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OsloMet – Oslo Metropolitan University

OsloMet

OsloMet aspires to play a leading role as a provider of research-based knowledge related to the welfare state, in Norway and abroad.

Lobbying Activity

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

23 Jun 2025

Europe has incredibly rich and important textile traditions based on wool, linen and other locally produced fibres. European textile production has long been under threat from policies that view outsourcing and global free trade as an unquestionable good. Today, this production (farms, industry, craft) and good clothes for European citizens based on natural fibres are under a new threat: the EU textile strategy [1]. For the biobased textile economy, the worst culprit is the PEF and other similar LCA-based comparative tools [2]. They are not suitable for comparing plastics against natural materials and brand natural materials as the products with the greatest environmental impact. The same goes for the emphasis on the «durability» of textiles, which is most easily achieved by adding more plastic or making clothing entirely of plastic. We ask that the work on the bioeconomy strategy take into account the large problems that farmers, craftspeople, small-scale producers, and the natural fibre-based textile industry in Europe face today. It is urgent either to discontinue the use of LCAs or to find a solution where the LCAs account for the problems caused by plastics (microplastics, non-biodegradability, etc.). A sustainable agricultural system is a patchwork of different resources and products. Focusing on both food and clothing contributes to using the entire animal or plant, and to rotation in the use of land and crops. Textile production engages new farmers and SMEs, many of whom are women who believe in a better future. Safeguarding these important resources is to safeguard the future of the bioeconomy and vibrant rural areas/villages in Europe [3]. While creating new opportunities, such a bioeconomy also safeguards cultural heritage: an important part of Nordic farming is the summer pasture farms. These small mountain farms are only used during summer in order to bring the cattle to fresh grassland. The grasslands have no alternative use due to their location high in the mountains and steep hillsides. The use of these farms reduces the need for concentrate and increases animal welfare, since life here is more in line with natural behaviour compared to a barn. The summer mountain pasture was recently listed as a UNESCO Intangible Cultural Heritage [4], but the number of these farms is declining rapidly. We suggest examining how other EU strategies directly counteract/hinder the bioeconomy and finding ways to avert the gravest consequences of these policy measures. References 1. Clothing Research. Feedback to the EU Textile Strategy. 2022; Available from: https://clothingresearch.oslomet.no/2022/05/04/feedback-to-the-eu-textile-strategy/. 2. Klepp, I.G., et al., Critical review of Product Environmental Footprint (PEF) - Why PEF currently favors synthetic textiles (plastics) and therefore also fast fashion. 2023, OsloMet: Oslo. https://clothingresearch.oslomet.no/2023/02/07/new-critical-background-paper-on-pef-for-apparel-and-footwear/background-paper-on-pef/. 3. Analysys Mason, Policy brief: Farm diversification among young entrepreneurs in the Nordic and Baltic region, Bioeconomy Program, Nordic Joint Committee for Agricultural and Food Research (NKJ). 2025: Lund. 4. UNESCO. Summer farming at fäbod and seter: knowledge, traditions and practices related to the grazing of outlying lands and artisan food production. 2024; Available from: https://ich.unesco.org/en/RL/summer-farming-at-fabod-and-seter-knowledge-traditions-and-practices-related-to-the-grazing-of-outlying-lands-and-artisan-food-production-02109.
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

The data the service providers will handle depends on the content of the Digital Product Passport (DPP) This will be different for the various product groups that the DPP will apply to. It is therefore important that service providers can accommodate different configurations. It is further important that the service providers can provide the transparency needed for the DPP content to be reliable, e.g., access to data for verification or research purposes, and limited to objective information. In the following, our response concerns DPP requirements for textiles and clothing. Here, we further stress that all data made available to consumers in the DPP must be limited to objective information. Systems that are controversial and that build on subjective evaluations, weightings or data-validity such as the Product Environmental Footprint Category rules for apparel and footwear must be avoided as they are in no way or form helpful to the consumer. This will also be important for the service providers, to lessen their burden, and equally for data-providers and the SMEs who will have to implement the DPP. These actors should not be the victims of arbitrary subjective weighting due to lacking and faulty secondary data. Similarly, durability cannot become an objective parameter nor an information requirement, no matter how much the consumer is seeking information on quality. This is based on the fact that most durability parameters favour synthetics. Water and wind proofing information, on the other hand is vital and provide consumers with reliable information about their garments suitability. Information such as the above will empower the consumer vis-à-vis legal rights and guarantees, and here the most pressing issue is to date products. Furthermore, DPP for apparel and footwear should include a standardized size labelling system where the consumer can get reliable information of the garment measurements and what body measurements the garment will fit. Our complete recommendations for the content of a DPP for apparel and footwear can be found here: https://clothingresearch.oslomet.no/input-on-eu-strategy-dpp/
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

