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Global Standard gGmbH

GOTS

Global Standard gGmbH is a self-funded not-for-profit organisation that implements the Global Organic Textile Standard (GOTS) (www.global-standard.org).

Lobbying Activity

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

Global Standard, owner of the Global Organic Textile Standard (GOTS), welcomes the EUs intention to develop a Bioeconomy Strategy that aims to create a sustainable, circular and competitive bioeconomy in the EU while respecting planetary boundaries, protecting and restoring biodiversity and ensuring a fair transition across the EU, at national, regional and local level. A key objective of this Bioeconomy Strategy should be to strengthen and invest in biobased sectors that show concrete environmental, climate, economic, and social benefits, demonstrate innovative applications and contribute to true circularity. Natural fibres, and particularly natural organic fibres, offer a compelling example of a sustainable bioeconomy in action. Grown in diverse agroecological regions, often on marginal or non-arable land, the cultivation of fibres such as (organic) cotton, wool, hemp, and flax, supports biodiversity, reduces water stress by using rainfed systems, builds soil health, sequesters carbon, and sustains rural livelihoods. Natural fibres are renewable, biodegradable, and capable of regenerating ecosystems. They are farmed, not mined like fossil fuel-based synthetic fibres. Natural fibres grow back seasonally and, at end-of-life, return safely to the soil. This regenerative loop must be recognised as the foundation of a circular bioeconomy. Across Europe and beyond, natural fibres are also increasingly used in high-value applications (with, for example, modern wool or hemp innovations extending far beyond traditional textiles) and the natural fibre sectors are modernising rapidly - investing in regenerative and organic agriculture, traceability, and exploiting low-impact processing. To reach the Bioeconomy Strategys goals, policy coherence is crucial. This means, for example, that the Strategy must align with the EUs climate and environmental targets; redirect public funding to practices and businesses that use biomass in an efficient, sustainable and non-polluting way; ensure that bio-based products meet high standards of environmental and social sustainability and prevent greenwashing. For textiles this also means that any methodology and data used to calculate and communicate the environmental footprint of a textile product must consider both the positive characteristics of natural fibres and the negative impacts of synthetic fibres (such as dependency on fossil fuel resources and microplastic pollution), which, unfortunately, is not the case with the Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear recently approved by the EU Commission. Finally, considering the fact, that the use of biomass today is a major driver of environmental degradation across Europe and globally, the EU Bioeconomy Strategy must alleviate these pressures rather than compounding them. This will not be possible without a shift to production and consumption patterns that operate within planetary boundaries and support a thriving rural economy. Against this background, the revision of the Bioeconomy Strategy, should Position natural fibres as strategic assets in the bioeconomy, both within and beyond Europe; Broaden the definition of circularity to include renewability, biodegradability, and regenerative land use, explicitly recognising the contributions of natural fibres and organic farming practices; Support agricultural fibre communities within member states but also acknowledge that natural fibres are part of global supply chains. Supporting them will not only strengthen Europes strategic autonomy in biobased materials but also drive positive global outcomes for biodiversity, climate resilience, and livelihoods; Design criteria for public procurement in a way that supports a sustainable bioeconomy, e.g., by prioritizing textiles made from natural organic fibres; Ensure policy coherence and adopt sustainability metrics that reflect the full environmental and social performance of natural fibres.
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Response to Evaluation of the Public Procurement Directives

