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ETSA (EUROPEAN TEXTILE SERVICES ASSOCIATION)

ETSA

The European Textile Services Association (ETSA) is a non-profit making organisation which was set up in Brussels in 1994 to represent and promote the interests of textile service industry leaders in Europe.

Lobbying Activity

Response to Evaluation of the Public Procurement Directives

7 Mar 2025

The European Textile Service Association (ETSA) represents the textile services industry, including laundering and rental services for reusable textiles like workwear, uniforms, and linens. ETSA also collaborates with textile manufacturers, national associations, and suppliers of machinery and detergents. Since 2021, ETSA has served as a European Commission Climate Pact Ambassador, promoting sustainability and aligning industry efforts with EU climate goals. Key Concerns & Recommendations 1. Ensuring Fair Competition Public procurement should provide equal opportunities for in-house and external textile service providers. Declining competition in procurement is a concern, partly due to unrealistic tender specifications and insufficient bidding time. Insolvency, especially in healthcare contracts, creates financial risks for textile service providers, many of whom operate on a pre-financing basis. ETSA suggests the EU develop a best-practice collection of tender documents to improve the tendering process. 2. Strengthening Sustainability in Public Procurement Procurement policies should prioritize sustainability and circular economy models over low-cost selection. ETSA advocates for mandatory green criteria that include: o Leasing and service-as-a-product models. o Preference for reusable over disposable textiles, which reduce greenhouse gas emissions. o Lifecycle cost assessment as a required award criterion in procurement decisions. Example: Surgical textilesReusable options significantly cut emissions compared to single-use alternatives imported from Asia. 3. Simplifying Large-Scale Contracting Complex and fragmented procurement rules create inefficiencies for cross-border providers. ETSA supports harmonized procurement processes and the proper use of digital tools like the European Single Procurement Document (ESPD) to simplify bidding. 4. Recognizing Digital Innovation Digital procurement platforms should be standardized and user-friendly. Public tenders should include criteria for RFID tracking, automation, and smart textile management solutions to keep procurement aligned with technological advancements. 5. Supporting Green & Transparent Procurement While the EU promotes sustainability in procurement, clearer and more predictable tender processes are needed to support innovation and circular economy goals. Conclusion The ongoing review of EU procurement directives presents an opportunity to enhance fair competition, sustainability, and innovation in the textile services sector. A balanced procurement strategypromoting environmental responsibility, digital transformation, and transparent regulationswill benefit both businesses and public interests. ETSA remains committed to collaborating with policymakers, industry stakeholders, and procurement authorities to ensure that procurement policies align with the EUs green transition goals.
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Meeting with Yvan Verougstraete (Member of the European Parliament)

