Stichting OCA
OCA
Organic Cotton Accelerator is a multi-stakeholder organisation advancing farmer prosperity whilst creating a transparent, resilient, and responsible organic cotton supply chain.
ID: 512556252856-43
Lobbying Activity
Response to Circular Economy Act
4 Nov 2025
The Organic Cotton Accelerator (OCA) welcomes the European Commissions commitment to advancing circularity in the EU through the forthcoming Circular Economy Act. We support the Acts objective to strengthen Europes resource efficiency and resilience. We also urge the EU Commission to maintain a high level of ambition on sustainability, while ensuring coherence with existing legislative initiatives, such as the Eco-design for Sustainable Products Regulations (ESPR) and the upcoming New EU Bioeconomy Strategy. The textile industry remains one of the most resource and emission-intensive sectors in the global economy. Emissions are generated at multiple stages of the value chain, from fertilisers and pesticides in fibre cultivation to land-use change energy-intensive processing and heavy reliance on fossil fuels in material production. Raw material extraction alone accounts for 21% of the textile industry emissions (Circularity Gap Report: Textiles, 2024) and global fibre output remains 88% fossil-based (Textile Exchange, 2025). The dependence on virgin, fossil-based inputs reveals a key challenge: recycling alone cannot deliver a fully circular textile sector. Current infrastructural and economic limitations make it difficult for secondary raw materials to meet growing industry demand. To achieve true circularity, the Circular Economy Act must therefore look beyond secondary raw materials and recognise the potential of sustainably sourced renewable materials as part of the solution. The ESPR introduces the concept of ''sustainable renewable materials, which offer essential environmental and social benefits that contribute to genuine circularity. While the concept has not yet been legally defined, it is increasingly recognised across industry and policy discussions as a priority area. Several organisations and alliances have issued or are developing position papers calling for clear definitions and criteria to distinguish truly sustainable renewable materials from other natural or bio-based inputs. Recognising such materials in the Circular Economy Act would help advance the goals set out in the European Green Deal, the Clean Industrial Deal, and the Competitiveness Compass, by regenerating nature, reducing reliance on finite resources, and ensuring that circularity delivers both environmental and social value across global supply chains. In this context, OCA invites the Commission to consider the role of sustainably sourced renewable materials in advancing circularity in the textile sector, alongside addressing current challenges such as market fragmentation, waste management, and secondary raw material flows.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
Cotton is the worlds second most used textile fibre and the largest driver among natural fibres (Textile Exchange, 2024), yet its conventional production often involves known significant environmental and social costs. By avoiding synthetic pesticides, synthetic fertilisers, and genetically modified seeds, organic cotton represents a sustainable and regenerative approach to cotton production that benefits farmers and nature. In spring 2025, the Organic Cotton Accelerator (OCA) published a regional Life Cycle Assessment from India demonstrating that organic cotton consistently yields lower greenhouse gas emissions, reduced water usage, and fewer pollutants compared to conventional cotton, consistent with other scientific literature and industry reports. Furthermore, the EU Agriculture and Food Vision officially recognises organic farming as best practice in generational renewal and protection of ecosystem services, reinforcing the need to integrate materials like organic cotton into policy frameworks. When it comes to raw materials production, placing organic cotton and other organic fibers at the forefront of its Bioeconomy strategy would align with this vision, embedding its environmental benefits within measures aimed at restoring biodiversity, improving soil health, and uplifting farming communities. The textile industry significantly contributes to rising GHG emissions through various processes, including the extensive use of fertilisers and pesticides for natural fibre production, land-use changes to expand agricultural areas, material production and finishing. Raw material extraction, whether from plants, animals, or the Earth (fossil fuels), represents 21% of the textile industry emissions (Circularity Gap Report, 2024). Natural bio-based textiles like organic cotton represent a promising shift to advance sustainability in textiles and reduce the use of fossil-based resources. However, not all bio-based textiles are inherently low-impact. The promotion of bio-based alternatives must be guided by sustainability criteria that are well established in existing and upcoming EU frameworks and recognised, credible international standards that are aligned with the SDGs. These should include environmental, social, and governance considerations linked to the sourcing, cultivation, and processing stages. The Ecodesign for Sustainable Products Regulation (ESPR) introduces the concept of sustainable renewable materials, yet its definitions must be fully aligned with the Bioeconomy Strategys understanding of bio-based materials. We strongly encourage the European Commission to ensure consistency between definitions of sustainable renewable materials (under ESPR) and bio-based materials (under the Bioeconomy Strategy) to ensure that bio-based materials recognised as renewable are also demonstrably sustainable in environmental and social aspects. Without this consistency, policy risks being fragmented, undermining efforts to elevate traceable and truly sustainable materials like certified organic cotton. In addition, the Bioeconomy Strategy should reinforce the role of primary producers, especially smallholders, to support the sustainable development of rural livelihoods, boost biodiversity, while supporting climate change mitigation and adaptation. The cultivation and extraction of bio-based materials, as well as their processing, carry significant socioeconomic implications for farmers and farming communities in third countries. Sustainable farmers are the backbone of the production chain, without them there is no production, no intermediate materials, and no supply chain resilience. The new Bioeconomy Strategy must include all supply chain actors, both within and beyond the EU borders. We encourage the EU to explore the need and appropriateness of bringing bioeconomy under international multilateral fora and promoting green diplomacy on bioeconomy, including trade negotiations and international cooperation.
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