CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU

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CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
ECOPRENEUR.EU
EUROPEAN SUSTAINABLE BUSINESS FEDERATION

CIRCULAR FASHION
    ADVOCACY
A STRATEGY TOWARDS A CIRCULAR FASHION
          INDUSTRY IN EUROPE

                 2019
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
DISCLAIMER

This report has been produced by Ecopreneur.eu, which takes full responsibility for
the report’s contents and conclusions. While funders, members, their company
partners, members of the Board, participating organisations, and those experts
who were consulted and acknowledged here have provided significant input to the
development of this report, their participation does not necessarily imply
endorsement of the report’s contents or conclusions.

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CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
CONTENTS

Foreword                                                       p. 4
Executive summary                                              p. 8
Chapter 1. Introduction                                       p. 12

Chapter 2. What could a circular fashion economy look like?   p. 16

Chapter 3. How to get there: The role of advocacy             p. 21

Chapter 4. An advocacy strategy for Europe                    p. 26

Chapter 5. Conclusions and recommendations                    p. 59

Colophon and acknowledgments                                  p. 63

References                                                    p. 64

                                                                      3
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
FOREWORD
The fashion industry is at a crossroads. The fast spinning wheels of apparel production
have reached such pace and scale that the waste and pollution generated have
become a critical global issue. A staggering 73 per cent of materials used for clothing
are sent to landfill or incinerated, with less than just 1 per cent of the fibres recycled.
Textile production creates greenhouse gas emissions larger than that of international
transport. Hazardous substances escape into the environment and affect the health of
those making and wearing the garments. Plastic microfibres released from clothes in
the laundry machine are polluting the oceans. The fashion industry hasn’t considered
the planet’s boundaries, as it too often focuses on solving short-term economic
problems.

Recent modelling results by the Stockholm Resilience Centre suggest that creating an
economy that meets the Sustainable Development Goals within planetary boundaries
is still possible. However, only by rapid, radical transformations for our entire economy
that decouple natural resource use and impacts from economic progress. This study
shows that the fashion industry is increasingly aware of the need for action to become
a fully circular system. If combined with true efforts to overcome social issues in
producing countries, this can lead to real change and open new opportunities in the
apparel sector.

However, companies cannot act in isolation. Markets cannot ensure efficiency in the
allocation and use of resources if prices do not reflect the true value and costs of
resources. Rewards to capital determine the business case and invite to disregard
environmental externalities and costs. Most managers still make short-term
investment decisions, overly influenced by bonuses based on short-term share prices.

                                                                                              4
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
FOREWORD

Technological progress is essential for the circular economy, but will not be developed
fast enough without a strong demand for circular fashion products – and will not fix
adverse incentive systems.

This report provides insights into the economic dynamics of circular fashion. Based on
the collective experience and business sense of European green small and medium-
sized enterprises and pioneering companies in various sectors, the report provides a
more detailed picture of what policy measures such as extended producer
responsibility, procurement, fiscal incentives and ecodesign regulation can do.
Moreover, where these measures are often opposed by business, the report strongly
advocates their rapid development and implementation in the fashion sector.

Political consensus on how to change it is still lacking, both in the more general
circular economy debate and for fashion. Advocacy is therefore crucial to build
enough support for the EU and member states governments to take decisive
measures to foster sustainable resource management and circularity. While some
businesses achieve great progress already, only governments and adequate
governance models can enable global markets to adopt circular fashion as the new
normal.

I therefore call on the fashion industry to join this advocacy for change.

Janez Potočnik
Partner, SYSTEMIQ

                                                                                          5
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
About the author - Ecopreneur.eu        About the funder - C&A Foundation

Ecopreneur.eu, the European             C&A Foundation is here to transform
Federation of Sustainable Business,     the fashion industry. We give our
sets a course toward sustainable        partners the financial support,
economic policies on the European       expertise and networks so they can
level to support the economic and       make the fashion industry work better
societal transformation across Europe   for every person it touches. We do this
and beyond. Ecopreneur.eu aims at       because we believe that despite the
opening solidified structures and       vast and complex challenges we face,
brings sustainable matters to           we can work together to make fashion
European policy-makers. Ecopreneur      a force for good.
is a non-profit non-governmental
organisation that now holds six         www.candafoundation.org
associations from different countries
of the European Union. Together they
represent over 3000 green businesses,
mostly small and medium-sized
enterprises. While several of these
companies are active in fashion,
Ecopreneur does not represent the
fashion industry.

www.ecopreneur.eu

                                                                          6
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
”
The best way to
predict your future

               ”
is to create it.
        ― Abraham Lincoln
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
EXECUTIVE SUMMARY
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
EXECUTIVE SUMMARY

Textiles and clothing are a fundamental         This report focuses on the role that
part of everyday life and the fashion           advocacy can play in realising a circular
industry forms an important sector in           fashion economy. In a circular fashion
the global economy. However, the                economy, products and materials flow
current system for producing,                   through a closed loop system by way of
distributing and using clothing cannot          repair and maintenance, sharing and
be sustained. It operates mostly in a           rental, re-use of materials and products,
“linear way”, following the take-make-          collection after use, separation, sorting,
waste model. Large amounts of non-              industrial processing, design and up-
renewable resources are extracted from          cycling, and recycling into fashion
the earth to produce clothes that are           products or into other industries (or
often used for only a short time, after         from other industries). The system only
which they are discarded. The industry          uses safe material inputs, regenerates
as a whole is extremely wasteful and            ecosystems and does not pollute the
polluting. Less than 1 per cent of              environment; processes run on
material used to produce clothing is            renewable resources and energy, and
recycled. In the words of the Ellen             recycled materials streams are clean.
MacArthur Foundation, “on current               Competition from cheap, low-quality
trend, the negative impacts of the              products is eliminated.
fashion industry will be potentially
               1
catastrophic”. In addition to the               To realise a circular fashion economy,
environmental ones, the industry is             there are certain systemic issues that
facing a number of social issues such as        need to be addressed. A trend is needed
poor working conditions, poverty,               to move away from business models
exploitation, abuse and gender                  based on product sales at lowest price
inequality.                                     only to service models based on true
                                                pricing and performance. Furthermore,
The fashion industry therefore needs to         countries need to create and enforce
move away from a ‘linear’ model                 governance and legislation geared
towards a ‘circular’ one. In a ‘circular’ or    towards circular fashion. In other words,
‘flow’ fashion economy, clothes, textiles,      a system which ensures transparency,
and fibres are kept at their highest value      taxes resources, externalities and
during use and re-enter the economy to          energy more heavily and labour less,
avoid becoming waste.                           sets up minimum requirements for
                                                fashion products on the market and
The fashion industry is increasingly            bans those that do not meet them.
committed to a circular model, but is
only at the beginning of a journey to
create a more ethical and sustainable
future for fashion.
                                                                                        9
CIRCULAR FASHION ADVOCACY - ECOPRENEUR.EU
EXECUTIVE SUMMARY

  Governments have driven all major innovations, and only they can change legislation to
  foster change. By combining policies for procurement, economic incentives and
  regulation, governments can tilt the existing linear ’level’ playing field into a circular
  one. But how do we ensure government action?