5 Mar 2025

The upcoming reform should reinforce the role of public procurement as a strategic policy tool, supporting the EU in achieving its environmental and social objectives while promoting sustainable economic practices. Currently, Directives allow for the consideration of qualitative, environmental, and social criteria in public tenders, provided they do not hinder competition in the internal market. There is too strong focus on competitiveness and equal treatment, at the expense of sustainability. The Directives aim to avoid discrimination against bidders and their products. Therefore, many requirements targeting social and environmental objectives are often deemed discriminatory. This risk leads contracting authorities to rely heavily on price-only criteria, favouring cheaper, conventional products and services. This practice restricts competition from the outset and results in the proliferation of tenders with a lack of or single bid. While conventional products may be cheaper initially, their environmental and social costs are significantly higher and borne by society. There is an urgent need to strengthen the sustainability principle within the Directives, by reinforcing and explicitly defining the scope of the sustainability principle (Article 18.2). The Directives should shift from a focus on more competition to better competition, emphasizing the quality and strategic impact of bids, including sustainability, quality, and social value. It must be recognized that sustainable procurement alters the pool of suppliers by giving per se preferential treatment to environmentally friendly firms and goods. Evidence shows that such preferential treatmentwhether through bid discounts (as seen in the CO Performance Ladder policy used by Dutch authorities), mandatory minimum environmental and social standards (as in the U.S. Recommendations of Standards and Ecolabels for Federal Purchasing, which mandate procuring goods with particular certifications), or a best price-quality and sustainability ratio (as practiced by the City Council of Barcelona, which mandatorily scores price with a maximum of 35% points)encourages greater investment in green technology and industry certifications, leading to more competitive bidding. In this context, trusted certifications should be seen as enablers of sustainable procurement, reducing the burden on contracting authorities to account for environmental and social considerations. Reputed standards also help achieve procurement goals related to simplification and flexibilization of existing rules. Textile sectors already have a mature, competitive market of economic operators using supply chain certifications to address human rights and environmental impacts, offering variety of certified products, facilities, inputs, and fibres. Under the Article 43 of the Directive, contracting authorities can seek labelled products. However, if an economic operator cannot obtain the specific label indicated other appropriate means of proof is accepted. This places contracting entities in a difficult position of functionally becoming certifying entities, increasing costs and administrative burdens for those lacking the necessary expertise. Global Standard believes that reputed sustainability standards are the future of green and socially responsible procurement. Unlike public reporting or self-declarations, independent certifications are credible tool to demonstrate due diligence and compliance social and environmental standards. For sectors with a wide range of certified goods, such as textiles industry, Directives should encourage reliance on trusted standards in public tenders. Allowing contracting authorities to require or prefer certified products without considering "equivalent" criteria would significantly reduce the information and verification burden on public buyers, reduce litigation that congests the procurement process, while fostering green investments and competition among manufacturers.
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Response to Revision of EU rules on textile labelling

4 Sept 2023

Include organic in the Textile Regulation Voluntary sustainability standards (VSS) play an important role in promoting and securing sustainable production. The UN Forum on Sustainability Standards defines Voluntary Sustainability Standards are rules that producers, traders, manufacturers, retailers or service providers may be asked to follow so that the things they make, grow or do dont hurt people and the environment. VSS are also important for the textile industry. Organically produced fibres have a positive impact on textile goods made with them, in particular if combined with controlled ecologically sound and socially responsible processing. While the term organic is defined and protected by the EU Organic Regulation for agricultural products including fibres, this is not the case for textile goods. Such inclusion is not intended in spite of the fact that already the Impact Assessment, published as part of the review of EU Organic Regulation 834/2007, acknowledged that the exclusion of textiles and clothing from the regulation could be considered a risk to the credibility of the term organic. It was recognised that the global nature of the supply chain would necessitate a global approach to the organic standard for the farm production of organic fibre as well as textile processing and manufacturing. Given the widespread positive image of organic, this legal gap has caused and indeed is causing widespread greenwash (see attachment for examples). GOTS has previously raised concerns regarding the lack of protection of the term organic by the Textile Names and Labelling Regulation EU 1007/2011 and maintains that if organic were to be defined as a protected term for textiles it would properly inform consumers regarding organic textile products, help eliminate greenwash, and would support green public procurement of organic textiles and the many other relevant actual proposals for EU regulations. Consequently, organic must be included as a defined term in the EU Textile Regulation1007/2001. This was also supported already by the 2012 study for COM DG GROW by consultancy Matrix Insight on the need and options for harmonisation of labelling rules for textile products. The study concluded that there would be a positive impact from protecting the term organic in relation to textiles. The four-fold growth in certification to GOTS since the 2012 study serves to reinforce the potential benefit. Textile products sold as organic should be produced from organic textile fibres according to globally recognised organic farming standards (e.g. the EU Organic Regulation) and processed, certified and labelled according to a recognised and appropriate organic textile processing standard that prohibits hazardous and residual inputs according to clear criteria. GOTS supports IFOAM Organics Europes Position Paper (Organic Textiles: Protecting the Integrity of the Organic Label: https://www.organicseurope.bio/content/uploads/2022/08/IFOAM-OE_Position-paper_Organic-textiles_2022.pdf?dd), which proposes that the following definition is included in the Textile Regulation 1007/2011: The term organic and equivalent terms such as eco, bio, ecological (as per art. 30 of Regulation (EU) 2018/848 on organic production and labelling of organic products) in relation to textile and clothing/apparel may only be used if: 1. the goods have been produced in accordance with a recognised, independently set organic textile scheme, that meets the following criteria: a. The scheme should be independent and impartial. b. The scheme should be established accordingly with an open and transparent standard-setting process in line with industry best practices. c. the label requirements are based on objectively verifiable and non- discriminatory criteria. 2. the goods are certified by a duly accredited and independent certification body. 3. the goods clearly differentiate between textiles containing organic fibres and organic textiles.
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Response to Ecodesign for Sustainable Products - Product priorities