5 Dec 2024 · Recycling of Textile

Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Nov 2023

ETSA, or the European Textile Service Association, is a key organization in the textile services sector. It offers services like cleaning and renting out reusable textiles such as work clothes, linens, and uniforms. ETSA is also involved with textile producers, national associations, machinery, and cleaning products. Since 2021, it has been working as an Ambassador for the European Commission Climate Pact. This means ETSA helps support the EU Climate Pact's strict environmental goals. ETSA plays a crucial role in connecting the European Commission with the textile care industry, which is vital for addressing the growing problem of textile waste, a major focus in the European Union. As the 2025 deadline for mandatory separate collection of textile waste approaches, Europe urgently needs well-coordinated and well-funded strategies. These strategies should go beyond recycling, emphasizing the importance of reuse and remanufacturing. This involves working closely with partners in collecting, sorting, and recycling textiles. A comprehensive approach like this is key to developing a strong European textile recycling value chain, moving towards a more circular economy. Mandatory National EPR with Minimum Harmonization Having a single, unified EPR (Extended Producer Responsibility) system throughout the European Union is really important for achieving our environmental goals. Right now, different countries in the EU have their own rules, which can make things complicated and slow down work. If there's one EPR system for the whole EU, it will make operations smoother, more uniform, and less complex to manage. This is especially helpful for the many small and medium-sized businesses (SMEs) that work in different EU countries. ETSA has also shared its thoughts on this topic in another paper in 2023, which you can check out for more information. However, ETSA and his Members gave the following core recommendations to the EU in regard to an EPR for textiles, which will be core to the WFD revision: Eco-design in textile manufacturing is crucial for creating high-quality, washable, and repairable textiles, aiding in recycling at the end of their life. The sorting process for textiles varies significantly, especially for post-consumer versus technical textiles like PPE/workwear, which may contain specific chemicals or contaminants. It's important to consider these differences to avoid environmental risks from increased transport, energy for sorting, and downcycling. The current definition of waste hinders circular textile flows. Textiles fit for reuse or recycling are often bogged down by bureaucracy and regulations, especially in crossborder transport. A revised definition of waste is necessary to promote circularity and provide clear classifications for reusable materials. A discussion on common definitions for different types of textiles is needed in the Waste Framework Directive and the EU-level EPR for textiles. The significant presence of SMEs in the European textile services industry means that a new EPR could add extra administrative burdens. Targeted financial incentives are essential to manage these challenges. More research and funding are needed for recycling technologies, as there is a lack of technology and capacity for high-grade recovery of various end-of-life textiles. Challenges like the trade-off between durability and environmental impact, such as mixed fabrics lasting longer but releasing microplastics and being more complex to recycle, or how to best address the use of potentially harmful products in protective work textiles, need to be openly addressed. The full ETSA response can be seen in the attachment.
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

The European Commission is working on reshaping the European Standardisation System (ESS), and one of the strategies involves revising standardisation regulation 1025/2012. ETSA, the European Textile Service Association, represents the textile services industry, including laundering and rental services for reusable textile products in various sectors. ETSA also represents textile manufacturers, machinery, detergents, national associations, and a research institute. We actively participate in standardization efforts in our capacity as Liaison organisation in CEN and ISO. Standards play a crucial role in ensuring harmony, interoperability, and improved product quality in terms of security, safety, and efficiency. They enhance product and service quality by setting common requirements, driving innovation, and boosting competitiveness. A harmonized market enhances business opportunities, especially for the EU on the global stage. ETSA supports the European Commission's efforts to include societal interests, promote EU's global standards role, and involve European Associations, SMEs, consumers, and environmental concerns. Greater representation and inclusivity would enhance transparency, trust, and the quality of standards. Simplified procedures and mechanisms for public involvement in standards development are needed, along with improved governance and skills/training systems. EU funding for standards-oriented research is vital, as there are currently limited incentives for such research. ETSA advocates for various incentives to encourage research and development in standards drafting. Concerning harmonized standards developed by European Standards Organizations (ESOs) following EC mandates, there's uncertainty due to recent legal cases. ECJ rulings have changed the process, imposing bureaucratic burdens on standardization bodies. The issue of purchasing harmonized standards is also under discussion. If they become free, the EU Commission and Member States must ensure ESOs' financial viability and efficiency. Aligning standards with EU policy objectives is positive, ensuring they contribute to broader EU goals. However, a balance must be struck, as standards are technical, while policy objectives are more political. Promoting European values and supporting EU industrial policy globally is supported by ETSA, but caution is needed not to jeopardize the ESS. ETSA values a balanced approach, ensuring the ESS remains effective and relevant in the evolving global economy. They are committed to increasing inclusiveness and transparency in this transition.
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Response to Environmental claims based on environmental footprint methods