  Advocacy is key to creating a new system of governance acting as a powerful lever in
  driving change alongside proofs of concepts, pre-competitive collaboration and
  convening, increasing and bundling demand, capacity building, raising worker and
  community voice, and transparency and accountability.

  According to Ecopreneur, a set of policy instruments to accelerate and mainstream a
  circular fashion economy should be based on the following five pillars:

 1       Innovation policies – research programmes with government subsidies, investment
         tax deduction, technological development and innovation, small and medium-sized
         enterprises (SMEs) support, with a focus on textile recycling, preventing
                                                                                            i
         microplastics release, and calculating external impacts and true prices.

 2       Economic incentives – procurement, extended producer responsibility, VAT and a
         tax shift to drive market demand for circular products and services by making make
         them cheaper and “linear” ones more expensive.

 3       Regulation – establishing a common regulatory framework for transparency and
         traceability, circular design and improved end-of-waste status across the EU. This
         regulation should apply to substances of very high concern (SVHC) and textile
         waste, and should be enforced through taxes, bans and fines – for example, with a
         ban on landfilling of textiles. The Sustainable Apparel Coalition’s (SAC) Higg Index
         can play a major role here by measuring material flows and environmental impacts
         of manufacturing systems.

 4       Trade policies – facilitating export of semi-finished products and sorted, reusable
         textile waste to producing countries. Negative social impacts in producing
         countries should be avoided. Waste transport across the globe should be
         minimised.

 5       Voluntary actions – covenants, commitments and standards are encouraged to
         engage stakeholders, with legislation standing by in case of lacking results.

i The true price of a product or service reflects the true cost (environmental and societal) of materials and
production processes.

                                                                                                            10
EXECUTIVE SUMMARY

Ecopreneur proposes that the                 A key message would be to urge the EU
recommendations for advocacy                 to move first to create a circular fashion
messages and actions listed in this          economy because it forms a huge
report are used by the EU and other key      economic opportunity, both for Europe
stakeholders to develop a collaborative      and for producing countries; globally,
strategy and plan up to 2030 that            overall annual benefits are estimated by
supports a circular fashion economy. In      Eurochambres to amount to € 161
addition, philanthropic funders should       billion.7 For the fashion industry to
connect and build the advocacy               realise the economic, social and
capacity of non-profit organisations that    environmental benefits of a circular
support circular economy and a circular      economy, immediate action and long-
fashion sector. This is particularly         term commitment towards advocacy is
important given the strong influence of      needed.
lobbyists advocating for the ‘linear’
status quo.

                                                                                     11
CHAPTER 1
INTRODUCTION
CHAPTER 1

Textiles and clothing are a fundamental                    According to the Ellen MacArthur
part of everyday life and the fashion                      Foundation, approximately 73 per cent
industry forms an important sector in                      of the materials used for clothing are
the global economy. The EUR 1.1 trillion                   sent to landfill or incinerated with less
clothing industry employs more than                        than 1 per cent being recycled to make
                                                                          1
300 million people along the value                         new clothing. The 2017 Pulse of the
       1
chain. At the same time, the fashion                       Fashion Industry report, put together by
industry is problematic. The current                       Global Fashion Agenda and the Boston
system for producing, distributing and                     Consulting Group, estimated that in
using clothing operates mostly in a                        2015, the global textiles and clothing
linear way, following the take-make-                       industry was responsible for the
waste model. Large amounts of non-                         consumption of 79 billion cubic metres
renewable resources are extracted from                     of water, 1.7 billion tons of CO2
                                                                                                     2,3
the earth to produce clothes that are                      emissions and 92 million tons of waste.
often used for only a short time, after                    Should growth continue as expected,
which they are discarded rather than                       total clothing sales would more than
reused or recycled. This is damaging the                   triple in 2050.
environment faster than it can recover.

    Figure 1. World fibre production 1980-2025, showing a huge increase in the use of polyester fibres.
    Source: Tecnon OrbiChem 4

                                                                                                          13
CHAPTER 1

     With the share of plastic-based fibres                Fortunately, measures to foster circular
     projected to remain at 63 per cent, this              fashion not only tackle waste, but also
     would mean a threefold increase of                    offer considerable economic
     microplastics entering the oceans as                  opportunities. The economic advantage
          1
     well. In the words of the Ellen                       in adopting a circular fashion economy
     MacArthur Foundation, “on current                     was recently estimated by
     trend, the negative impacts of the                    Eurochambres at € 161 billion (land use
     fashion industry will be potentially                                           7
                    1                                      externalities excluded). In addition, the
     catastrophic”.
                                                           transformation of the fashion industry’s
                                                           business model from a linear to a
     In addition to the environmental costs,
     there are a number of negative social                 circular system has risen far up on the
                                                                                            8
     issues that proliferate the fashion                   agenda of the fashion industry. To
     industry such as poor working                         support the transition to a circular and
     conditions, poverty, exploitation, abuse              inclusive fashion industry, a holistic
     and gender inequality.                                approach to social, environmental and
                                                           economic policy-making is necessary.
     The fashion industry therefore needs to
     move away from a ‘linear’ model                       This report focuses on the role that
     towards a ‘circular’ one. In a ‘circular’ or          advocacy can play in realising a circular
     ‘flow’ fashion economy,ii clothes,                    fashion economy. The focus is on
     textiles, and fibres are kept at their                apparel, but it has implications for all
     highest value during use and re-enter                 textiles applications. It discusses what a
                                                 5
     the economy to avoid becoming waste.                  circular fashion economy could look
     Measures to tackle fashion waste
                                                           like, what government policies are
     include the development of resource
                                                           needed to realise it and how advocacy
     efficient and durable fabrics and
                                                           can accelerate its development into a
     clothes, leasing and rental services,
     improved infrastructure for the second-               mainstream phenomenon. The report
     hand market or ‘recommerce’, iii,6                    builds on a Circular Fashion Policy Lab
     recycling of textile waste or discarded               organised in May 2018 (see Colophon
     clothing and increased transparency                   and Acknowledgements) and includes
     throughout the value chain.                           input from various experts and
                                                           stakeholders.

