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The Changing Markets Foundation partners with NGOs on market focused campaigns.

Lobbying Activity

Response to European Climate Law amendment

16 Sept 2025

Ensuring the EUs 2040 Climate Target has a strong and legally binding target is essential to ensure climate goals are achieved and communities in the EU are protected from further global heating and its impacts on health, food security, and economic risk. The current proposal relies too heavily on international credits, which could become a further reliance in the EU enabling the lock-in of unsustainable practices and slowing down the needed emissions reductions at home. A further over reliance on technological fixes will set the EU up for failure in meeting its climate targets in key sectors, particularly in agriculture. Our research has shown that without systems change policies, including a reduction in livestock numbers and dietary shift, the EU will not reduce its methane emissions in line with international targets and the Global Methane Pledge, which it launched in 2021. This lack of international leadership, further opens the door for other countries to step back from climate commitments at a time when urgent reductions are imperative to avoid climate tipping points. Rapid cuts in methane emissions are particularly important as an opportunity to slow down warming and act as an emergency brake. Sectoral targets are needed to ensure action across all greenhouse gases in the EU, including super pollutants that come from agriculture, such as nitrous oxide and short lived gases like methane. Methane from enteric fermentation and manure accounts for 66% of greenhouse gas emissions in agriculture, and nitrous oxide for 30%. Allowing for the proposed sectoral flexibilities is likely to result in continued agricultural exceptionalism, which has led to the lobbying and derailing of many EU policies to date, and the EU missing significant opportunities to pull the climate emergency brake. This is a serious concern for the EUs farmers who are already facing the impacts of climate change on their profits and livelihoods. The EU must include clear targets for reducing greenhouse gases in agriculture and the corresponding support to farmers to achieve this and shift to more sustainable farming practices such as agroecology. According to the EUs own assessment, the sector could reduce its emissions by 44% by 2040, if structural changes and a modest shift to healthier diets is pursued. This was estimated to be even higher by the EUs Scientific Advisory Board on Climate Change, stating up to 56% would be possible. Supporting a transition away from industrial animal agriculture, an important source of EU agricultural emissions, will be key to achieving these climate goals. The EU has a significant opportunity to place its agricultural sector ahead of the game on climate resilience and reducing emissions globally, while setting up farmers in the EU to be best prepared to shift to sustainable practices. Corresponding dietary shifts in the EU could provide the opportunities needed to support both health and climate goals, supporting a reduction in health costs across the EU and leading to economic gains. To achieve this, the EU must include adequate budgets for this in the next long-term budget and ensure all parts of the agri-food chain play their role in the transition, including retailers. The EUs commitment to a just and socially fair transition is welcome and ensuring farmers are supported to transition to more sustainable practices and urgently cut super-pollutants and wider environmental pollution will not only help the EU meet its climate goals, but set the agriculture sector up for a successful future. The Strategic Dialogue stated that the time for change is now and the work on the 2040 Climate Target can be the start of that work, ensuring all sectors have clear and legally binding targets to meet and even go beyond its 90% target.
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and European Environmental Bureau and Deutsche Umwelthilfe e.V.

9 Apr 2025 · 1. Role of the CAP and ‘Vision for Food and Agriculture’ 2. Policy opportunities for methane emissions reduction