20 Jul 2023

ETSA the European Textile Service Association, a business association with membership consisting of laundries, detergents, machineries and national associations would like to express support and outline concerns regarding the EU Commission Proposed Directive on "Green Claims." While we appreciate the intention behind this proposal to promote reliable and verifiable environmental claims, we believe it is crucial to consider the following points in order to ensure a balanced and effective approach, which does not overburden industry and works towards promoting sustainability and preventing greenwashing. Firstly, we acknowledge the references made to other legislative developments such as the Empowering Consumer Directive proposal, the Eco-design for Sustainable Products and Digital Products Passport Regulation, and the upcoming revision of the Textile Labelling Regulation. We strongly recommend that these existing rules and regulations pertaining to environmental claims, labelling, and assessment be applied to the specific claims addressed in the Green Claims Directive. This will avoid duplication of efforts and streamline the implementation of consistent standards across different sectors. Regarding the methodology and substantiation of green claims, we agree that claims should be supported by sound scientific evidence. However, instead of introducing new verification methods, we propose that claims must be in line with figures from sustainability reports that are already verified by a third party. By utilizing the existing audit processes for sustainability calculations, companies can ensure consistency between their public claims and verified information. This approach would prevent an additional burden on businesses while maintaining transparency and accountability. When it comes to broad claims like "sustainable" or "environmentally friendly," we urge careful consideration of potential restrictions on common words that are not distinct to any particular source or organization. Intellectual property law recognizes the concept of "lack of distinctiveness" for words that cannot be exclusively linked to a specific entity. We believe that similar reasoning should apply to the use of such broad claims in the context of the Green Claims Directive. Restricting the use of common words may limit communication and impede free speech, which should be protected as long as claims are not misleading or deceptive. Fundamentally, we believe in the consumers individual responsibility and intellectual faculties to choose a product or service claimed sustainable. Furthermore, we support the scope of the proposal in following a value chain approach and including products from small and medium-sized enterprises (SMEs). It is essential to encourage sustainability practices across all sectors and empower SMEs to contribute to environmental goals. In terms of verification, we agree that independent conformity assessment bodies should play a role in verifying claims and labelling schemes. However, it is crucial to consider the cost impact on businesses, particularly SMEs. The verification process should be streamlined and cost-effective to ensure it does not become a barrier for companies striving to comply with the Green Claims Directive. With regard to the complaint mechanism and access to courts, we support the provision that allows natural or legal persons or organizations to submit substantiated complaints to competent authorities. Transparency and accountability are vital for maintaining consumer confidence. It is equally important to ensure that the competent authorities have the necessary expertise and resources to address these complaints effectively. We acknowledge the concerns raised about environmental claims related to textiles containing plastic polymers made from recycled PET bottles. The full ETSA response can be see in the document in the attachment.
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Response to Promoting sustainability in consumer after-sales

25 May 2023

ETSA, the European Textile Service Association, represents and works on behalf of the textile services industry, which provides laundering and rental services for reusable textile products such as workwear, linen, and uniforms, while also representing textile manufacturers, machineries and detergents. The legislation highlights the importance of creating a rental model for textiles and prioritizing the reparability of clothing and other textile products. This is something which forms the basis and crux of the textile service business model, and why ETSA which has also been a European Commission Climate Pact Ambassador since 2021, wholly supports this legislation. We ask the Commission to consider the fact that the textile service value chain is inherently circular, with the potential for products to be repaired, reused, and recycled throughout their lifecycle. In this regard, right to repair is essential to our industry. By prioritizing circularity, the industry has been reducing waste, conserving resources, and minimizing the environmental impact of textile production and curtailing excessive consumption. One key aspect of the circular textile service value chain is the rental model. Rather than consumers purchasing clothing and other textile products outright, a rental model allows for these items to be rented or leased instead, often through an intermediary. This approach encourages greater product lifespan and minimizes waste, as consumers are able to return products to be reused, repaired or recycled by professionals within the textile care industry instead of simply disposing of them. This emphasis on reparability is a crucial component of circularity, as it allows products to be kept in use for longer periods of time, thereby drastically reducing carbon emissions and resource extraction needed in the production of new material. A survey by ETSA Member, CWS has shown that repairs extending the lifespan of textile products can drastically reduce carbon emissions. In contrast to a linear system, a circular system enables an average reduction in greenhouse gas emissions of 76 per cent. In addition to the rental model, the textile service value chain also emphasizes the importance of reuse and recycling. By reusing textiles, businesses can reduce the need for new production and conserve resources. Recycling textiles also plays a crucial role in circularity, as it allows for materials to be repurposed rather than disposed of as waste. The industry is committed to repairing and reusing textiles throughout their lifecycle, with many ETSA members actively upcycling and finding creative repurposing for used, destroyed or soiled garments. Nevertheless, consumers must also be willing to accept repair, reused and recycled textiles in the services and hospitality industry. At our core, the industry is fulfilling consumer demand, thus consumers should also be made aware of the benefits of repairing and recycling textile products, with the Commission showcasing the benefits of repairability to consumers and investing in skills concerning repairing and recycling. In some cases, such as in 3-4-5 stars hotels, it should not be given for granted that consumers would accept a repaired towel or sheet- hence(or unbleached cotton); this option should be presented to consumers as a voluntary one and not provided by legally binding measures for companies. A true behavioural change could be certainly encouraged by companies: for instance, the lower level of quality could be presented to consumers accompanied by alternative prices which could be indicated in an annex to the contract but it should be up to the discretion of the company to provide such an option. Additionally, this can pose a challenge to the repairer. See attachment to view the entirety of the feedback
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

