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From May 12 – August 4, 2021 the EU is seeking feedback from businesses that trade in Europe on the EU strategy for sustainable textiles. This strategy is designed to help the EU shift to a climate-neutral, circular economy where products are designed to be more durable, reusable, repairable, recyclable and energy-efficient. It aims to ensure that the textile industry recovers from the COVID-19 crisis in a sustainable way by making it more competitive, applying circular economy principles to production, products, consumption, waste management and secondary raw materials, and directing investment, research and innovation towards sustainability.

Following our recent article exploring the EU Sustainable Products Initiative, Positive Luxury has collected all the important information below and encourages luxury businesses that trade in Europe to prepare for this legislative change – and take advantage of this opportunity to co-create ambitious climate solutions with legislators.

You can contribute to the consultation by responding here


The European Green Deal, the Circular Economy Action Plan (CEAP) and the Industrial Strategy identified textiles as a priority sector in which the EU can pave the way towards a carbon neutral, circular economy, and announced an EU Strategy on textiles.

In the Commission Staff Working Document ‘Identifying Europe’s recovery needs’, which accompanied the communication ‘Europe’s moment: Repair and Prepare for the Next Generation’, the Commission outlined the impact of the COVID-19 pandemic on the industrial ecosystem for textiles in the EU, identifying its recovery needs in the light of current and expected weaknesses on both the demand and supply sides.

The problem the initiative tries to solve

Textiles and clothing make up a diverse industrial ecosystem covering different value chains and types of products. The industry employs 1.5 million people, spread across more than 160,000 companies in the EU, most of which are SMEs, with an EU annual turnover of EUR 162 billion in 2019.

Despite a growing social trend for sustainability in the EU textile and fashion industry, Europeans consume on average 26kg of textiles per person per year with a significant share of these coming from third world countries. Each item is used for a shorter period, resulting in 11 kg of textiles discarded per person per year – this is the true cost of the popularity of fast fashion across the continent.

Whereas the EU textile industry is globally competitive, especially in the areas of technical textiles and luxury fashion, the ecosystem is suffering significantly as a result of the COVID-19 crisis, both in terms of disrupted supply and a drop in consumer demand. The crisis has also affected international trade in secondhand textile products and disrupted waste streams.

The textile sector is a resource-intensive sector with important climate and environmental impacts. Textile consumption is the fourth highest pressure category in the EU in terms of use of primary raw materials and water (after food, housing and transport), and fifth for GHG emissions (EEA). Most of the pressure and impact linked to clothing, footwear and household textiles in Europe occur in other regions of the world, where the majority of production takes place.

Moreover, it is estimated that less than 1% of all textiles worldwide are recycled into new textiles. The presence of substances of concern hampers future high-quality recycling and pollutes water and soil, whilst textile waste collection rates and recycling capacities are low to medium in the EU. Besides their impact on the environment, textile value chains are recognised as being long, globalised and diverse. As a result, the European textile and clothing industry faces an uneven playing field due to the often lower production costs and environmental and social standards in place in third countries. They find it challenging to prove that their products are produced under acceptable environmental and working conditions. The textile sector also suffers from skill gaps, shortages and mismatches due to the rapid technological changes taking place that require international workforces to continuously re-adapt.

Basis for EU legislation

Boosting the sustainability of the sector and addressing the challenges brought about by the COVID-19 crisis are EU-wide concerns, in which the stakes in terms of cross-border pollution effects and impact on the internal market are high. In order to address this, a coordinated and harmonised response at EU level will be needed to address structural weaknesses regarding textile waste collection, sorting and recycling in the Member States, and to strengthen capacity both of the industry and public authorities.

Since the textile sector is highly globalised, fragmented action at national and local level will be insufficient to drive change. A lack of EU action would undermine effective environmental protection across the EU, as well as the possibility of creating a level playing field for textile businesses in and outside the EU. The proper functioning of the internal market would also be at risk. Finally, failure to act would run counter to the strong demand from stakeholders in recent years to develop a sustainable textiles approach at EU rather than at national level. Subsidiarity will be duly considered for any legislative action that derives from this strategy, in accordance with the Better Regulation Guidelines.