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

16 Nov 2023

Recommendations 1.Set performance targets that respect the waste hierarchy and support closed-loop recycling instead of downcycling (e.g. polyester from recycled plastic bottles). Commissions proposal lacks prevention, collection, reuse and recycling targets, potentially compromising the waste hierarchy and undermining the impact of fibre-to-fibre recycling technologies. Our report Take-back trickery: An investigation into clothing take-back schemes underscore the urgency for mandatory performance targets, revealing that 76% of clothes in perfect condition donated to major fashion stores to be reused or recycled end-up destroyed, stuck in the system, or shipped across the world to countries that unable to deal with the amount of used clothing. It exposes a blatant disregard for the waste hierarchy's principles. Recycling targets should be set as a proportion of material that is not reused. Closed-loop recycling and associated targets will be required to support a truly circular economy for textiles. The fast fashion model exacerbates the waste crisis; therefore, prevention targets, supported by durability and repair criteria, are essential. 2.Introduce fees that drive real change: Basing financial contributions on weight of the products does not reflect durability, reusability, recyclability, or environmental impact of items. Regulators can drive product design change by modulating fees on certain environmental criteria. Recommendations: Set higher fees for textiles that are non-recyclable, or have adverse environmental impacts throughout their life cycle and end-of life (e.g. microplastic shedding). Ensure that EPR fees travel with second hand textiles to the destination country so that communities in these countries can pay for collection, repair, and waste management. 3.Mandatory sorting must be fit for purpose: Our investigation, "Trashion: The Covert Export of Waste Plastic Clothes to Kenya," exposes sorting failures within the EU. Investigation in Kenya revealed that 2050% of imported used clothing is unsellable and largely consists of waste plastic clothes. EU exports items unsuitable for the destination: damaged, unfit for local styles, and often soiled or irreparably damaged. This influx causes grave environmental and community consequences, with dumped clothing polluting landfills and the Nairobi River, eventually reaching the ocean. The dominance of synthetics raises concerns about microplastic contamination in water and soil, with some clothes used as fuel, posing health risks for locals. Recommendations: Ensure that there are sufficient inspections of sorting operations to prevent sending waste to the Global South. Ensure that there are strict penalties for operators that are sending waste, equivalent to percentage of their income. 4.Virgin plastic tax to tackle the use of virgin synthetic fibres that underpins the fast-fashion industry. Synthetics make up 69% of all fibre production, and are project to account for 73% of all fibre production by 2030. A virgin plastic tax could help shift the market away from over-reliance on synthetics, account for the negative impacts of such materials (microfibre release, fossil fuel extraction and non-biodegradability) and level the playing field with other fibres, which are more expensive than synthetics. Recommendation: Introduce a review clause obliging the Commission to study the options of introducing plastic tax by 2025. 5.Progressive fees linked to the number of new items placed on the market every year could tackle fast fashion. The marginal cost of placing additional new items would increase as more new items are placed on the market. In addition, a specific threshold for the quantity of new items placed on the market should be set. Recommendation: Introduce a review clause obliging the European Commission to study the options of progressive EPR fees by 2025.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Brunswick Group Limited srl and International Wool Textile Organisation

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

Response to Measures to reduce microplastic pollution

17 Jan 2022

Our research into the reliance of the fashion industry on fossil-fuel derived, or plastic, synthetic fibres, has been published in several reports in 2021 and is part of an ongoing campaign. As part of this research, we reached out to 46 different global fashion brands asking them to disclose key information on their use of synthetic fibres - including any policies they have for reducing microfibre shedding from their clothing. The results of this outreach revealed that fashion brands are asleep at the wheel when it comes to this important issue. Most companies analysed are addressing this issue by joining voluntary industry groups, such as the Microfibre Consortium - which itself has non-binding targets set for only 2030 - or are holding off on any meaningful action until ‘more research’ is done. Yet all research that has been conducted – including a meta-analysis in the Journal of Hazardous materials suggesting microplastics are likely damaging human cells, especially those with irregular shape, such as synthetic microfibres – points in the same direction: that synthetic microfibres are harmful to human health and more persistent than natural microfibres. Many of the brands which responded repeated the assertion that natural fibres are just as bad for the environment as synthetic fibres, despite the science suggesting otherwise. Numerous studies have demonstrated that cellulosic fibres biodegrade in the marine in environment after a period of time whereas synthetic fibres persist and can enter the ecosystem and food chain. While coatings and dyes of all fibre types can be harmful, this is not exclusive to natural fibres and should be addressed as part of phasing out toxic and environmentally harmful materials. We believe it is important that synthetic materials are highlighted as of unique concern due to the persistence of their microfibre pollution. The Commission has many opportunities to address microfibre pollution. For example, the EU textile strategy, where we recommend that the Commission sets out strategies and measures to reduce pollution from the shedding of microfibres from synthetic fibres, as suggested by Science Advice for Policy by European Academics. One such strategy should be reducing the use of synthetic fibres, in line with the precautionary principle. Secondly, set measures and maximum thresholds for the number of microfibres released during the production, use, and end-of-life phases. In addition, explore setting rules on industrial pre-washing and wastewater filtering in European processes, so that these large quantities of microplastics are washed out and collected before the products are sold on the market – putting the responsibility for this on producers, not consumers. Measures to tackle microfibres should come within the framework of wider measures the Commission should adopt to encourage the use of non-toxic circular materials, and introduce ecodesign measures to prevent material mixing and blends, and to eliminate substances of concern – all of which hinder circularity. We also recommend that the Commission introduce a tax on virgin plastic, which should also cover the use of virgin synthetic fibres in the textile industry and it should not incentivise the use of plastic waste from other sectors (such as PET bottles) as a feedstock for recycled polyester fibres in the textile industry, as this does not prevent shedding of microfibres and competes with the packaging industry’s mandatory recycled content requirements. We also urge the Commission to prioritise phasing out synthetic fibres from children’s clothing and collections for new mothers, as there is emerging scientific evidence that young children’s health is the most vulnerable to microfibre pollution.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