2 Nov 2023

The Wasted Textiles policy consortium (The Consortium) welcomes the dedicated attention of the European Commission on minimizing the environmental impacts of textiles and the previously published comprehensive Waste Framework Directive revision proposal. The Consortium has read this proposal in light of the EU's Textile Strategy and with a particular focus on the elimination of the fast-fashion business model, which is a major source of the textile sector's growing environmental and social impacts and the main barrier to implementing sustainable and circular solutions and business models in the sector. The current feedback concentrates on key concerns that the consortium has on the WFD revision, with a special focus on how the EPR is framed, its implications and how the eco-modulation is being envisioned. The feedback takes departure from the defined objectives of the Waste Framework Directive in the document Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2008/98/EC on waste, which says: The overall objective of the WFD revision is to reduce environmental and climate impacts, increase environment quality and improve public health associated with textiles waste management in line with the waste hierarchy and The specific objectives address two distinct problems: volume of textiles waste is not decreasing in line with the European Green Deal ambitions and textiles waste is not being treated in line with the waste hierarchy. Our consortium's feedback is summarised in the following three main aspects, which are elaborated on in the attached document, followed by supplementary comments on selected text from the proposal, also in the attached document. 1. Main focus on waste management and not prevention. 2. Using PEF and ESPR methodology for EPR fee modulation is problematic. 3. The proposed EPR fee size is too low to bring the desired impact and its application should be expanded to the global South.
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Response to Revision of EU rules on textile labelling

29 Sept 2023

Consumption Research Norway SIFO welcomes the revision of the textile labelling rules. SIFO is a not-for-profit research institute at Oslo Metropolitan University (OsloMet). For over 25 years, we have contributed to the knowledge of the consumption of clothing, also including many projects about labelling and consumer behaviour. We encourage this important work and want to contribute with our knowledge about textile consumption including products, labelling and consumers. Our goal is to lower the environmental impact of textile consumption and give consumers reliable, understandable, and relevant information. Attached is our response.
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Response to Environmental claims based on environmental footprint methods

17 Jul 2023

Consumption Research Norway (SIFO) welcomes the EC's efforts to halt greenwashing and the opportunity to provide feedback on the proposal. SIFO is a non-profit, transdisciplinary research institute at the Oslo Metropolitan University. Our research aims to understand the role of consumption and consumers in society and to provide the knowledge basis for public consumer policies. In the attached feedback document, we build on our research concerning greenwashing seen from a consumer perspective along with more specific knowledge of clothing and textiles and the challenges that the industry and authorities are facing in the development of tools to compare the environmental impacts of textiles. Even though [t]he European Green Deal sets out to empower consumers to the green transition» - and this proposed directive will make consumers make more sustainable decisions, we see that there is a danger that the industrys interest in continuing green marketing will be prioritised over environmental and consumer interests. We, therefore, emphasise that the directive actively addresses that green claims must be significant, verifiable, relevant, and understandable for consumers and that knowledge of consumption and consumer interests is taken seriously in the development of the directive. We would like to remind that we are all together the most important stakeholders as consumers and also as citizens because the welfare of tomorrow depends on a rapid reduction of climate and other environmental impacts. Following the points and referenced research in the document we recommend that: - green marketing is allowed only when products have a significantly lower environmental impact than other products and that both negative and positive effects of green marketing are examined. We, therefore, recommend clearly defining what significant improvements mean. - the Commission considers whether its proposals promote fossil materials, and whether green marketing of fossil materials over natural materials is in the interest of the consumers and the environment. - We discourage the use of PEF and other LCA-based tools for comparison of textile products before they in an empirically based, scientific manner, take lifetime (the use phase) into account. And we ask that: - the information provided by the industry (including its various investigative organisations and consultants) is not automatically considered factual, but that it is verified against independent sources and research. This includes that it satisfies the criteria for comparative LCAs, using the same system boundaries and functional units, and that data used is representative of technologies, times and places in all production phases - global averages and other secondary information are used only where it is documented that they are representative and appropriate for the given product or producer. In short, we would like the consumers right to protection against greenwashing to weigh heavier than the industrys wish to market its products as green. This can be done by placing the bar for what entails greenwashing low. Furthermore, we believe that single-use products are incomparable to products used over generations and recommend that lifetime analyses are done, as opposed to focusing on durability and other plastic-promoting suggestions. In other words, we wish for clear and strict definitions of what environmental improvements consist of, reliable and relevant information, and that the rapid plastification of several product groups (including textiles) is not further promoted through environmental regulations.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Aalborg Universitet and Revaluate OÜ

25 Jan 2023 · Implementation of the EU Textiles Strategy and the development of extended producer responsibility for textiles

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen) and Aalborg Universitet and Revaluate OÜ

25 Jan 2023 · Implementation of the EU Textiles Strategy and the development of extended producer responsibility for textiles.