Citizen Fashion Policy Workshop.
The Interdisciplinary Textiles Circularity Centre at Royal College of Art hosted a number of research workshops as part of the Regenerative Fashion Hub at Rich Mix London in March 2024.
I participated in the Citizen Policy Workshop, a session aimed at understanding what the policy requirements of sustainable fashion are from the point of view of citizens. Working with not-for-profit think tank Policy Connect, the insights from all of the facilitations were to be gathered and disseminated into a report that would be presented at a parliamentary roundtable later in 2024. In partnership were also the universities of Cranfield, Cambridge, Leeds, Manchester, York and UCL.
This post further informs as much about the workshop as I’m allowed to say (being that it’s an in-progress study), and gives some takeaways for further reflection on policy needs and advocacy in textiles and fashion.
Regenerative Fashion Hub at Rich Mix, London.
The Regenerative Fashion Hub is the on-the-high-street exhibition of research conducted by the Textiles Circularity Centre on sustainable apparel-textiles.
Introduction + participants.
The 1.5 hour session featured a short tour of the exhibit, along with a discussion on what us participants thought the policy landscape for fashion looked like currently, and what we thought the priorities should be. We were also presented with an overview of what the actual policy landscape currently is, and why there’s even a focus here. It was to be focused on the UK, though other examples were mentioned — partly showing up the UK’s lack, but also to highlight what could be possible.
It turned out that most of us participants, I think, based on the answers and discussion points, were in some way embedded in the textile and fashion sectors, rather than simply being ‘citizens’ so it was perhaps a biased session. I initially was going to join the afternoon session that was focused on stakeholders such as brands, but decided I wanted more of the citizen insight, being that I’m looking to communicate with everyday folk rather than the industry bubble.
Images: 1. Exhibit introduction board highlighting the reasons behind the Regenerative Fashion Hub, and diagram of the ‘Social Production Network’, a network of actors that work together to promote and engender circular principles in the local economy; 2. Information board highlighting the ‘participation’ element of the Social Production Network where democratic decision-making engages local communities in encouraging circular strategies.
Current policies.
My view was that I didn’t think there really were any set in place. There was discussion on lots of initiatives that either existed in the EU alone, were supposed to be implemented by the UK but dropped, or were only being talked about as a possibility.
These are some of the examples mentioned:
Extended Producer Responsibility (EPR).
Tax on second-hand [for retailers of the goods, rather than imports/exports].
RFID tracking + product labelling [digital product passports].
Ban on the destruction of unsold goods.
Greenwashing monitoring.
Carbon reporting.
Environmental Product Declaration.
Durability standards.
Safety regulations.
Hazardous chemicals e.g. ZDHC — not mentioned, I noted down.
Current policy landscape.
Effectively, there isn’t much going on for the UK, hence the need for this research and report.
Professor Phil Purnell from the School of Civil Engineering, University of Leeds and Visiting Professor for the Materials Science Research Centre at RCA is continuously developing new methods that enable the analysis of the lifecycle and the resource flows of materials. He took us through a material flow diagram to help us understand how much textiles the UK uses, where it all goes when finished with, and where anomalies are.
Images: Photos of large presentation boards. Material flow diagram based on various studies and reports that shows how textiles in the UK are collected, exported, incinerated, landfilled and stored in wardrobes. Graphs show statistics specific to Londoners’ clothing use, and maps showing various challenges affecting textile waste.
The diagram shows the mass flow analysis of the UK clothing economy as in 2018. It shows the flow of clothing from imports to where the unwanted clothing items end up, such as landfill, incineration, charity shops and export.
There’s a section for overseas production waste attributable to the UK, though these figures are an estimation and doesn’t necessarily show the extent. It also can’t show the direct CO2 emissions derived from textile and apparel production for the UK market, or indeed for anywhere in the world, and similarly can’t show any associated agricultural products used or wasted. I queried if they were in discussion with farmers and the farming industry to recognise material flows not usually ascribed to fashion, such as the cattle hides that don’t make it to leather production.