ii                                                                               1
    Or a “new textiles economy” as it is called by the Ellen MacArthur Foundation.
iii
    The process of selling previously owned, new or used products.
                                                                                                    14
CHAPTER 1

Some of the measures proposed in this               Reading guide
report, for example increased
transparency and a tax shift from labour   Chapter two analyses the circular
to resource use and pollution, address     fashion system: the structure, the
both the environmental and social          characteristics and the policy regime.
impacts (Chapter 4.1). Ecopreneur is       Chapter three further explores the
carrying out a separate study about the    transition from the linear to a circular
impacts of an EU circular fashion          fashion economy in terms of what needs
economy on producing countries.            to change and how policy can make
However, additional measures to            those changes a reality. Chapter four
address social impacts are outside the     describes the role of advocacy in the
scope of the report and require further    transition to a circular economy.
stakeholder collaboration.                 Chapter five sets out a strategy to drive
                                           policy development, amendment,
This is the first report delivered by      adoption, implementation and effective
Ecopreneur.eu. Ecopreneur has              operation of a circular fashion economy.
welcomed the opportunity provided by       It introduces the most important lobby
C&A Foundation to apply and test our       and advocacy organisations within the
cross-sectoral policy recommendations      EU and explores how together they can
to the fashion industry and hope it will   set the wheels of policy-making into
form the basis for other sectors to        motion. Finally, Chapter six presents a
follow.                                    number of recommendations and a set
                                           of policy instruments to accelerate and
                                           mainstream a circular fashion economy.

                                                                                  15
CHAPTER 2
WHAT COULD A CIRCULAR
              FASHION
  ECONOMY LOOK LIKE?
CHAPTER 2

In a ‘circular’ or ‘flow’ fashion economy,             Figure 2 visually represents many
clothes, textiles and fibres are kept at               important aspects of a circular business
their highest value during use, and re-                ecosystem for textiles, with a focus on
enter the economy to avoid becoming                    material flows.
waste, benefitting business, society and
the environment. 1

  Figure 2: Schematic view of many important aspects of a circular business ecosystem for textiles, with a
                                          9
  focus on material flows. Source: Ethica.

The diagram shows how a circular                       is coloured in green and the flow of non-
fashion industry could function in the                 reusable textiles is coloured in blue. The
future with closed loops besides some                  green flow suggests in total three ways
in- and outflux to and from other                      the user can reuse textiles.
industries. The model is showing us                    It covers:
two flows: the flow of reusable textiles

                                                                                                      17
CHAPTER 2

  Repair and maintenance, using do it        There are large regional differences
  yourself or special repairing services.    in collection rates – in Germany 75
  Re-use as a product, including             per cent of discarded garments are
  second-hand market, sharing and            collected, while in the US and China,
  giving or clothing rental services.        rates are between 10 per cent and 15
  Re-use as material, including                        1
                                             per cent. Many countries,
  handcraft, takeback or collection          particularly in Asia and Africa, have
  after use, recycled textile production
                                             no collection infrastructure at all1
  and design & up-cycling.
                                             with recycle rates as low as one per
The second, blue flow is a sustainable       cent. While in the Netherlands, where
way of recycling non-reusable textiles. It   apparel reuse is relatively well
includes pick up and separation, sorting,    established compared to many other
industrial processing, chemical or           sectors, there are only around 550
mechanical recycling, textile design and     stores for second-hand clothing,
production, and links with other             compared with more than 9,000
                                                              11
industries.                                  regular stores.
                                             Run on renewable energy and use
Figure 2 is not showing everything.          safe, renewable resources. This
Connecting the Ethica model to the EMF       excludes recycling processes using
       1                                     fossil fuels as an energy source. The
report and the vision of Fashion for
      10                                     input of renewable energy, such as
Good, a circular fashion economy
                                             solar and wind allows the fashion
should:
                                             industry to counter the processes of
                                             wear and degradation. Insofar as
  Produce and provide access to an
                                             virgin material input is still needed to
  abundance of high-quality, affordable
                                             supplement recycled input for
  clothing that enhances customer well-
                                             producing synthetic fibres, it should
  being.                                     increasingly come from renewable
  Capture the full value of materials and    resources. This means using
  clothing during and after use. This        renewable feedstock for plastic-
  means using clothing longer and            based fibres and regenerative,
  more often (following the green flow       sustainable agriculture to produce
  in figure 2) and recycling items that      any renewable resources. Plastic
  can no longer be used (following the       microfibres are not released into the
  blue flow). This provides a challenge      environment and ocean. During the
  because only around 25 per cent of         whole producing, utilisation and
  garments globally are collected for        recycling process CO2 emissions are
  reuse or recycling through a variety of    minimised.
  systems.

