Sympatex Technologies
Sympatex
At Sympatex, we have made it our goal not only to do what is required by law but also what is technically possible to make our contribution so that the textile industry can close the ecological loop as quickly as possible.
ID: 068469941546-22
Lobbying Activity
Meeting with Virginijus Sinkevičius (Commissioner) and
7 Oct 2022 · To exchange on the commitments of the EU Strategy for Sustainable and Circular Textiles, including sustainability and information requirements for textiles, tackling green-washing and promoting circular business models
Response to Sustainable Products Initiative
22 Jun 2022
Sympatex fully supports EU policy to regulate that design for circularity becomes the norm for new products in order to ensure that waste is avoided at the end of life and material ressources are used in the most economic way. This is not only a moral imperative for future generations, but it will create a level playing field for manufacturers placing products on the EU market and at the same time will boost a resource limited economy.
Sympatex main comments on the ESPR proposal are the following:
• Sympatex truly welcomes the ESPR and welcomes the future adoption of ecodesign criteria for textile products. As an industry, we should press the accelerator as much as possible now that a direction is set. Ecodesign will make the industry more sustainable, will ensure a level playing field and boost innovation through channeling creativity.
• Minimum design requirements for textile shall include:
o Clear rules specifying requirements for design for economic efficient recyclability and rewarding recyclability analogously to durability. This should include restricting materials where no economic recycling solutions are available on the market as well as substances that hinder recycling: the most sustainable garment is a garment, which has a long lifetime, high quality and can be recycled to a new product to truly close the loop.
o high minimum requirements for recycled content for materials where recycling technology is readily available today e.g. polyester-based textiles. We call on the EU to legislate a 50% recycled content target in all textiles by 2025 and 95% by 2030.
• The Product Environmental Footprint methodology should serve as a basis for product requirements for apparel and textiles. Nevertheless, the PEF as it stands today needs to better integrate circularity and end-of-life to serve both purposes.
• The Digital Product Passport shall prioritises the disclosure of data required to accelerate the circular economy i.e. information on a need-to-know basis to allow for better recycling at end-of-life. For the supply chain, transparency should be favoured against traceability as it is the most economic means for transformation. SME’s should also be given additional support to effectively implement the DPP. Data carriers attached to the prodcuts shall not hamper the recyclability of the products.
• Involve the appropriate set of stakeholders when product requirements are developed. As eco-design will move to become more focused on circular design, it is key to ensure that the whole value chain relevant for circular design is duly represented. Brands and manufacturers should be directly represented as well as the expertise and input from end-of-life managers like recyclers.
• Develop markets for uptake for recycled materials through mandatory green public procurement standards rewarding recycled content and design for recyclability. GPP should become the leading role model and set the standards.
• Ensure strict compliance with and strong market surveillance of ecodesign requirements as this is essential to create the level playing field.
• Sympatex fully supports the planned ban on destruction of unsold goods - and to implement it immediately. In cases where unsold stock is available, it should be offered to circular business startups in order to support their first steps in going to the market. This would create a clear incentive to limit production to the actual demand as well as incentivising new circular business models.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Feb 2022
Shifting to a circular economy is both an urgent societal necessity, but also an economic opportunity.
For the revision at hand, the EU is considering waste prevention measures specifically for the textile sector, whilst also aiming to further boost the fiber-to-fiber recycling industry in the EU. Both efforts will be essential for upgrading the industry towards a circular system. It is therefore important to point to a few inconsistencies the WFD revision process should address.
The EU’s waste hierarchy is one of the main tools to guide actions for preventing waste and recycling waste at the highest value level, while each level has differing leverage depending on which sector one looks at. It is therefore crucial to recognize the need to critically evaluate what the most effective level on the Waste Hierarchy is in each specific situation. The different levels of the EU waste hierarchy reflect the order of preference for how to prevent and treat waste, but not necessarily the order of effectiveness to minimize waste for a specific
industry. We thus support the development of further guidance and a critical methodology to assess the waste reduction potential and the true reduced environmental impact of each level in the waste hierarchy.
In the context of the textile industry, the potential of EU waste prevention measures should not be overestimated. By solely focusing on these measures, the revised WFD could overlook measures with a higher impact – and which must be included when deciding on an
effective EU waste policy. Waste created before product consumption, i.e. production waste is limited in the textile industry (~15%) and there is already a clear economic incentive to reduce this further.
On the other side, the assumption that designing products for longevity, and garments specifically, will automatically reduce overall consumption due to longer product use, is questionable. More than half of today’s collected apparel is still fully re-wearable i.e. can be resold. This underlines that consumers not necessarily wear clothes longer, even though the technical quality of the garment would allow for much longer use. Longer use is mainly a factor of consumer choice, only limited due to material qualities – so extending lifetime will not lead to a reduction in consumption per se.