The aim of this diagram and associated statistics is to understand where policy can inform, particularly when it comes to reducing consumption. Though, to avoid onus on the citizen, it needs to look also at where production can be cut (i.e. cut-make-trim waste, textile overstock). This research isn’t necessarily about where to improve practices within fashion, but where the clothing originates and where it goes, and what elements are retained.
I think it’s tricky when research or data is purely about fashion, though of course this is needed to minimise diagrammatic information. The board does state that “textile waste in the UK amounts to nearly as much as new clothing consumption” coming from offcuts and unsold clothing. However, I find it problematic to focus on clothing alone, when there are interconnected industries (such as components, embellishments, footwear, leathergoods) because the story and statistics are still undersold.
Policy roadmap discussion.
We moved on to discuss for a short time on how we feel about the “now”, following on from explanation about the material flow diagram.
Essentially, there are no pieces of legislation “with teeth”, and it’s transpiring that the government wants the industry to regulate itself. A participant mentioned how policy seems to them to be reactive rather than proactive, though other countries - such as France - generally look ahead, like with the Right To Repair scheme. The UK government, however, can’t even establish standards across the Local Authorities for recycling, so how to combat a wider supply and value chain?
The European Commission directive 1999/31/EC on the landfill of waste is too full of jargon for me to comprehend, but there was talk of how textiles now mostly go for incineration rather than landfill, with energy from burning saved and distributed. In the material flow diagram, it shows that of the 401,000 tonnes of UK-specific textile waste, 77% is incinerated, while 19% is landfilled, and 4% is other (wherever that means). It was pointed out that previously those figures were reversed. For the government this is a win.
Even when concerning plastics, landfill is the “worst option” with incineration as “preferred”, because it refers to not allowing the build-up of methane and instead being able to harness energy, so controlling it and keeping all the waste underwraps. It is rarely highlighted that of course all the particles are not captured, and it only increases pollution - just of a different sort. It is rarely mentioned too that incinerators sit usually on the outskirts of towns and cities, where there is most deprivation and already an influx of pollution from major circular roads e.g. Edmonton in North London. It’s challenging to have a discussion on the supposed pros and cons of each, when the social element is removed (landfills still pose a threat through removal of useable land, and contaminated groundwater; though my point about this was essentially stated as invalid, that the dye particles - and someone else mentioned microplastics - don’t disintegrate and instead stay inert.
The government’s Resources and Waste Strategy looks appealing and promising, with it stating all the good stuff. But realistically, they keep stalling on plans that support a shift to, as they say, “leave the environment in a better condition for the next generation”, such as with the Extended Producer Responsibility scheme and Deposit Return Scheme.
Environmental Product Declarations were also noted, a business-to-business transaction declaration that quantifies environmental information on the life cycle of a product via Life Cycle Assessment methodology. There are issues with how LCA’s are conducted — such as the views of the assessor, and not including social impacts — and so if something is based on a corrupt methodology, then how can the finished declaration be sound? The argument here was that EPD’s can allow businesses and consumers to understand the comparison between a “good” and a “bad” product — though it requires the consumer to have knowledge and drive, and as mentioned, that the methodology is actually holistic i.e. it may tell you something about CO2 emissions, but it can’t compare land use or regeneration to economies.
Images: 1. A piled high landfill in Ghana [Credit: The Or Foundation]; 2. A citizen boxes up unwanted clothing into a retailers’ Take Back Scheme box [Credit: Unknown].
Policy priority areas.
In this segment we discussed what policies we would prioritise for fashion, split into Society, Tech + Science, Environment and Economy. These are some of the suggestions from participants, along with thoughts or challenges I had.
→ Society.
Education — the ‘green skills gap’ and whether there should be policies on vocational qualifications to close this gap. Also the teachings in school, such as removing any gender stereotypes with curriculum, and perhaps increasing education on value rather than practical skills, because these can already be accessed via YouTube. The problem here is that there needs to be a desire to learn, so that children or adults outside of education will be introduced to these skills, and be inspired to try them. Within school it can be controlled, and that’s where there needs to be an importance laid on STEAM rather than just STEM, and accessibility for all.