                                                                                  18
CHAPTER 2

  There is zero landfill and incineration      The legislative system geared
  of fashion products and materials,           towards circular fashion. Circular
  excluding the small fraction that can        fashion provides the best business
  no longer be recycled.                       case. Procurement is circular, both in
  Regenerate ecosystems by net                 public authorities and companies.
  positive impacts, such as producing          Material costs are reduced by using
  clean water from production                  recycled instead of virgin inputs.
  processes and not polluting the              Production using recycled materials
  environment. The economy consists            in producing countries is facilitated
  of an ‘ecology of things’ inspired by        by cross-border take-back systems
  strategies such as ecomimicry.               and free trade of post-consumer
  Be distributive by design, meaning it        waste – provided it is used for
  creates a thriving ecosystem of              recycling.
  enterprises from small to large,             Labour costs are reduced by
  retaining and then circulating enough        decreasing or eliminating income
  of the value created so that                 taxes and prosperity increases.
  businesses and their employees can           Taxes and levies on fashion products
  participate fully in the wider               and materials reflect their ecological
  economy.                                     and social footprint. Minimum
  Reflect the true cost (environmental         requirements eliminate the most
  and societal) of materials and               hazardous substances and worst
  production processes in the price of         performing products from the market
  products.                                    and ensure that recycled materials
  Use a transparent and traceable              streams are clean. Mandatory
  transaction system, committing to full       material passports and intensified,
  and regular public disclosure of all         global market surveillance ensure
  policies, procedures, progress and           transparency throughout the fashion
  real-world impacts on workers,               and textile value chains. Finally, as a
  animals, communities and the                 result, competition from cheap, low-
                 8,13
  environment.                                 quality products is eliminated.
  Be socially fair at a global level. This
  means safe and just working                Importantly, in a circular economy, the
  conditions without exploitation or         use of fashion products is only limited by
  abuse, fair wages, gender equality,        the amount of materials and capital
  and inclusivity.                           available in the economy. This is possible
                                             because the negative impacts of fashion
Ecopreneur adds to this the following        consumption in the form of waste and CO2
characteristics of the legal and socio-      have been designed out of the system.
economic system in a circular fashion        The main question becomes: how can this
economy:                                     circular fashion economy be realised?
                                                                                    19
”
The circular fashion system of the
future needs to be inspired by nature.
Take the example of a blossoming
cherry tree; it may look wasteful at first
view, being covered with an abundance
of flowers in spring. However, the
flowers provide birds and insects with
fruit. The soil, microorganisms and
neighbouring plants benefit when the
tree drops the blossom on the ground.
In the end, nothing is wasted.
                                ”
               ― Enrico Rima, Lebenskleidung
CHAPTER 3
   HOW TO GET THERE:
THE ROLE OF ADVOCACY
CHAPTER 3

In light of the growing issues of climate     Based on their general transition model,
change and ocean plastics and the             DRIFT describes how the fashion
recent interest in the Sustainable            industry can transition to a circular
Development Goals (SDG) we should             economy through the application of six
first ask, can we create a circular fashion   transition pathways of transformative
economy?                                      change through a set of specific
                                              interventions. One of these pathways is
New modelling results by the Stockholm        advocacy, which includes lobbying,
Resilience Centre suggest that creating       campaigning, commissioning and
a circular economy is still possible. Their   publishing research, and other activities
new complex systems dynamic model             intended to influence decision making
“Earth-3” combines the SDGs with              by policy-makers and financial
global planetary boundaries including         institutions. The others are proof of
the climate, biosphere and economy.           concepts, pre-competitive collaboration
The outcome shows that we are not             and convening, increasing and bundling
doing enough and tougher interventions        demand, capacity building, worker and
are needed to tackle increasing               community voice and transparency and
                                                              10
consumption. Rapid, radical                   accountability.
transformations are needed not just for
the fashion industry but our entire           The importance of advocacy as a
economy. 14                                   powerful lever of change is severely
                                              underestimated. This stems from
The good news is that we are not too          several misconceptions. Firstly, the role
late to start the process and the fashion     of governments in realising innovation is
industry is increasingly committed to a       heavily underestimated. Contrary to
more sustainable and ethical future for       popular belief that major innovations
fashion. Also, the current European           can only be realised by business and
Commission (EC) sees the textile sector       industry, they can in fact only be
as a potential priority accelerated           realised by government interventions. In
activities towards circularity and creates    the words of prof. Mariana Mazzucato,
an urgency about planning for the             “In fact, there is not a single key
future.                                       technology behind the iPhone that has
                                                                          15
                                              not been state-funded.” She
This begs the question of how we can          advocates for an “entrepreneurial state”
create a circular fashion economy.            that leads the country towards a shared
Insights to this question have been           common future.
provided by DRIFT (Dutch Research
Institute for Transitions).

                                                                                     22
CHAPTER 3

In the words of Jocelyne Bourgon, a            Moreover, the influence of small NGOs
former public servant that led some of         doing advocacy can be much larger
the most ambitious public sector               than the relative size of their
reforms in Canada, recently declared in        constituency compared to, for example,
a report from Origame that:                    BusinessEurope, provided they gather
“Government needs to go where no one           good intelligence covering a range of
             16                                                     18
else goes.” And in the words of Jason          EU member states.
Kibbey from the Sustainable Apparel
Coalition: “Governments have the               Without advocacy, legislation will not
possibility to become powerful actors in       change. Fortunately, the fashion
the fashion industry; they can ask for a       industry increasingly acknowledges the
different future.” 10                          importance of the government
                                               regulation, amplified by a regulatory
Secondly, governments are often seen           and political focus on the environmental
as weak. Businesses are far more               and social issues present within the
interested in acquiring EU innovation          fashion industry. Examples of this
subsidies than in EU policy-making,            include China’s ban on the import of
even though about 50 per cent of all           plastic waste, as well as single-use
new legislation proposals (including           plastic bans from the EU, New Delhi and
some with far-reaching implications)           Costa Rica, which are already having a
come from Brussels.                            significant effect on European waste
                                               streams. 6
Finally, the power of lobbying is widely
acknowledged. Professional lobbyists           In addition to providing innovation
try to influence legislation, regulation, or   subsidies, such as those described by
other government decisions, actions or         Mazzucato, the government also holds
policies on behalf of a group or               the role of procurer, legislator and
individual who hires them.17 While it has      facilitator of collaboration between
come to be expected that major                 industries and within value chains.
industries, such as tobacco and oil will       Legislation is vital in creating a
lobby to block all legislative change that     methodology for transparency,
impacts their profitability,                   introducing price incentives that will
environmental organisations such as the        influence consumers to buy
European Environmental Bureau (E.E.B.)         circular products and services,
and Friends of the Earth, are powerful         and ensure standardisation and
                                                               16
lobby organisations as well.                   harmonisation of a framework that
                                               enables (eco-)innovation and circular
                                               business models. In addition, market
                                               surveillance is crucial to ensure
                                               compliance.