5 Oct 2021 · Circular economy and the preparation of the EU Textiles Strategy

Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

16 Jun 2021

The objective of Article 9 SUPD is the seperate collection of plastic bottles in order to ensure that they don’t end up littered in the environment and the evidence shows that the only way to achieve viable and long-term 90% separate collection rates is through mandatory Deposit Return Systems. Furthermore, a high-quality bottle-to-bottle recycling is necessary in order to reach the recycled content target of 30 percent - also part of SUP. Therefore, although the SUPD not only allows for separate collection through DRS, but also other collection modes together with other recyclables, the term “separate collection” should be defined as strictly and precisely as possible. Any weakening of the definition can drastically undermine the core objectives Article 9 had in the first place. Thus, the draft Implementing Act should be adapted so that: • It clearly defines strict requirements for the quality of the material, even if it is collected together with other recyclables, so that closed-loop bottle-to-bottle recycling is still possible: SUP bottles should be collected in a way that allows for recycling into foodgrade material. In a previous draft version of the Implementing Act, this requirement for foodgrade quality was mentioned explicitly. We think that it would be important to make this quality aspect very clear again. At the moment, the requirements are not explicit enough and allow for loopholes. It should be stated very strictly that bottles should not be collected with hazardous waste/contaminated materials, and such a requirement should also not be controlled by industry itself, but by an independent body. • A collection with the residual waste, mixed waste, black bin, etc. should be explicitly ruled out from being counted as separate collection of SUP bottles for recycling. This point should be made absolutely clear by naming all those terms explicitly in the Implementing Act, and not leaving this point ambiguous in any way. Bottles recovered from waste-splitting of residual waste should absolutely be excluded from separate collection, as their quality will be low and the Implementing Act should not support modes of collection that do not reach 90 % collection rate. • The definition of separate collection should be aligned with what the Waste Framework Directive defines as separate collection, otherwise this could set a precedent for future deviation, to the detriment of the environment. Article 3(11) of the Waste Framework Directive defines separate collection as a procedure “where a waste stream is kept separately by type and nature so as to facilitate a specific treatment”. Despite this very clear definition, there have been ongoing discussions among certain stakeholder groups on whether SUP bottles that have been pulled out of the residual/mixed waste can be added to the number of separately collected SUP bottles, in order to reach the separate collection targets set in Article 9 SUPD. Especially in the light of the comprehensive measures to prevent waste and promote recycling that are envisioned within the Green Deal and the Circular Economy Action Plan, the SUPD should be leading the way to strict and consequent legislation, the purpose of which cannot be undermined by ambiguous definitions. We also believe that schemes like for example RECICLOS started by ECOEMBES in Spain should not count as separate collection, because they do not have long-term viability to reach 90% collection rates and they are pushed by the industry as distraction against DRS. This should be clarified to Member States, as otherwise they might lose valuable time to put proper collection systems based on deposit return in place. For more on that see our report More Trash, More Cash, who's really behind the plastic crisis in Spain: http://changingmarkets.org/wp-content/uploads/2021/03/MoreTrashMoreCash.pdf
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Response to EU strategy for sustainable textiles

