Framework is also in line with ISEALs Claims Good Practice Guide. Through our Claims Framework (https://bettercotton.org/wp-content/uploads/2021/12/Better-Cotton-Claims-Framework-V3.0.pdf), we provide support to eligible members to communicate their commitment to Better Cotton in a clear, transparent and credible way. The ability for members to communicate their investment in Better Cotton to consumers strengthens their commitment to our farm-level programmes which seek social, environmental and economic improvements for cotton farmers and farming communities. We believe that clear and credible communications by all stakeholders about their sustainability efforts is important for driving positive market changes by allowing consumers to make informed purchasing decisions. The Green Claims Directive is a great step towards establishing a fair level playing field for economic operators, however some sections of the Proposal could benefit from additional clarifications to facilitate its implementation and maximise the benefits sought: 1) Avoid limiting substantiation to one standard methodology Better Cotton welcomes the position that the Commission has adopted in the Proposal not to restrict claims substantiation to a specific set of methods related to lifecycle analysis (LCA) or product environmental footprints (PEF). Establishing one single method as the standard methodology for the substantiation of green claims such as PEF or LCA would not be appropriate as, to date, there is no standard methodology available that can cover all relevant impact categories for all product types. Moreover, such flexibility is instrumental to ensure substantiation methods are adapted to the wide array of impact categories and practices covered by schemes, and the variability in operating contexts found across sectors and materials. Keeping such a flexibility is the only way to favour a Just Transition across the world and enhance sustainable livelihoods. 2) Ensure policy coherence to accelerate the Green Transition Better Cotton welcomes the leadership of the European Union in accelerating the green transition through the proposal of policies that will protect consumers from greenwash and, in turn, encourage environmentally sustainable consumption practices. We wish however to flag that greater alignment across these policies is needed, particularly between the Proposal and the Proposal for a Directive on empowering consumers for the green transition (the ECGT). More specifically, it is unclear whether sustainability labels, in addition to environmental labels, need to comply only with the ECGT, or whether these are also covered under the Proposal. Furthermore, if sustainability labels are to comply with both proposals, it should be made clear that they should also be included in the list of officially recognised environmental labels that are allowed to be used on the Union market at the outset of the adoption of the Proposal. Uncertainties surrounding the definitions and application of these directives can lead to barriers in their implementation.
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