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Are synthetics receiving an easy ride at the expense of natural fibres in the European Union’s proposed Green Claims Directive? Last week, the European Council confirmed its support for the new legislation, which is intended to prevent companies from misleading consumers with false environmental claims — in short, to stop greenwashing.
That synthetic fibres are being favoured is certainly the take of a global collective of farmers and supporters, which has published an open letter warning that a methodology that could be used to substantiate claims is flawed. More than 900 signatories representing over 500,000 farmers across countries, including Mongolia, India and the US, claim that the methodology unfairly favours synthetics and “misrepresents natural fibres as harmful to the environment”.
If the directive is implemented in its current form (the European Council will next negotiate with the European Parliament to finalise the process), it would, the letter states, pose “a significant risk of injustice to farmers whose lives depend on the production of these natural fibres”.
Breaking down PEF and PEFCRs
The methodology that is upsetting farmers is the Product Environmental Footprint (PEF), first introduced in 2013 as part of the European Commission’s Building the Single Market for Green Products Initiative — intended to create a standardised framework for calculating and communicating the environmental impacts of products.
The PEF method outlines category rules (referred to as PEFCRs), developed to focus on the most relevant environmental impacts, processes and life cycle stages in a given product category. In apparel and footwear, which covers 13 subcategories from T-shirts to swimwear, factors considered include circularity and durability, while those not currently considered include microplastics, biodiversity and volume.
Though not yet rolled into policy on a wide scale, the general approach document from the Green Claims Directive vote by the European Council appears broadly supportive of the use of the PEF method to substantiate environmental claims.
A central argument against the core methodology is that calculations for natural fibres start at field level, while for synthetics, they start at the barrel of oil, skipping the impact of processes such as fracking and habitat destruction. “For synthetic fibres… extracting this raw material consumes many natural resources and often endangers the biodiversity of the extraction areas,” says signatory Francesco Vantin, a farmer and co-founder of hemp-fibre denim brand Gimmi Jeans. He also lists microplastics and poor recyclability and biodegradability among the other impacts that have gone overlooked.
“If the PEF is not completed with the points discussed… the risk is giving the textile sector an excuse to consider synthetic fibres more sustainable than natural ones, discouraging and demotivating people like me who create value through their cultivation,” Vantin says.
Beyond natural versus synthetic
The letter is the latest in a string of clashes between advocates for natural and synthetic fibres. Its contents closely echo criticisms of the Sustainable Apparel Coalition’s (now renamed Cascale) Higg Index, which was similarly accused of favouring synthetics through the use of flawed and even biased data. The International Wool Textile Organisation (a former voting member in the development of PEFCRs) is among bodies to have publicly called the PEF methodology into question over recent years. It backed a report published by the Make the Label Count campaign, claiming that multiple negative impacts of synthetics (microplastic pollution, environmental impact of fossil fuels, etc) and positive impacts of natural fibres (renewability, biodegradability, financial opportunity for rural communities, etc) are being overlooked.
The EU is not unaware of the controversy. A 2023 Green Claims Directive proposal document by the European Commission stated that prescribing a single methodology like the PEF would not be appropriate as it gives an “incomplete picture of the environmental credentials of a product in the green claims context”.
On 6 June, the European Environmental Bureau (EEB), one of the observers of the development of PEFCRs, called upon the Environmental Council to avoid recommending the use of PEFCRs to substantiate green claims until known shortcomings are overcome. Back in 2022, it laid out those shortcomings in a letter that cited concerns including poor data quality, the exclusion of social impacts and the fact that the full product lifecycle is not covered. “EU laws should not allow the fashion industry to use a method that fails to fully account for the environmental impact of synthetic fibres,” says Emily Macintosh, senior policy officer for textiles at the EEB. “An EU law to address unsubstantiated claims is essential, but for calculations to be meaningful, they must be based on sound data.”
The right data is essential
The EEB argues that PEF is too reliant on the use of global average secondary data which, it says, “fails to capture local variations in environmental impacts”.
However, this problem is not specific to PEF, says Jeremy Lardeau, SVP of the Higg Index at Cascale, which is tasked with coordinating the Technical Secretariat (guiding body) behind the development of PEFCRs. “The issues identified with the PEF methodology are common to any Life Cycle Assessment (LCA) developed on similar principles. The challenge is that natural fibre proponents often reject the conclusions of LCAs as conducted today. Their quarrel is more with the principles of LCA methodology rather than with the PEF specifically,” he says, adding that the data used is managed by the EU Commission.
Yet some believe the central EU database is not expansive enough, and that both the industry and the EU need to invest accordingly. “We’ve got to invest, as natural fibre [producers], in a massive way to create data quality that is actually good,” says Crispin Argento, global managing director of cotton transparency startup Sourcery. With more accurate, localised data, Argento believes a new standard could be set.
Fellow signatory and founder of the Sustainable Fibre Alliance Una Jones agrees. “These kinds of policies can have a hugely colonising effect on how products and information shift across the globe. We need to make sure that the European Union is investing in suitable monitoring, evaluation and learning systems that don’t just support the EU’s decision-making but also support herders in making responsible decisions on the ground,” she says. Jones was born in Mongolia and acts as a representative and advocate for cashmere herders from her homeland.
No room at the table
“The voices of herders are never really considered in this dialogue,” says Jones. “There needs to be a more considered approach to involving wider Indigenous heritage and community voices.”
Argento believes farmers are hidden “behind the commodity trade system that is built on their obscurity”. Certainly, mapping fibre producers externally isn’t a quick or easy task, but there are two key elements restricting them from self-initiating engagement. First up, the EEB says, is the complex nature of the EU Commission’s platforms, which make it difficult to access the relevant documents to review or respond to.
A second issue is the governance structure of the development of PEFCRs. The Technical Secretariat consists of 26 members, of which 14 have voting rights. And of these 14 — which includes a mix of brands, retail groups, material companies and industry groups — the farmers’ letter alleges that eight have a synthetic business model to protect. “All organisations that wanted to join the Technical Secretariat were accepted during the open application period, which lasted for over a year,” counters Cascale’s Lardeau. “There was no selective process for membership, ensuring a broad and inclusive representation.”
However, the signatories argue that the high cost of becoming a voting member means only larger brands with ample funding can afford to participate in the democratic process. According to Lardeau, the fee is €200,000 for the duration of the five-year project. The initial figure was €150,000, but when the project was extended from two to five years, an additional fee of €50,000 was levied per member.
While Lardeau says this is competitive in comparison to the costs of other sector PEFCRs, the pay-to-play nature of obtaining voting rights means the average cotton farmer in India or herder in Mongolia is immediately excluded on a financial basis. Discussions between members are highly technical, a source close to the subject says, and not every member of civil society has the know-how to steer the minutiae of the broader methodology. However, expertise is relative, and currently, farmers feel as though theirs is being excluded.
There is a consensus that a system supporting accurate sustainability claims is essential. Even among critics, it is broadly agreed that PEF is the best methodology that currently exists — but there is very considerable room for improvement.
Neither PEF nor PEFCRs are set in stone, with both undergoing pilots and the apparel and footwear PEFCRs not subject to adoption by the EU Commission until 2025. So there is still time for the concerns of farmers and other civil society actors to be heard.
The rigidity of EU structures means it is unlikely for fibre producers to have a meaningful seat at the table, although the push to expand the parameters of the impacts continues. “It’s not about taking down the PEF,” says Argento. “It’s actually about taking ownership of reporting.”
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