2 Feb 2021

We welcome the Roadmap as a first step to address the wide range of environmental and social challenges in the textile industry and develop an ambitious comprehensive EU strategy for textiles. This strategy creates a crucial opportunity to tackle the global impact of fast fashion, by making sure the industry shifts to responsible production based on the use of sustainable fibres, and by slowing down consumption and production through a switch to more durable clothes with greater levels of reuse and effective recycling. The Roadmap acknowledges the impact of the ‘Fast fashion’ phenomenon and the need to move towards “more sustainable consumption and production patterns”. However, the Textile Strategy should go further and recognise that this pressure and impact is the result of a business model based on the sale of ever-more new products made from finite virgin resources which have a short useful lifespan and are seldom reused or recycled (the linear economic model). Our new report, Fossil Fashion: The Hidden Reliance of Fashion on Fossil Fuels , exposes how today’s unsustainable fast-fashion business model is deeply rooted in the fashion industry’s dependence on synthetic fibres. There is a striking correlation between the rise of polyester and the explosion of cheap, low-quality clothing that is causing untenable volumes of waste, toxic microfibres and widespread pollution. The use of synthetic fibres, especially polyester, has doubled in textiles in the last 20 years, and already accounts for over two thirds (69%) of total global fibre production. If nothing changes, this is likely to continue growing to reach nearly three quarters of total global fibre production in 2030, with polyester accounting for 85% of this share. As a cheap fibre, costing half as much per kilo as cotton, polyester has become the backbone of today’s throwaway fashion model. The trends speak for themselves, with the average consumer buying 60% more clothing compared to 15 years ago, yet wearing each item of clothing half as long. This trend is projected to worsen as global fashion production leaps from 62 million tonnes in 2015 to 102 million tonnes in 2030. Surveys show that these trends are at odds with what Europeans want from the sector. According to a 2020 Eurobarometer survey, nine in ten (88%) EU citizens thought that clothing should be made to last longer; 77% thought clothing should only be made from materials that can be recycled; nine in ten (88%) are worried about the environmental impact of microplastics; and 87% thought there should be stricter rules when calculating environmental impact and related claims. Without strong legislation from the EU, we will be entirely unable to cope with clothing waste and its environmental ramifications, as well as with the climate implications of the industry’s growing reliance on fossil fuels. The Roadmap and the upcoming EU Textile Strategy should thus recognize this issue and the Commission should adopt measures to decouple fashion from fossil fuels, slow down the rate of clothing consumption, increase the quality of materials (e.g. through mandatory eco-design measures and eco-modulated fees), which should then be separately collected, reused, repaired and ultimately recycled in a viable and environmentally benign fibre-to-fibre process. We believe that this strategy should be framed around the recommendations outlined in the attached document.
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Response to Revision of EU rules on food contact materials