ETSA, the European Textile Service Association, represents and works on behalf of the textile services industry, which provides laundering and rental services for reusable textile products such as workwear, linen, and uniforms, while also representing textile manufacturers, machineries and detergents. The industry will be concerned by the EU Taxonomy legislation and its new delegated acts, and wholly supports the objectives of this legislation. ETSA working as an EU Commission Climate Pact Ambassador since 2021 fully backs the call for the whole of Europe and indeed the world to redouble its efforts with respect to adhering to the legally binding goals of the EU Climate Pact but also to support a transition of the global economy to more circular practices. Indeed, it is worth noting that the textile services industry is sustainable by its very design as it operates on a product as a service model that enables the reuse of textile products multiple times between different customers, including most of time repairing or even refurbishing products, and increasing on building closed loop systems, allowing on the longer term to reduce waste and contribute to a more sustainable economy at all stage of a product life. The laundry equipment essential for the reuse of textile products is very often powered by gas, an activity which, according to the Complementary Climate Delegated Act, is part of the EU taxonomy. This aspect should be considered when defining new sets of EU taxonomy criteria. The sector is performing regular Life Cycle Analysis to compare different options between linear practices (eg : ownership of products or single use approach vs reusable solutions) to demonstrate the benefits of product as a service business model but most importantly to promote behavioral change in both customers and product users. For example: - The use of cloth roller hand towels reduces CO2eq emissions by 29% compared to disposable paper towels and waste by about 95%. - The use of reusable scrubs in healthcare facilities reduces CO2eq emissions by 31% to 62% compared to disposable scrubs, depending on actual consumption (Source: Cleaner Environmental Systems). Several studies have especially been conducted by our members on their contribution to a transition to the Healthcare sector contributing at the same time to local job non relocatable development. Supporting the transition to circular economy for ETSA is a key topic, and having the (inherently circular) product as-a-service business model in our member companies represents a fantastic opportunity to redouble sustainable commitments. At the same time, the EU should also acknowledge the challenges that companies in the industry face, including the high costs associated with transitioning to renewable energy sources and investing in new technologies. By providing support and incentives to help companies in the industry switch towards more sustainable operations, the EU can encourage positive change while ensuring the industry's continued viability, which is essential to the continued economic and service infrastructure of Europe. We ask the EU to recognize that the textile services industry has already been facing challenges following the aftermath of the pandemic, which had a significant impact on the hospitality, travel, and events sectors that are among the industry's key customers. Many companies in the industry experienced a subsequent prolonged decline in demand for their services and reduced revenues as a result, including after most restrictions were lifted. Additionally, almost immediately following a very brief pandemic recovery the industry has also been hit by the energy crisis following the Russian invasion of Ukraine, with rising energy prices increasing the cost of operations for many companies. To see the full ETSA response including on Annex 2, please see the attachment.
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Response to Revision of the Urban Wastewater Treatment Directive