Without fundamental changes in the consumer’s consumption behavior, longevity will simply delay the waste problem and not solve it.
The most effective way to decouple waste generation from economic growth in the apparel industry starts at the end of life of products. By rerouting apparel waste back into the raw material process, the apparent end-of-life of garments reverts into a new beginning-of- life. With clearly prescribed recycling content targets for the textile industy, economic growth can go hand in hand with waste reduction.
To be able to recycle the waste at end-of-life and avoid the waste leaking into the environment or being incinerated, Sympatex strongly supports the call for ensuring design for recyclability to effectively enable recovering waste through high-value fiber-to-fiber recycling. For the EU to implement its intentions on waste prevention efforts and the ambitious on the Waste Framework Directive, establishing an obligation for designing products for recyclability, is essential. The anticipated SPI will be a crucial enabler for efficient recycling processes – i.e. through
banning all materials that have not a proven recycling technology/process in place today and establishing high preference for mono-materials. To create the needed pull to establish the infrastructure for high-value recycling, high recycling targets combined with recycled content requirements, are essential.
Finally, Sympatex welcomes the intention to set rules for separate waste collection and expanding EPR obligations to textiles.
Read full responseResponse to Measures to reduce microplastic pollution
18 Jan 2022
We have identified the unintentional release of microfibres as a key issue since 2018. In the past few years, we conducted several studies with independent experts. Our initial feedbacks to the call for evidence reflect the knowledge gained through these studies and wider industry initiatives, such as the Microfibre Consortium. In 2019, Sympatex joined the Plastic Leak Project , an initiative co-led by Quantis and the eco-design center EA, with the objective to identify effective solutions to tackle plastic leakage along the life cycle of our products. We focus on quantifying the leakage of a new outdoor jacket. The results of the assessment revealed that 28% of the plastic used across the life cycle of the jacket leaks into the environment. Approximately 99% of this leakage was found to occur not during use phase (washing of the product), as it is commonly assumed, but rather at end-of-life. At this stage, the leakage is due to inadequate waste collection and treatment systems in developing countries where 50% of the used apparel is estimated to be exported to give them a second life.
1. Measures should cover all microfibers unintentionally released, including natural fibres
Given that natural fibers are often treated with chemicals and dyes, their capacity for natural degradation is significantly impacted.
2. Barriers to be lifted through the upcoming EU policy framework
We call on the European Commission to
- Follow a science-based approach to further understand where the leakage takes place along the value chain, to identify its root-causes as well as the best prevention measures to implement across the industry;
- Allocate the relevant funding to support cross industry alignment to ensure research is meaningful and impactful.
- Recognize the need for trans-industrial collaboration to implement efficient measures to prevent the leaking of microfibers into the environment (e.g. obligatory filters for washing machines, textile waste collection systems).
3. Ecodesign: coherence with existing EU initiatives and the weaknesses of biodegradability
Enabling better material choices across all types of fibres is essential. Ecodesign requirements should be driven from science-based understanding of how fibres are shed from textiles so that root cause change can be factored into the development of new fabrics.
Furthermore, design for circularity it the main key to prevent the dominating source of microfibers leaking in the environment, i.e. inappropriate textile waste treatment.
We call on
- the Sustainable Product Initiative to set maximum benchmarks for all types of microfiber shedding on product level;
- the EU PEF methodology to integrate microfibre leakage into life cycle assessment.
- the Sustainable Product Initiative to set clear targets on product level for a transformation of the textile industry towards circularity;
Sympatex does not support biodegradable fibres as a solution, due to the mounting evidence around the lack of the lack of biodegradation potential of so called ‘biodegradable fibres’ in locations where factors that promote biodegradation (UV, temperature, oxygen, appropriate pH, microbes etc) are absent – e.g. deep sea, soil etc. In this sense, we support The Microfibre Consortium’s Biodegradability Statement .
Furthermore, we consider it counterproductive to foster solutions that will actually support the buy-use-discard mentality of the consumer. And finally, the risk of relying on the consumer to separate different fiber types will remain.
4. Address the root-cause identified in the Plastic Leak Project: End of life
EU policy measures should look at the end-of-life stage of a product. For instance, the largest source of microplastic leakage by far takes place at the end-of-life of a garment. By truly building a leak-free circular system where products and materials are designed to be recovered through recycling, the biggest source of microplastics is eliminated.
Read full responseMeeting with Virginijus Sinkevičius (Commissioner) and
17 Jun 2021 · To discuss the forthcoming EU textiles strategy