                                                                                        23
CHAPTER 3

 Circular products/services

                                                                      Linear products/services

   Procurement
Price incentives
     Regulation

                                                                      Linear products/services

Circular products/services

    Figure 3. Schematic view of the linear (top) and circular (bottom) economy as a football field

   Figure three illustrates the possibilities             The desire to create a circular economy
   for governments using policy instruments               (represented by the green arrows) is
   to create a true level playing field. In the           pointing in the opposite direction and
   current linear economy, the system is                  much weaker. As a result of this uphill
   completely geared to optimisation of the               battle, very few companies can
   ‘free’ market. The market forces,                      successfully bring products and services
   customers and companies (represented                   to the market.
   by the orange arrows) are driven in the
   direction of linear products and services.
                                                                                                     24
CHAPTER 3

In contrast to what traditional             Being ‘connected’ can be accelerated by
economists and politicians often state,     advocating governments to facilitate
our current economic system is not a        collaboration between industries and
‘level playing field’. To help drive        within value chains. ‘Internalising’
developments and the transition to a        impacts, costs and benefits is in fact the
                                                                     16
circular economy (bottom), government       core task of advocacy. Finally,
policies for procurement, economic          advocacy campaigns can encourage
incentives and regulation must all point    governments to highlight the ‘value’ of
in the same direction and create a truly    materials and products as valuable
‘level playing field’.                      resources and implement circular public
                                            procurement and waste management in
According to DRIFT, there are four          the transition to a circular system, and
shaping principles for a future in which    to initiate government campaigns
fashion is a force for good. The future     explaining the benefits of going
fashion industry should be; connected,      “circular” in general. The next chapter
accountable, where all negative impacts     will work all of this out further.
are internalised and materials are valued
in a way they can move from one
product cycle to the next. Advocacy has
an important role to play in all four
shaping principles.

                                                                                    25
CHAPTER 4
AN ADVOCACY STRATEGY
          FOR EUROPE
CHAPTER 4

                 4.1 Creating the right policy framework
According to Ecopreneur, an adequate         Through Horizon 2020, the LIFE
set of policy instruments to accelerate      Program (with e.g. ECAP, the European
and mainstream circular fashion should       Clothing Action Plan), the Cohesion
be based on the following five pillars for   Funds and the Executive Agency for
a circular fashion economy:                  Small and Medium-sized Enterprises
                                             (EASME), the EU is already subsidising
1. Innovation policies – programs with       research, technological development
subsidies for research, technological        and innovation, and SME support.
development and innovation, SME              Projects cover topics such as; textile
support and investment tax reductions.       waste, chemical recycling, reducing the
2. Economic incentives – procurement,        environmental impact of clothing across
extended producer responsibility (EPR),      the supply chain, collaboration, as well 21,22
tax shift and VAT.                           as measuring and sharing best practice.
3. Regulation – creating a general           Advocacy is needed to lobby for budget
regulatory framework that creates            for innovation programmes that
harmonised transparency and                  facilitate technological large-scale pre-
traceability and minimum requirements        competitive collaboration and joint
for circular design.                         implementation of common design and
4. Trade policies – adapting the waste       material selection standards, in line with
definition for export to producing           the relevant efforts of the Sustainable
countries.19                                 Apparel Coalition (SAC), Fashion for
5. Voluntary actions – covenants,            Good and Zero Discharge of Hazardous
commitments and standards.                   Chemistry (ZDHC).

These pillars were the outcome of the        The EU subsidy schemes should launch
Circular Fashion Policy Lab organised by     calls for developing a shared
Ecopreneur and the European Circular         technological innovation programme
Economy Stakeholder Platform (ECESP)         with a supply chain perspective that
on 24 May 2018 (see Colophon and             forges partnerships between innovators
Acknowledgements) and are explored in        and frontrunner companies (brands,
more detail in the following pages.          retailers, suppliers, manufacturers),
                                             select key innovations and initiate joint,
  Pillar 1: Innovation policies              large-scale projects in transformative
                                             innovations (e.g. in product traceability,
To a large extent, innovation policies are   recovering fibres, green chemistry
                                                    10
‘business as usual’.                         R&D).

                                                                                     27
CHAPTER 4

Advocacy is vital to increasing the          2. Preventing microplastics release.
budgets for existing European                With plastics forming 63 per cent of the
Commission supported programmes              materials used for apparel, the release
such as:                                     of plastic microfibres from washing
                                             machines into the environment and
1. Textile recycling. The difficulties of    oceans is a growing issue. Only partial
recycling used apparel, preferably           solutions, such as ball filters and laundry
                                                                           23,24,25
without downgrading of the raw               bags, have been identified.
materials, is probably the major hurdle      Microfibre waste pollution has also been
for creating a circular textiles economy.    recognised by five European industry
The current status of recycling within       associations representing the global
the textile industry compares to that of     value chain of garments and their
                                  22
the glass industry 20 years ago.             associated maintenance. They have
Recycling became a success only once         signed a voluntary Cross Industry
purity issues for collected glass were       Agreement (CIA) to collaborate for the
resolved. Problems with textile recycling    prevention of microplastic release into
include the widespread use of                the aquatic environment during the
                                                                             26
biodegradable (natural or man-made)          washing of synthetic textiles. Similarly,
and synthetic fibre (60-70 per cent of all   there is a Microfibre Consortium with
textiles groups) blends. Blends are used     several live research projects (but only a
to achieve optimal end-use properties        limited number of stakeholders behind
                                                 27
but complicate recycling. After              it). An EU funded project should aim
shredding, these blended yarns, fabrics      for real solutions to prevent the
and garments can only be used for            microplastics release from a systems
downcycling as insulating materials or       and life cycle perspective. Research
floor protection for painters. Separating    topics should include; a switch from
natural and synthetic fibres leads mainly    staple to filament yarns (like silk) which
to irreversible damage to the fibres,        have no open ends and are therefore far
rendering them unusable for further          less prone to breaking; the development
textile processing. Furthermore, the         of synthetic fabrics that don’t shed
recycling industry is faced with coated      microfibres; fibres that are biobased,
fabrics, deep colours and finally, the       biodegradable and sustainable at the
recycling costs. Government support for      same time; microfibre filtering methods;
the development and upscaling of new         and methods to clean apparel without
technologies for textile recycling into      water.
quality products is therefore crucial
(also see pillar two).