13 Mar 2023

We at ETSA, the European Textile Services Association representing our members, wholly acknowledge and follow closely the actions of the European Commission with respect to the revision of the Urban Waste Water Treatment Directive. As a European Commission Climate Pact Ambassador, we totally support efforts by the European Union to improve both sustainability and public health, with respect to our common waterways. ETSA, represents laundries, detergents, manufacturers and machineries in Europe, who are part of an inherently circular product ecosystem. Textile goods are expertly handled at facilities, where they are washed, repaired, and reused. When a textile item is no longer fit for re-use, it is either re-incorporated into further products or when the fibers have degraded to the point where any further usage is not possible, it is disposed of (mostly recycled) in a professional manner that maximizes resource efficiency. Based on the necessity of providing hygienically cleaned textiles to European businesses, healthcare facilities and citizens, during the cleaning process, industrial laundries produce an amount of wastewater. It should be understood by the Commission, that per textile item, industrial laundries produce considerably less wastewater than home washing and that over the years, industrial laundries have been able to reduce the amount of water they need for the laundering process, while still conforming to European hygiene standards . It should also be known that industrial laundries are experts in chemical identification (chiefly detergents and essential coatings for healthcare and personnel protective purposes) and, for most of them, they can pre-treat the wastewater generated in their on-site facilities and then send the wastewater to a local wastewater treatment plant, always in accordance with local legal requirements. Chemicals which are used by industrial laundries include those which are necessary for not only hygiene, but also in the construction, repair and re-coating, re-impregnation of PPE, including coatings/impregnations which are used to protect the lives of essential servicemen and servicewomen in fields such as healthcare, construction, services, security and more. In addition to often pre-treating their wastewater before sending it to a municipal treatment plant, many laundries in the textile services industry employ filtering techniques to remove potential pollutants prior to municipal wastewater treatment. In this regard, the textile services industry supports the directive as collecting pollutants from the environment, rainwater and water sources through the use of specialized municipal treatment plants is the most optimal solution. ETSA members recognize the importance of water recycling and treatment, especially in light of water shortages in recent years. We ask the European Commission to understand that textile services have been developing their methods to consistently use less water for washing while delivering the same hygienic quality of textile services. In this regard, we reduce the volume of water to be treated and recycled by urban wastewater treatment plants and are wholly committed to a cleaner and more efficient water usage system in Europe.
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Response to Enabling factors for digital education

16 Sept 2022

The European Textile Service Association is a registered trade association located in Brussels, advocating on behalf of the textile services industry, including but not limited to laundries, machineries, detergents, textile rental firms, as well as national associations. ETSA members fully support the European Commission’s commitment to digitalization, upskilling and remote education. As an example of our commitment to this endeavour, beginning in 2018 and finishing in 2021, ETSA, in cooperation with several of its national associations, were involved in an EU-funded project called “Educate!” which aimed at training and upskilling workers in the textile care industry through the use of digital technology through the use of an app. The unforeseen consequences of the 2020 COVID-19 pandemic really accented and bolstered the project’s relevance and importance not only to our industry but society in the macro-sense. Furthermore, the goals of the EU Climate Pact of which ETSA is an EU Climate Pact Ambassador, mandate a reduction in emissions across society in a holistic sense. Increased digitalization and digital training can be part of that equation, as it reduces travel expenses and allows workers more flexibility by reducing emissions from transport. In sum, the project consists of several training modules complete with tests and video tutorials which showcase how to conduct the processes needed for the functioning of an industrial laundry from all levels of the workplace hierarchy, while also showing workers exercises and stretches they can do after a shift in order to maintain and improve overall physical health. Moreover, the utilization of this digital technology allows workers to learn at their own pace and on their own time, improving flexibility and work-life balance while also ensuring critical information pertaining to safety, health, etc. is properly understood by employees. What European institutions and indeed Member States should do, is provide monetary assistance and financial incentives to help companies improve their remote and digital training capacities (many of these companies often lack supplies or the presence of the necessary regional digital infrastructure) and also underscore the opportunities provided by apprenticeships and blue collar jobs which struggle to be filled in Europe, particularly in regions experiencing a “brain drain.” By innovating and investing in digital technology, training and education, not only can we incentivize the undertaking of these training programs and the fulfillment of essential jobs in Europe (including in textile rental and laundries), due to the convenience and ease afforded by remote learning but companies and local governments can also find opportunities to create new, green and digital jobs in their own right. Furthermore, it must be stressed that for this undertaking to expand and impact greater society in a positive sense, it needs to be supplemented by cooperation from the European Union, Member States, private investment as well as local and regional authorities.
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Response to Improving the provision of digital skills in education and training

