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International Wool Textile Organisation

IWTO

IWTO is the recognized global authority for standards in the wool textile industry, and since 1930, IWTO has represented the interests of the global wool trade.

Lobbying Activity

Response to Circular Economy Act

3 Nov 2025

Circular Economy Act Call for Evidence The International Wool Textile Organisation (IWTO) is the global authority for standards in the wool textile industry. Founded in 1930, today IWTO has represented 41 members across 28 countries, spanning the entire wool textile pipeline from farm to retail. Headquartered in Brussels, IWTO's European membership includes eight EU member states plus members in EEA countries, EFTA members, and the UK. IWTO strongly supports the Commission's goal to accelerate circularity and strengthen the single market. To achieve this, the Circular Economy Act must integrate both technical and biological circularity, recognising renewable, biodegradable, and regenerative materials as essential to eliminating waste and regenerating nature. KEY RECOMMENDATIONS: 1. DRIVING CIRCULARITY THROUGH SUFFICIENCY Circularity requires addressing overproduction and overconsumption, not just recycling efficiency. The Act should integrate sufficiency-based instruments: targets for reducing production volumes, measures to curb planned obsolescence, and incentives for fewer, higher-quality goods. Reducing waste at source is the most effective path to circularity and will strengthen Europe's resource resilience. 2. KEEPING TEXTILES IN CIRCULATION AT HIGHEST VALUE Circularity must go beyond physical durability to include functional, sensory, and emotional qualities that influence product longevity. Quality, functionality, and comfort are essential: products that perform well and feel good are kept, cared for, and reused longer. Minimum recycled content targets should not compromise these qualities, as recycled fibres behave differently. The Act should prioritise design that maintains functionality and user satisfaction. Natural fibres are used longer due to comfort and quality, fostering emotional durability that supports repair, resale, and reuse. 3. INTEGRATING REGENERATION, BIODEGRADATION, AND RENEWABILITY Circularity must allow materials to safely return to nature. Renewable natural fibres biodegrade and, when managed regeneratively, enhance soil and biodiversity. The Act should recognise biodegradability, renewability and regeneration as core enablers of circularity, on equal footing with reuse and recycling, and ensure "end-of-waste" and product criteria reflect these biological processes. 4. A JUST AND REGENERATIVE TRANSITION Natural-fibre production sustains rural livelihoods, supports cultural heritage, and empowers women and smallholders. A regenerative circular economy must promote fair livelihoods, social resilience, and rural vitality, not only material efficiency. Recognising the social and ecological value of renewable fibre systems strengthens the EU's global leadership and links circularity with environmental regeneration and social justice. CONCLUSION: The EU can accelerate its transition and reduce dependence on fossil-based materials by integrating biological circularity into the Circular Economy Act. Natural fibres are vital to a circular economy that truly eliminates waste, keeps materials in use, and regenerates nature. By prioritising garments that stay in use longer and materials that safely return to nature, the Act can deliver real circularitynot just recycling, but renewal.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

Fossil carbon emissions are confirmed in any Google search to be the greatest driver of the worlds climate crisis, yet application of CBAM to textiles would unfairly promote fossil-based fibres (i.e. polyester and nylon) over natural fibres like cotton and wool. This is due to inequitable assessment of carbon emissions. For natural fibres, the impacts of fibre formation are fully counted (i.e. the greenhouse gas emissions from farming are included) but for fossil fuel-based fibres the impacts of forming oil are not counted - only the impacts of extracting the oil and onward are counted. This is due to the general principle in life-cycle assessment that only human-driven impacts shall be considered. With the majority of natural fibre emissions occurring during the fibre formation stage, the omission of comparable data for synthetic fibres clearly results in an unfair comparison. Rather, a fair comparison of natural and synthetic fibres would commence at the extraction point. For fossil fuel this is at the wellhead, for cotton at harvest and wool at shearing. This approach of excluding geological and biological processes that are not caused by humans will avoid CBAM delivering a perverse outcome. We have no more control over the cellular mechanisms that create the billions of fibres (wool or cotton) in an animal or plant than we have control over the geological process that generate oil, coal and gas.
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and

3 Apr 2025 · Exchange of views on the Green Claims Directive

Meeting with Aurel Ciobanu-Dordea (Director Environment)

7 Jan 2025 · EU's Strategy for Textiles

Meeting with Daniel Buda (Member of the European Parliament)