                                                                                      28
CHAPTER 4

3. Fashion & textile innovations.          Circular design of textiles and
Innovations with the potential to          garments for recycling, durability,
reshape the industry 28,29 such as those   reparability and waste prevention.31
identified by Fashion for Good and         For instance, apparel made from
Ecopreneur member MVO Nederland            either pure synthetic or from pure
(CSR Netherlands).                         natural fibres instead of blends can
                                           be readily recycled into new textiles.
In addition and connected to the
                                           The first steps towards circular
aforementioned, EU and member states
                                           design have already been taken.
government support is needed for:
                                           Recycled bottles are already being
  The development and                      used to produce polyester or
  implementation of new artificial         polyolefins fibres. Dutch company
  intelligence technologies that could     Schijvens is the first company to
  help prevent apparel waste by            produce 100 per cent recycled
  predicting future trends in fashion      corporate clothing made of 50 per
  with forecasting errors reduced by up    cent worn textiles and 50 used
                                                           32
  to 50 per cent.
                   30                      plastic bottles. Circle Economy is
  Enabling the sharing economy,            piloting a Circular Fashion Tool in a
  servitization (the changing face of      consortium with three brand and
  service and manufacturing in             retailer partners.33 Dutch company
  fashion), and proof on concepts of       UPSET is using a new technology
  new, performance-based business          capable of transforming 100 per cent
  models even in the absence of new        cotton waste into 100 per cent
  technologies.                            recycled fibres, without adding
  Overcoming the demand reduction          resource-intensive virgin cotton.34,35
  challenge. With waste prevention and     UPSET is a partner of the consortium
  recycling still in development, some     Clothes the Circle, which also
  form of ‘slow fashion’ is needed to      includes MVO Nederland, and is
  reduce the negative impacts of a         developing several circular textiles
  growing population. But, how can         value chains as part of a cooperation
  brands become sustainable without        with India and Sri Lanka.36 The
  compromising their bottom line? Are      Austrian company Lenzing has
  there other models that de-link          developed a technology which
  revenue from mass consumption            involves upcycling a substantial
  besides servitisation? How will          proportion of cotton scraps to
  apparel remain accessible to low-        produce new Lyocell fibres to make
                                                                   31,37
  income segments?                         fabrics and garments.

                                                                                29
CHAPTER 4

Finally, trials at Chemnitz University     The system uses chemical and heat
show that socks made from natural          recovery for the production of
fibres have a higher abrasion              viscose and Lyocell fibres.38 To make
resistance than conventional socks         sure the circular economy objective
using nylon instead. All of these new      of recycling is in line with climate
technologies are in urgent need of         objectives, the use of EU subsidies
further development, implementation        should be restricted to processes
and upscaling.                             with net positive CO2 emissions and
Calculating the external impacts           be accompanied by research on
along multiple lifecycles for all          recycling using renewable energy. In
fashion products and developing a          the long term, subsidies for recycling
user-friendly tool to do this as part of   processes based on fossil fuel energy
the design process, ideally using the      should be phased out.
Sustainable Apparel Coalition’s Higg       Facilitating the replacement of
Index (see pillar two).                    hazardous chemicals by safer
Calculating financial incentives based     alternatives.
on external impacts, i.e. create           Communicating the safety and risks
standard calculation schemes for           of chemicals in textiles and fashion
levies, fees, taxes or premiums for a      and debunking any existing myths.
specific product or service based on       Circular fashion policy research,
its external impact (needed for pillar     including planetary boundaries and
two). For impacts that cannot be           science-based targets, which is often
quantified by a life cycle assessment      a forgotten topic that is needed to
or similar method, such as                 provide insight into the economic and
microplastics release, levies triggered    social aspects and consequences of
by political action should accelerate      the transition to a circular textiles and
change, such as the €0.15 plastic          fashion industry between now and
bag levy.                                  2050. For example, the effect of
Developing chemical recycling on           clothing production from secondary
renewable energy. Chemical                 materials close to end customers or
recycling has the attractive potential     replacing cotton by a new type of
to transform old clothes into              environmentally-friendly fibre may
secondary raw materials, but the           result in job losses for economies
processes used are generally energy        reliant on manufacturing, like
intensive. Practical examples to           Bangladesh.
reduce energy use in textile
production include the closed-loop
production system used by Lenzing.

                                                                                  30
CHAPTER 4

The revolutionary transition to a            Finally, the support should extend to
circular fashion economy requires            EU-wide knowledge-building by
accompanying measures to avoid               connecting existing networks such as
social conflicts, poverty and civil unrest   Cradle-to-Cradle and the Dutch
in producing countries. 31                   Circular Textile Valley and facilitating
Extending existing support (e.g. by          collaboration between industries and
                                 39
the Europe Enterprise Network and            within value chains (see Chapter
building on the European Resource            three).
                                             Investment tax reductions for sorting,
Efficiency Knowledge Centre - EREK)
                                             purifying and recycling installations, a
for SMEs in the textiles and fashion
                                             common aspect of existing
industry (including small brands,
                                             innovation policies, but then geared
design schools and retailers) with
                                             to circular change.
national and regional support in the
                                             Training programmes for those
form of awareness campaigns,
                                             providing finance for the fashion
communicating best practices and
                                             industry, giving them the necessary
successful new business models,
                                             background and means to evaluate
harmonised circular design training,
                                             the risk and opportunities of circular
tools and communities of practice.
                                             business models. This should enable
Circular fashion hubs with regional
                                             the finance sector to use natural
networks, knowledge, capacities and
                                             capital approaches, shift financial
learning processes focusing on
                                             incentives and support the
circularity and innovation should be
                                             institutionalisation of valuing natural
set up in each EU member state. The
                                             capital. Similarly to how (part of) the
Circularity Check launched by
                                             finance sector is currently
Ecopreneur, MVO Nederland and
                                             accelerating the energy transition by
WeSustain can be used by companies
                                             taking the CO2 footprint of
for self-assessment, as input for                                        10
                                             investments into account.
internal discussions about their
                                             The acceleration of social enterprises,
circularity strategy and to measure
                                             for instance those that are active in
the completeness of their circular
          40                                 the reuse and remanufacturing
strategy. The circular fashion hubs
                                             industry.
should also facilitate access to
                                             National programmes for circular
various sorts of funding for SMEs,
                                             fashion and textiles separate to the
including start-ups, with schemes
                                             EU. As it stands, EU Programmes only
that are funded or backed up by EU
                                             receive funding 14 per cent of the
financial programmes, venture capital
                                             time due to poor proposal selection,
and loans.

                                                                                   31
CHAPTER 4

   long lead times and bureaucratic red    There may be some opposition to
   tape. National schemes can alleviate    subsidies from a limited number of
   some of these shortcomings              sustainable companies claiming they
   through SME vouchers with simple        distract from other more important
   access: fast, low threshold, clear      market-driven activities. Also, the
   criteria, a guaranteed voucher if       history of subsidies has in many cases
   these criteria are met, minimum red     been perverse, resulting in a negative
                                                                                  16
   tape and immediate closure of the       effect or perpetuating the status quo.
   online application form if the budget   Ecopreneur however supports the
   is exhausted.                           importance of well- targeted subsidies
                                           supporting innovation.