What does the initiative aim to achieve and how

The aim of the initiative is to set in place a comprehensive framework to create conditions and incentives to boost the competitiveness, sustainability and resilience of the EU textile sector, taking into account its strengths and vulnerabilities, after a long period of restructuring and delocalisation, and addressing its environmental and social impacts.

It will ensure coherence and complementarity with initiatives under the European Green Deal, the Circular Economy Action Plan, the Industrial Strategy and the Chemicals Strategy for Sustainability. The initiative will facilitate and encourage optimal use of the recovery plan and sustainable investments, in particular in production processes, design, new materials, new business models, infrastructure and capacity. Support to technologies, including through digitalisation, related to innovative textiles, tackling the release of microplastics, manufacturing and recycling processes will contribute to the digital and green transition.

To boost the EU market for sustainable and circular textiles, the initiative might consider setting targets to significantly step up reuse and recycling efforts as well as green public procurement in the EU. These objectives will be considered through a structured engagement with the industrial ecosystem and other stakeholders (i.e. research and innovation, consumer associations, investment companies, Member States, civil society), to allow for their swifter achievement, and to contribute to monitoring subsequent implementation of the initiative.

The initiative will propose actions to make the textile ecosystem fit for the circular economy, addressing weaknesses regarding sustainable production, sustainable lifestyles, presence of substances of concern, improving textile waste collection and recycling in the Member States as well as capacity building (including for skills).

The initiative will do so by identifying textile-specific and horizontal actions along the whole value chain. Taking into account the preparation of the Sustainable Products Initiative, the initiative will underline possible approaches for improving design for sustainability (ensuring the uptake of secondary raw materials and tackling the presence of hazardous chemicals, among others), facilitating its future implementation. The initiative will also propose actions to promote more sustainable production processes.

In addition, the initiatives will look into supporting more sustainable lifestyles, for instance by incentivising ‘product as a service’ and other sustainable business models. The initiative will promote voluntary approaches such as the EU Ecolabel and look into maximising the synergies within the New Consumer Agenda and the Bauhaus initiative.

The role of extended producer responsibility in promoting sustainable textiles and treatment of textile waste in accordance with the waste hierarchy will also be considered, and the implementation of the legal obligation to introduce separate collection of waste textiles by 2025 will be supported. Finally, the initiative will explore how to reinforce the protection of human rights, environmental duty of care and due diligence across value chains, including improving traceability and transparency. It will steer international cooperation and partnerships, including aid for trade, towards more sustainable consumption and production patterns, including in terms of land and water use and the use of chemicals

Better regulation: Consultation of citizens and stakeholders

Stakeholders in the textile ecosystem have been very active in recent years and have shown keen interest and commitment to making the industry more sustainable. Their willingness to developing new business, behavior and consumption models are therefore of particular importance and value.

Stakeholders to be consulted will include all industry players including: fibre, yarn, fabric or clothing manufacturers, SMEs and global companies, suppliers, retailers, service providers, collectors, sorters, recyclers, research and innovation centres and other stakeholders such as public authorities, consumers and consumer associations or civil society. Consultation activities will reach out to and engage with industry and other stakeholders, including by organising workshops, (tele)conferences, and holding a 12-week public consultation which will be published on ‘Have Your Say’.

Recommended actions for luxury business operating in the EU

  • As this legislation is only in the Feedback Period, we do not know the exact shape it will eventually take. However, the focus on sustainable and circular textiles, the promotion of more sustainable production processes, and a changing attitude towards waste textiles clearly implies sweeping changes in the pipeline
  • We recommend that businesses contact the commission before the feedback period closes on August 4, 2021 (midnight Brussels time) to ensure that this legislation is as bold and progressive as possible.

You can contribute to the consultation by responding here

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