13 Nov 2024 · Green Claims Directive

Response to Sustainable Products Initiative

21 Jun 2022

The International Wool Textile Organisation (IWTO), representing the global wool textile industry, welcomes the European Commission’s proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products, the Ecodesign for Sustainable Products Regulation (ESPR). We support the goal of having products with longer lifetimes and a move away from a linear, disposable business mindset towards one that designs with longevity, reuse, repairability and recyclability in mind. We would like to point out some important considerations pertinent to textiles, for the Commission to consider. First, the interrelated issues of overproduction and the use lifetimes of textiles: 1. Overproduction is a major sustainability challenge in the textile industry. Promoting longevity and repairability of textile products, however, will not necessarily reduce overproduction. 2. Textiles with longer lifetimes will not automatically reduce the rates of purchase of new items or the disposal of used items. Discarded clothing, for example, is often unwanted for reasons that have nothing to do with its ability to have a long lifetime, nor with it being worn out or needing repair. 3. Clothing may be used very little because it is no longer wanted aesthetically or fashionably. When this is the case, the product will have a large environmental impact no matter how long it may last in a technical sense or how repairable it is. 4. A strategy for ecodesign of clothing must account for the ways in which, and the degree to which, clothing and other textiles are used/not used. Second, regarding the concept of durability: 1. Durability of products is mentioned as a key objective of the proposal for ESPR. Physical durability assessment of clothing is currently a dominant feature of the Product Environmental Footprint Category Rules (PEFCR) for Apparel & Footwear as well. 2. In the Apparel & Footwear PEFCR, accounting for important non-durability factors and incorporating these impacts in the overall score is yet to be decided. Given the likelihood of the PEFCRs to underpin ESPR and other initiatives, it is vital that the non-durability related factors which contribute to early obsolescence be accounted for in the PEFCR scoring, in order to fully inform consumers of expected product lifetimes. 3. Echoing what we said above, physically durable clothing does not necessarily equate to longevity in terms of utilization of products. 4. It is worth noting that while synthetic textiles are much stronger in test situations than natural materials, natural fibres are in fact used longer. Thirdly, points on repair and recycling: 1. Clothes are mainly repairable. When they are not repaired, it is because the repair is considered not worth the effort to do so. 2. Textile to textile recycling is very limited. There is no large-scale recycling of textiles. Recycling natural fibre textiles into new products does take place but needs to be scaled up. 3. Risks of recycling must be assessed. For example, the practice of using recycled PET in clothing because doing so allows the item to be labelled “recycled”. This essentially leads to even more fossil fuel materials in clothing – an outcome which seems inconsistent with the goals of the Regulation. Respectfully submitted, IWTO
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Meeting with Marc Tarabella (Member of the European Parliament)

10 Feb 2022 · Make the Label Count

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Brunswick Group Limited srl and Stichting Changing Markets

18 Jan 2022 · Circular economy, EU Textiles Strategy and PEF methodology for textiles

Response to Measures to reduce microplastic pollution

16 Dec 2021

Microplastic pollution is a global challenge across many industries and sectors – one of critical importance being textiles. A 2021 study by the California Ocean Science Trust and a group of interdisciplinary scientists acknowledges that microfibres from textiles are among the most common microplastic materials found in the marine environment. Every time synthetic clothes are manufactured, worn, washed , or disposed of, they release microplastics into terrestrial and marine environments, including human food chains. Synthetic fibres represent over two-thirds (69%) of all materials used in textiles, a proportion that is expected to rise to 73% by 2030. The production of synthetic fibres has fuelled a 40-year trend of increased per capita clothing consumption. Global textile consumption has become 1) more reliant on non-renewable resources, 2) less biodegradable, and 3) increasingly prone to releasing microplastics. The increased consumption is also discretionary, driven by consumer desire and remains unchecked. Thus, the long-term trend in the textile industry parallels the intentional addition of microplastics to products such as cosmetics. The contrast is that the European Chemicals Agency has recommended such intentional additions be restricted, whereas the over-consumption of synthetic fibres continues unchecked. One way for the EU to account for and mitigate microplastic pollution is through an EU-backed methodology measuring and reporting microplastic emissions, so that consumers and procurement officers have the information needed to minimise microplastic pollution resulting from their purchasing decisions. There is a critical opportunity to address microplastic pollution in the fashion textile industry through the EU Product Environmental Footprint (PEF) methodology. To meet the environmental objectives of the Circular Economy Action Plan, the EU is proposing that companies substantiate their products’ environmental credentials using this harmonised methodology. However, microplastic pollution is not accounted for in the PEF methodology. This omission has the effect of assigning a zero score to microplastic pollution and would undermine the efforts of the European Green Deal, which aim “to address the unintentional release of microplastics in the environment.” The incorporation of microplastic pollution as an indicator would increase the legitimacy of the PEF method as well as better inform consumer purchasing decisions, especially as the European Green Deal seeks to “further develop and harmonise methods for measuring unintentionally released microplastics, especially from tyres and textiles, and delivering harmonised data on microplastics concentrations in seawater.” Whilst we continue to learn about the damage of microplastics and there is new knowledge emerging on the toxic impacts along the food chain, there is sufficient information on the rate of microplastic leakage into the environment to implement a basic, inventory level indicator in the PEF now. This is consistent with the recommendations of a review of microplastic pollution originating from the life cycle of apparel and home textiles. There are precedents in PEF for basic level (e.g., ‘resource use, fossils’) and largely untested (e.g. land occupation and toxicity indicators) indicators, and therefore an opportunity for the EU to promote research and development in the measurement and modelling of microplastic pollution by including such emissions in the PEF methodology. For such an indicator, the long and complex supply chains of the apparel and footwear industry would be a test case with high-impact and a global reach. Respectfully submitted, International Wool Textile Organisation References are provided in the attached file
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Meeting with Eduard Hulicius (Cabinet of Vice-President Věra Jourová)