Circular textiles and fashion innovation
                                            Pillar 2: Economic incentives
policies are needed for two reasons: to    Far more important than lobbying for
accelerate the new regime and to           subsidies, is lobbying for the
destabilise the old one. Lack of access    implementation of economic incentives.
to funding is a major bottleneck for       Without these incentives to create a
innovation and growth for many SMEs,       strong demand for circular business
including start-ups and sustainable        models, technologies will not be
companies. Government subsidies are        implemented (despite the subsidies). To
also needed to engage the potential        attract consumers, circular fashion
‘losers’ of a circular economy. ‘Losers’   products must have the same properties
in this case could refer to traditional    and care conditions as their linear
companies with a strong dependence         counterparts and ideally (but not
on linear business models and low          necessarily) be available at a lower price.
innovation potential, lagging behind       If these targets are achieved, no
                                           campaigning for new products is
on resource efficiency. Industrial
                                           necessary. However, without a driving
associations and confederations are
                                           force for this development, this process
lobbying for subsidies because the
                                           will take decades - or may never
majority of companies they represent,
                                           happen. In the absence of market
whether profit-driven multinationals or    demand and a clear business case,
conservative SMEs, need years to           company boards will continue to favour
innovate. And yet, if the markets were     linear business models despite their
demanding circular products and            circular ambitions.
services, no subsidies would be
needed at all.

                                                                                    32
CHAPTER 4

Therefore, industry incentives to             This will stimulate job creation and
develop and implement circular                incentivise the industry to value
business models are necessary to drive        materials and create clean, circular
                                                     10
the transition, similar to how the price      cycles. In concrete terms, we are
on CO2 emissions is driving the               talking about new measures to boost
transition to cleaner energy sources.         the demand for circular products and
Economists hail CO2 pricing as the most       services through procurement,
effective, efficient and honest way to        extended producer responsibility (EPR),
motivate industry to move ahead with          VAT and a long-term tax shift from
                                 41
the switch to renewable energy.               labour to resources. Like innovation
Ecopreneur member MVO Nederland,              policies, economic incentives are
representing over 2000 sustainable            needed for two reasons: to accelerate
companies, stresses the need for carbon       the new regime and to destabilise the
                                 42
pricing and true pricing as well. By          old one. From the perspective of
setting a clear long-term framework, the      sustainable companies, such as those in
government creates the conditions in          the membership of Ecopreneur, the lack
which companies can plan a long-term          of demand for circular products and
investment strategy. The same should          services at current prices is the number
be done for pricing resource-                 one hurdle for implementing circular
inefficiency. To the fashion industry’s       business models. While some circular
advantage, objects and materials can be       products and services can already
traced where carbon cannot. On the            compete on price, incentives are needed
other hand, the impacts of waste on the       to remove this fundamental barrier by
environment are much more diverse and         making circular products and services
far harder to measure than CO2                cheaper than their linear counterparts.
emissions. For the rest, both policies are    In addition, these incentives are needed
a classic example of ‘mechanism design’       to destabilise the old regime by making
to motivate specific behaviour by             linear products and services more
setting the framework conditions              expensive than circular ones through
                                         43
without specifying how to meet them.          the inclusion of their externalities.

Brands, retailers, suppliers and              In the following section we further
manufacturers should seek to influence        explore the four types of economic
governments in buying and sourcing            incentives.
countries by advocating for tax shifts
from labour to capital, natural resource
use and the production of externalities.

                                                                                    33
CHAPTER 4

 Pillar 2.1: Circular Procurement           This not only prevents the annual
                                            incineration of old uniforms, but also
Circular procurement can accelerate the     save tens of millions of euros; the
                                                                            45,46
transition by creating demand for           business case is already there.
circular products and services, thereby
helping to create economies of scale.       A continued absence of commitment,
Making green public procurement (GPP)       visible from a lack of GPP by the
– a tool that favours products, services    European Commission, Parliament and
and works that respect the environment      member states, is a risk to a circular
– mandatory is not enough. Circular         fashion future. It becomes clear that in
procurement sets out an approach to         order to overcome the complex
GPP which pays special attention to         challenges associated with generating
what the European Commission states         revenues, a basic level of political
as, "the purchase of works, goods or        commitment is needed. Finally, GPP and
services that seek to contribute to the     circular procurement would be greatly
closed energy and material loops within     facilitated by a reform and simplification
supply chains, whilst minimising, and in    of the EU procurement rules.
the best case avoiding, negative
environmental impacts and waste               Pillar 2.2: Extended Producer
                                       44
creation across the whole life-cycle".              Responsibility (EPR)
Supply chains for the fashion industry
should also be simplified. The Green        Extended Producer Responsibility (EPR)
Deal Circular Procurement, a deal led by    is a strategy to add all of the
Ecopreneur member MVO Nederland             environmental costs associated with a
and several other public and private        particular product’s life cycle to the
                                                                            47
organisations from the Netherlands,         market price of that product. These
involves a € 100 million commitment of      costs will have to be paid by the
circular investments from companies,        producer of the end product, typically
municipalities and the government to        the brand owner or the company that
pilot circular procurement, facilitating    determines the specifications of the
implementation and the removal of           garment or footwear, either by
obstacles in regulation. Flanders, Paris    producing it themselves or by
and other regions are already following     procurement on price and
this example. This example highlights       specifications. While in need of further
how circular procurement can boost the      improvements, EPR is a proven policy in
demand for circular products and            sectors such as packaging, electronics,
services. The Netherlands Ministry of       tyres, cars and batteries.48,49
Defence and police force have switched
to circular procurement of uniforms.