16 Sept 2022

The European Textile Service Association is a registered trade association located in Brussels, advocating on behalf of the textile services industry, including but not limited to laundries, machineries, detergents, textile rental firms, as well as national associations. ETSA members fully support the European Commission’s commitment to digitalization, upskilling and remote education. As an example of our commitment to this endeavour, beginning in 2018 and finishing in 2021, ETSA, in cooperation with several of its national associations, were involved in an EU-funded project called “Educate!” which aimed at training and upskilling workers in the textile care industry through the use of digital technology through the use of an app. The unforeseen consequences of the 2020 COVID-19 pandemic really accented and bolstered the project’s relevance and importance not only to our industry but society in the macro-sense. Furthermore, the goals of the EU Climate Pact of which ETSA is an EU Climate Pact Ambassador, mandate a reduction in emissions across society in a holistic sense. Increased digitalization and digital training can be part of that equation, as it reduces travel expenses and allows workers more flexibility by reducing emissions from transport. In sum, the project consists of several training modules complete with tests and video tutorials which showcase how to conduct the processes needed for the functioning of an industrial laundry from all levels of the workplace hierarchy, while also showing workers exercises and stretches they can do after a shift in order to maintain and improve overall physical health. Moreover, the utilization of this digital technology allows workers to learn at their own pace and on their own time, improving flexibility and work-life balance while also ensuring critical information pertaining to safety, health, etc. is properly understood by employees. What European institutions and indeed Member States should do, is provide monetary assistance and financial incentives to help companies improve their remote and digital training capacities (many of these companies often lack supplies or the presence of the necessary regional digital infrastructure) and also underscore the opportunities provided by apprenticeships and blue collar jobs which struggle to be filled in Europe, particularly in regions experiencing a “brain drain.” By innovating and investing in digital technology, training and education, not only can we incentivize the undertaking of these training programs and the fulfillment of essential jobs in Europe (including in textile rental and laundries), due to the convenience and ease afforded by remote learning but companies and local governments can also find opportunities to create new, green and digital jobs in their own right. Furthermore, it must be stressed that for this undertaking to expand and impact greater society in a positive sense, it needs to be supplemented by cooperation from the European Union, Member States, private investment as well as local and regional authorities.
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Response to Sustainable Products Initiative

22 Jun 2022

ETSA’s feedback to the European Commission on establishing a framework for setting eco-design requirements for sustainable products We at ETSA, the European Textile Service Association wholly support the European Commission’s framework in establishing eco-design requirements for sustainable products. We believe this initiative action by the European Commission will serve to combat planned obsolescence, increase the longevity of textile products and empower consumers to seek examine reparability, reusability, sustainability and product quality when contemplating the purchase and usage of textile goods. ETSA, in its function as a European Association represents the textile services industry’s laundries, suppliers and national associations. The business model of textile services is one which is inherently circular, wherein our members work tirelessly to repair, recycle and reuse textiles, thereby servicing businesses and healthcare facilities large and small throughout Europe. In our role as European Commission Climate Ambassador, ETSA Secretariat is constantly looking to promote more sustainable behavior and best practices both within our membership and to the outside world moreover. We therefore view the eco-design requirements on sustainable products as a tool for positive change. By viewing a textile product instead as a service to be rented, ETSA members are thus able to extend the life span of textile products through expert repairing and treatment techniques, without sacrificing hygiene or quality standards. By increasing minimum quality thresholds for goods to enter the market by implementing a horizontal approach via harmonized thresholds and standards, the EU Commission can ensure that textile service companies have the capacity to repair textile products. The full answer is attached here as a word document, if you have any inquires please do not hesitate to contact ETSA Secretariat
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