28 Jan 2021

The Changing Markets Foundation welcomes that the Commission has committed to ban the most hazardous chemicals from consumer products, including FCM, and has committed to revising the FCM legislation. We believe this is an important opportunity to establish safer and more sustainable food packaging as part of achieving a toxic-free circular economy. According to the Health and Environment Alliance, currently 63 chemicals used in plastic food packaging are toxic to human health. The health effects of these chemicals used in food packaging include cancer, reproductive disorders and hormone disruption. Scientific studies have shown how these chemicals can move from packaging materials into our food. It is important that the possibility of creating better rules is not constrained by the limits of the current framework on FCMs, which contains numerous gaps and flaws and is ineffective at protecting both people and the environment. Therefore, we believe that a new and efficient legal framework is needed to replace the current regulation, and any attempt to use the current framework will lead to a confused and ineffective system. Crucially, the new legal framework should be guided by five key principles that would ensure consumers are protected from harmful chemicals in their food. 1. A high level of protection of human health 2. A thorough assessment of chemicals in materials and fine articles 3. Effective enforcement 4. A clean circular economy based on non-toxic material cycles 5. Transparency and participation More information can be found here: https://chemtrust.org/5-key-principles-fcm/ The Inception Impact Assessment (IIA) is a welcome first step towards delivering a new framework. The IIA includes a number of positive elements, notably the proposal to ban the most harmful chemicals (tier 1 substances) such as endocrine disruptors and chemicals that are carcinogenic or toxic to reproduction. It is very important that the new regulation applies the precautionary principle and implements a generic approach to managing risks, as opposed to the current system, which only establishes limits for how much of a substance is allowed to migrate into food, even when that substance can cause long-term and irreversible damage to people and the environment. Furthermore, it is important that legislation adopts a class approach to regulating chemicals, rather than seeking to regulate chemicals individually. When a single chemical is proven hazardous to health, then other chemicals with similar properties should also be banned. This approach avoids a banned chemical being substituted with a similarly structured and often similarly dangerous chemical. The roadmap also moves in the right direction when committing to better protection of sensitive populations, such as pregnant women and children. However, we remain concerned that the IIA contains a number of shortcomings that risk undermining its effectiveness. A major concern is that monitoring compliance of the general safety levels of final materials is left to industry bodies, rather than public authorities. In our experience, allowing industry to self-regulate is, at best, ineffective and at worst, open to manipulation. According to the Commission’s own analysis, one of the defects of the current system is that companies have not been able to ensure the flow of information through the supply china and guarantee compliance. In our opinion, relying on industry self-regulation will undermine the whole process. Furthermore, as the EU transitions to a circular economy it is essential that chemicals in recycled materials are regulated to the same level as virgin materials. From a health perspective it is vital that there is adequate regulation and enforcement of harmful chemicals all types of recycled FCM. Finally, we are concerned that the roadmap does not mention the consumer’s right to know about hazardous chemicals in the products they buy.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

We agree with the feedback by the European Environmental Bureau, which they have handed it (EEB proposals for a more coherent EU Product Policy Framework contributing to the Circular Economy). We have a few additions as that we have encountered as part of our campaigns, notably our campaign to increase circularity of the carpet sector. We have listed here some of their main points, followed by our additional input: An integrated policy approach towards performance in a Circular Economy. We think “an agreed common set of criteria on performance of products and services in a circular economy” would help streamline policies and speed up the process of widening product policy to more sectors, such as carpet. We welcome the focus on plastics and chemicals. We want to highlight the importance of incentives to improve healthy, reusable, durable and closed-loop design of plastics, and that these should be applied across the board so also include textiles and carpet. Ecodesign approaches for non-energy related products and services. We agree with EEB's point and in addition, we think the selection of products and services should include especially those sectors where there is a high risk for vulnerable populations like babies to get into contact with toxics on the one hand, where there are innovations in terms of healthy, circular, closed-loop product design available, waiting to get scaled up. These sectors have a high potential to become healthy and circular, but need policy support to create a level playing field for producers, increase collection and recycling rates and ensure infrastructure build-up – we think the carpet sector is such sector and recommend that the Commission studies this sector and its potential with priority. An EU harmonised and digital Product Information System. This is necessary for all products in a circular economy. Information on the product (materials), chemical and waste information should become mandatory across all sectors. Again, the example of carpet shows that current voluntary product information initiatives do not give enough information to recyclers nor consumers, neither on product aspects, circularity and on the chemicals used. We have attached a joint NGO briefing on toxics in carpets in the EU and pathways to reduce toxicity and increase circularity of the sector. More reports and information on our work on can be found at changingmarkets.org/campaigns
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Meeting with Vytenis Andriukaitis (Commissioner) and

1 Jun 2018 · Pharmaceuticals in the environment