                                                                                     34
CHAPTER 4

Existing EPR schemes work because            This ‘bonus’ for companies working on
from all partners in the value cycle, the    increasing sustainability throughout the
producer has a key position to change        product life cycle is important for the
the product design to minimise waste.        transition to a circular fashion system.
For the fashion industry, high EPR fees      Companies can provide their own
on garments lacking circular design and      takeback system or contribute to
with high costs for waste management         collective recycling, thus ensuring that
will reflect their true price and increase   pioneering initiatives are not stifled by
the demand for circular alternatives. An     mandatory participation in a collective
important aspect of EPR schemes is           scheme. In addition, EPR also has the
that they are private schemes backed by      potential to generate private funding for
the government, in contrast to taxation,     activities supporting the transition, such
which is a government scheme.                as research or circular textile covenants.
Provided good governance, this               For ECO-TLC 70 per cent of the budget
element of self-control allows industry      goes to sorting, 20 per cent to
to design tailor-made schemes fostering      communication, and 10 per cent to
                                                                        51
innovation.                                  research and innovation. For these
                                             reasons, EU recyclers’ and waste
France is the only country in the world      management federations are strongly
implementing an extended producer            advocating to step up the EU EPR
responsibility (EPR) policy for end-of-      policies, even if some individual SME
use clothing, linen and shoes.57 The         recycling companies oppose it. In
French EPR organisation ECO-TLC has          addition, by 2025 all EU member states
contributed to a threefold increase in       are required to have separate collection
the collection and recycling rates of        for textiles, providing a secure input
post-consumer textiles (clothes, linens      stream. 52
and footwear) since 2006. In addition,
the material recovery rate of post-          Despite these achievements and
consumer textiles can reach 90 per           opportunities, there are several issues
cent, of which 50 per cent can be            connected to EPR for the fashion and
directly reused. ECO-TLC has created         textiles industry:
financial incentives for ecodesign
                                               Sorting and recycling of textiles
specifically on using recycled content,
including a 50 per cent discount for any       suffer from system cost and
product containing a minimum of 15             inefficiency. For instance, a technical
per cent recycled fibres sourced from          solution is needed for cotton-
                         50                                     51
post-consumer textiles.                        polyester mixes. The current market
                                               for recyclable textiles and clothing
                                               are limited.

                                                                                       35
CHAPTER 4

Advanced recycling technology is           Public communication needs to be
required to replace or complement          improved. Alternative schemes in
                                    57
inefficient mechanical recycling.          other countries have produced
Without this, increasing collection will   better results. Recommendations to
lead to bankruptcy of the EPR              the French government to address
organisation. The waste will be            these challenges include an option to
eliminated because it accumulates          either preserve the current structure
                           51
and cannot be recycled. In addition,       of the EPR sector or to totally
                                                                      54
ensuring clean secondary raw               redesign its governance.
materials is important for the industry    WRAP concludes that the fee income
to make the switch to the sourcing of      collected as part of an EPR scheme
recycled materials (as described in        such as ECO-TLC could be used in a
pillar one). Until solutions for textile   range of ways to help the UK secure
sorting and recycling are found, EPR       and develop textile waste prevention
fees to stimulate recycling would          and landfill diversion. However, the
have an adverse effect and only lead       fees might look quite different in the
to the piling up of textile waste. For
                                           UK due to political priorities and a
this reason, Euratex, the European
                                           different starting position, with
Apparel and Textile Confederation
                                           considerable collection achieved
representing a large fraction of                         55
European textile producers, is critical    without EPR.
         53
of EPR. The R&D investments                The market for ‘reuse’, the most
needed to improve recycling (in            preferred option for textiles recovery,
France) are estimated at € 20 million      has been shrinking in the last few
                               54
over a period of three years.              years. Its main market is in Africa,
An evaluation of the ECO-TLC system        and a growing number of African
by the French General Council of the       countries are banning the import of
Environment and Sustainable                used textiles to encourage a
Development (CGEDD) concludes              competitive textiles industry locally
                                                                56
collection rates are growing steadily      and internationally. And in France
but below the targets set. Sorting         there has been an increase in
                                                                                51
outlets respect the order of priority of   recycling at the expense of reuse.
the treatment methods but largely          The quality of new clothing is
depend on the acceptance of the            becoming lower and the export of
                                                                                   57
countries receiving the waste to be        clothing is becoming more difficult.
reused, and even though the costs          Discovering new markets for ‘reuse’
remain moderate, the cost                  and increasing second- hand clothing
components remain unclear.                 demand in Europe are challenging
                                           but critical.

                                                                                   36
CHAPTER 4

  Companies investing in the circular        On the other hand, the only existing
  economy are under the impression           EPR example for the fashion industry,
  that they pay several times for            the French ECO-TLC, struggles with
  everything. Cost calculation schemes       fundamental issues which need to be
  are unclear, and they would like           solved before a roll-out in other
  positive incentives rewarding their        member states becomes an option. The
  efforts and achievements.                  French governance of textile waste may
  Verification poses operational issues      be totally redesigned. Ecopreneur,
  as well and raises the questions of        therefore, recommends the fashion
  how the system verifies recycled           industry works towards realising a
  content or ecodesign. It may be            strong EPR system for textiles by 2030
  necessary to audit a company after it      by building on all available lessons and
  files for a 50 per cent discount on the    recommendations from other sectors
  fee, which raises further questions        and from France (see also Chapter 4.2).
  (amplified by e- commerce) as to how
  to trace and enforce these national         Pillar 2.3: Tax shift from labour
  EPR schemes on the international
  market.                                            to resource use and
                                                    environmental impact
EPR offers large opportunities for textile
waste reduction by focusing on the most      The third major economic incentive to
promising streams and on good                mainstream circular fashion is a tax shift
practices in other sectors. This presents    from labour to resource use and
great potential to identify new markets      environmental impact, as taxes
for ‘reuse’ and to improve the textiles      influence purchase and investment
waste sector. Such an EPR policy also        decisions by consumers and businesses.
could drive societies to financially         Currently, tax revenue is raised largely
support innovation and research to           on employment. In OECD countries,
provide feasible solutions for fashion       labour taxes account for 52.1 per cent
                                             of total public revenue raised, while
producers to adopt ecodesign and
                                 57          green taxes account for only 5.3 per
design for recycling practices.
                                             cent. There is some variation across
Moreover, where ecodesign regulation
                                             continents; African, Asian, Latin
can effectively raise the bar in low-
                                             American and Caribbean countries may
performing parts of the market (see          rely more on taxes on goods and
below under pillar three), EPR has the       services. Nevertheless, labour taxes
unique potential to foster innovation in     provide a significant share of revenues
circular design for all companies by         in all regions and substantially more
applying eco-modulation of fees to give      than green taxes. 58
a positive economic incentive.

                                                                                     37
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