ETSA, the leading European association for textile rental companies and national textile services associations, welcomes the Waste Framework Directive (WFD) roadmap and its reflection on the environmental impact of waste management and measures to prevent the creation of waste and ensure high-quality recycling. Sustainability and the environment are at the heart of ETSA’s circular business model, and we thrive to actively engage with and support the European Green Deal. As an EU Commission Climate Ambassador, ETSA’s role is also to share best practices and models on sustainability as a contribution to fight climate change and foster circular economic models. ETSA especially supports the opportunity to introduce measures that will clarify a number of definitions and principles such as ‘textile waste as a resource’ and ‘textile waste to be disposed of’, ‘reusable’ or ‘high quality recycling’. Clear minimum requirements for collection and sorting of end-of-life textiles to be either recycled or disposed of should be set. Separate collection of textiles is due by end of 2024 and solutions to manage textile collection and related businesses are currently being developed. Waste reduction measures should seek to emphasis the reuse and recycling of textiles while reducing waste destined to disposal but also to encourage eco-design of products thereby allowing for easy repairs and maintenance during the care cycle and easy sorting at the time of end of life. By their very nature, textile services provide a more sustainable alternative to disposables, washing at home and ownership of textiles. The textile services industry, which incorporates textile rental and professional industrial care and maintenance of textiles, is committed to a business model which exercises the least possible burden on the environment. Rented textiles have a significantly longer life cycle than owned textiles. The main environmental burden of a rented textile product comes during the care cycle of that product. When the rented product no longer meets its quality requirements, it is removed from circulation. A long service textile life begins with selecting quality, durable eco-designed textiles, with laundry processes which minimise wear and tear, by repairs made during the care cycle and the reuse/recycling of the textile at the end of life so that fibers can be reused into the production loop. The main type of waste resulting from textile rental is the disposed textiles themselves. ETSA members strive to re-use textiles whenever possible. Otherwise, textiles are recycled or used as raw materials in energy production. ETSA members monitor their waste volumes closely. There needs to be a holistic approach where the revision of WFD is developed together with the incoming textile strategy, sustainable product initiative and other relevant initiatives. Within ETSA, we look forward to the public consultation to discuss these elements further with DG ENV.
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Response to Measures to reduce microplastic pollution