24 Nov 2021 · Green transition

Meeting with Alice Kuhnke (Member of the European Parliament)

7 Oct 2021 · Sustainability labelling (staff level)

Response to EU strategy for sustainable textiles

2 Feb 2021

IWTO, the International Wool Textile Organisation, welcomes the Commission’s initiative to develop a European strategy for sustainable textiles and the invitation to respond to this consultation. IWTO is the global authority for standards in the wool textile industry. Since 1930, IWTO has represented the collected interests of the global wool trade. IWTO’s 33 members are located in 23 countries around the world, and represent all stages of the wool textile pipeline, from farm to retail. As the Roadmap recognizes, textiles permeate our culture. Beyond what we put on our bodies, we use textiles in our homes, offices, cars, classrooms, shops, restaurants, you name it – look around you now and wherever you may be, chances are that you are in immediate contact with some form of textile. We agree that the textile industry has the potential to shape a much-needed carbon neutral and circular economy. In this respect, we support the intent of the EU to address textile waste collection, sorting and recycling and to set targets to significantly increase reuse and recycling efforts. Our long experience with recycling wool apparel shows there is a viable way forward and the re-use of valuable fibres is paramount to sustainability. Furthermore, we see Extended Producer Responsibility as an effective means of influencing product design for circularity. “Start as you mean to go on,” the British say, and this could not be more pertinent than textiles. It is only by designing for long service, using material with cost-effective end-of-life pathways, will we begin to move away from pretending that the “make-use-and-throw-away” model is doing anything but harming our habitat. We also urge the Commission to make clear how microplastics impacts will be communicated to the consumer, and to ensure that legislation supports and rewards the true circularity we all deserve.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

The International Wool Textile Organisation (IWTO) represents the collective interests of the global wool industry. We are based in Brussels and our goal is to ensure a sustainable future for wool through scientific research, wool textile education and knowledge sharing. Our members come from all stages of the wool textile pipeline, from farm to retail. IWTO agrees with the identified need to clarify and control methodology for substantiating green claims. We support voluntary adoption of labelling using PEFCR methodology until the methodology for apparel has been proven to be robust and meaningful. Premature adoption of mandatory labelling risks the PEF system losing credibility with business and the public, for whom the labelling is designed to help identify truly sustainable products. Summary: PEF is a commendable initiative, but it is not yet market-ready. Any planned adoption must be voluntary only. This system is not yet suited to handle the complex global fibre supply chain and further methodological development, taking an international perspective, is urgently needed. We provide examples from the field of textiles to demonstrate this point in the attached document, and on these points: 1) Accounting for renewable raw materials A sustainable textile industry requires a sustainable supply of environmentally friendly raw materials. Raw materials ‘grown’ on a farm are inherently circular. They can be grown again every year and at the end of life, biodegrade, returning their nutrients to the soil to be used again. However, an explicit assumption in LCA methodology (and hence PEF) is that raw materials are "extracted" (i.e. mined). Comparisons between textiles comprised of synthetic and natural fibres are compromised by the way the system fails to account for renewability. This results in an implicit bias against renewable raw materials. This fundamental system boundary difference exists because fossil fuel derived fibres do not include the biological processes required to generate the feedstock (because these processes occurred millions of years ago). Rather, fossil fuel supply chains begin with the extraction of raw material from the ground, largely free of any environmental footprint. In contrast, assessment of renewable, natural fibres includes all the environmental impacts associated with growing feedstock like cotton and wool fibre on farms (i.e. the plant and animal processes involved, and the agricultural system required to support these). Typically, LCAs for renewable agricultural production show high impacts for land use (i.e. the farm), nutrient addition to the soil, water consumption and GHG emissions, whereas sourcing fossil fuel involves minimal land use (i.e. land for the oil drilling rig), water consumption and GHG emissions. 2) Overlooking microplastics Over 60% of global textile fibre production is synthetic (plastic) and washing of textiles is an important contributor to microplastic pollution of the sea. Summary: The impact statement must conduct a thorough investigation of potential bias caused by the omission of impact categories such as renewability and microplastics. This is relevant for organic systems and more generally for systems based on natural production that are commonly compared to synthetics. 3) Trade barrier risks associated with the PEF methodology Summary: The impact statement must investigate revision of the methods to establish a globally relevant set of environmental indicators and methods in PEF, complying with the aim to create a ‘level playing field’ and to ensure ‘no less favourable treatment of imported products’. 4) Choice of methods for global warming assessment is inconsistent with global accounting requirements under the UNFCCC. Summary: GWP values must be standardised with global reporting requirements and the method should allow new methods for methane accounting as soon as practicable. With Kind Regards, IWTO.
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