3 May 2023

The JRC preliminary study on new product priorities provides a comprehensive overview of the product priorities for the Ecodesign for Sustainable Products Regulation (ESPR). It provides relevant detail on the textile sector. Global Organic Textile Standard (GOTS) acknowledge that textiles represent one of the highest priority product categories to be addressed in the ESPR in view of the high environmental impact (scoring 43 the highest amongst all product categories page 9), and the fact that textiles and footwear have the second highest market value (page 7) clearly demonstrates the priority that this category must take. GOTS welcomes this opportunity to provide comments on the relevance of organic textiles to the objectives of the ESPR. We believe that the term organic should be protected also for textiles. This would enable organic to be a clear and substantiated claim, based on clear organic farm production standards and an appropriate processing standard covering all steps in the processing chain from raw fibre to finished product. GOTS is a global voluntary standard (Version 6.0 of the standard) for processing of certified organic farmed fibres into finished organic textile products. Box 10 (page 163 177): Factsheet for Textiles and Footwear provides clear information on the environmental impact of conventional fibre production and the lower impact of organic fibre production. This means that organic fibre is highly relevant to the ESPR. However, the environmental impact of chemicals used in textile processing should also be considered. GOTS imposes strict hazard criteria that exclude many chemicals used in conventional processing. This protects the environment as well as the health of consumers and workers. Furthermore, GOTS includes clear social criteria although this is not included in the ESPR we believe that a sustainable product should satisfy both environmental and social criteria. GOTS considers that both organic farm production and appropriate processing are key to the organic textile label. Organic textiles must be produced from organically farmed fibre with appropriate processing, so that the whole product is organic. Only organic fibre is not sufficient to define an organic textile product. This is the same as for organic food products only products where farm production and processing both meet the requirements of the EU Organic Regulation (EU) 848/2018 may be labelled as organic. However, the EU Organic Regulation does not cover non-food products such as organic textiles. Furthermore, the Textile Regulation (EU) 1007/2011 (referred to in Policy Gaps on page 173) does not include organic when referring to permitted label names for textiles. Consequently, because organic textiles are not included in regulation (EU) 848/2018, neither is the term organic included in Textiles Regulation (EU) 1007/2011. The term organic is also not included in the ESPR. This means that greenwash is prevalent. This needs to addressed through the inclusion of the term organic in relation to textiles in the Textiles Regulation (EU) 1007/2011 and in the Ecodesign for Sustainable Products Regulation.
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