17 Jan 2022

Reducing the environmental impact of unintentionally released microplastics is the way forward! ETSA, the European Textile Services Association, welcomes the Commission’s objectives to tackle this issue and to set up voluntary measures and objective, science based and realistic standards to address it and to reduce the environmental impact of unintentionally released microplastics from synthetic textiles. The European Commission’s Green Deal about moving towards climate-neutrality and speeding up the transition towards a circular economy requires an ambitious textile service strategy and tackling, among others, the issue of microplastics . This is perceived as a societal issue facing individuals and companies in all countries, and in many sectors of our economies. It should be noted however, that as service providers, textile care services are a link in the chain, not the cause of microplastic emissions. Furthermore, A lot of the particles released during the industrial washing are not necessarily considered plastic. The non-fibres consist of many different materials, while the fibre-shaped particles consist mainly of polyester. The fibre-shaped particles, therefore, present an estimate of the number of microplastic particles with a best-case scenario where only 1% of the non-fibre particles are plastic and a worst-case where 5% is plastic. Overall, the textile care industry is responsible for a fraction of microplastic emissions. The overall value chain is committed to reduce the release of microplastics from synthetic textiles. With a holistic view of the LCA of such products and trying to minimise/prevent release at every stage whilst also using innovative solutions to capture and recycle microplastics, the sector is confident it is part of the solution. Selecting textiles Generally, textiles applied in textile service are high quality – high twist, tight weaving/knitting etc. because they are intended to be used in dozens of washing cycles they consequently release relatively limited amounts of microfibers. Establishing acceptable standards for microplastic release from laundries on the European level is vital. An analytical standard which is based on scientifically valid and accepted methods for microplastic measurement for acceptable microplastic release is critical. Textile care and ensuing wastewater The laundries are optimising their washing and drying processes with the aim to reduce the release. According to current knowledge, well over 95% of microplastics are retained in wastewater treatment plants. Sewage treatment plants could increase their performance even more with upgraded textile filters. Such an endeavour and investment would require focused leadership from the European Commission and Member States. Synthetic textiles end of life: Facilitating recycling or remanufacturing Reuse and recycling will reduce the demand for virgin fibers and help achieving a circular economy. Rules on the safe disposal, destruction and recycling on microplastic waste (i.e. the “fluff” or “mud”) should be clarified. Questions such as, does the burden of disposal lie with the laundry facility, the consumer or an intermediary waste disposal party must be addressed. Sustainable information/ labelling There must be a European-wide definition of what constitutes a microplastic that is based on objective scientific truth and is not influenced by ideology or aesthetics. Methods to quantify the presence of microplastics in water must also be universalized to reach a more reliable and valid understanding of the microplastic situation in Europe and indeed the world. ETSA is the leading European association for textile rental companies and national textile services associations. Textile services represent a crucial industry, supplying hygienically cleaned workwear, linen and other textiles to the rest of the economy: hospitals and nursing homes, hotels and restaurants, industries, trade, and crafts.
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Response to EU strategy for sustainable textiles

2 Feb 2021

Why would ETSA be instrumental to the Commission’s new strategy ON TEXTILES ETSA is the leading European association for textile care companies and national textile services associations. Please note textile care services which we represent, and the textile sector, are not the exact same thing. We represent a segment of the sector that is crucial in the TEXTILE VALUE CHAIN. Our textile care companies are essential because they supply hygienically cleaned workwear, linen and other textiles to the rest of the economy. Indeed, professional textile service companies supply hospitals and nursing homes, hotels and restaurants, industries, trade, and crafts with hygienically clean textiles. Hospital and table linen as well as professional workwear and Personal Protective Equipment (PPE) must be hygienically serviced and this not only because of Covid-19. We believe this essential role should also be recognised in the Commission‘s forthcoming strategy. Professional textile care increases the longevity of textiles and thus lowers the overall ecofootprint of textiles in the EU. Moving towards climate-neutrality and speeding up the transition towards a circular economy with an ambitious textile strategy is therefore essential. Sustainability and the environment are at the heart of the ETSA circular business model and we thrive to actively engage with and support the European Green Deal. We also embrace the importance of moving from a very much product-owning economy to a more lease-based economy. Instrumental role of textile services pre and post COVID 19 With a current market size of circa € 11 bn, the European textile service industry has significant economic importance and is a real contributor to value creation and employment in the European economy. This should not be underestimated when setting up a strategy that covers all the segments of the textile value chain. The overall market represented by our companies grew in recent years in almost every segment and product type. With over 135,000 employees in Europe, textile services are an industry that should not be underestimated. Textile services are part of a solution for other businesses in coping with the Covid-19 pandemic while also being valuable in the post Covid-19 future. We underlined this in our position paper 'Call for measures to restart the Economy'. We welcome the opportunity to engage and start a dialogue through the European Commission’s roadmap for an EU strategy for sustainable textiles consultation. In our answer, we especially expand on the following points as outlined in the roadmap: Strengthening competitiveness against the backdrop of the coronavirus crisis with the creation of conditions for Incentives, recovery and resilience, green public procurement of “products as a service” and the strengthening of the EU infrastructure and production capacities; circular textiles with sustainability by design sustainability requirements in standards and less waste with textiles end of life management (reuse & recycle) and sustainable investments and innovations. New business models are increasingly built around rental and leasing solutions. ETSA members are part of this transition from linear to circular economy with their circular business model. We combine cost-effectiveness with sustainability.
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