Sustainability — that this is a mindset/a way of life, and so how to increase participation from citizens in this shift. The main policy consideration was regarding community spaces, perhaps through the improvement of high streets (also covered under economy). In hindsight, realistically the only way to shift the necessity of a “sustainable mindset” is through regulation, such as with bans on single use plastic, the Deposit Return Scheme and awareness of repair (Right To Repair, Extended Producer Responsibility). However, where does fashion and textiles come under policy recruitment here? You can’t ban people from shopping (and why would the government want that). This is quite interlinked with the economy, as my thoughts look to reintroducting the Duty Free scheme to encourage international shoppers of “British” products.
Advertising — if we’re constantly bombarded with ads to shop at reduced prices, then there isn’t an incentive for citizens to bother trying to curb anything. My argument was that regulation wouldn’t necessarily support smaller businesses from rising up, as it’ll simply return to the fact that those with money are the ones in power. SME’s shouting about how their product is better, more sustainable, supports society isn’t going to make a difference if they’re drowned out by SHEIN’s algorithms. But can there be regulation on monopolies when money is always the driver?
Images: Two campaigns from fast fashion retailer H&M — one for their “Conscious Collection” touting a 100% organic cotton product (and then a stipulation to “see label for the product’s full fiber content”, and another for World Recycle Week. Both scream greenwashing and a need for advertising regulations and transparent communication.
→ Technology and science.
Greenwashing — related to the advertising, the online spaces are bombarded with messaging that drive consumption, and arguably, unnecessary unwanted consumption. Not only are we fighting big businesses selling us stuff constantly, we’re also battling language and jargon. We’re told certain products are better for us and that this research backs it up and those people are wrong… we don’t know what to believe. We are led by propaganda and greenwashing, probably most often without any malicious intent, but rather a misunderstanding. Regulation on terminology and claims can provide standards so that brands/retailers etc can’t unwittingly say something without comeuppance i.e. they have to know what they’re communicating.
The Green Claims Code from the Competition and Markets Authority (CMA), published in 2021, is compiled around six principles based on existing consumer law. It says that green claims “must not omit or hide important information” and “must consider the full life cycle of the product”. Though, it’s unclear how this code is currently being followed, if businesses are being investigated, and what the outcomes are since its inception.
Algorithms — the point on advertising also concerned the use of algorithms to target users with specific ads, brands and offers, and so should there be regulation on social media, and if so, how? I think there are already options with phones to regulate usage time (from the direction of parents), but of course, adults aren’t necessarily going to regulate their own ad-watching through limited device use. And browsers will continue to psychologically increase spending desire through those algorithms. It seems unlikely there’ll be a place for policy in terms of advertising and marketing (especially to regulate the big guns), so unfortunately it’s likely up to the smaller businesses to shout louder, be authentic, build trust and loyalty. Or, citizens need to stop being duped. And it also relates to the greenwashing of being sold actual transparent information through advertising and marketing.
Genetic Modification — this horrified me. A participant mentioned they wanted to see further deregulation of GM, and so I dove deeper to understand why. It was referring to easing of restrictions making it possible for more developments in the biosynthetics space, to increase those novel materials. Whether gene modification or gene editing, this is dangerous tech. It would never be reserved to just the materials space, and why anyway is “bio spider silk” still being seen as a more sustainable offering that a 5,000 year old crop?
Standardisation — the “good” vs “bad” linearities kept coming up, that there should be regulation on this way being best, or that way being worst. It simply can’t be binary. There are so many contexts between businesses, and holistically, in the grand scope of the world i.e. what suits the UK does not suit your pick of any other country. What would you introduce a standard on? If we’re speaking on standards for certifications for claims on fibre origin, then yeah, these should exist (and they generally do), though there are still assertions and manipulations of these standards e.g. fraudulent claims on organic cotton. We can’t standardise farming, even if we all wanted to push for regenerative practices, because it simply doesn’t suit all contexts. We can create frameworks, for instance with The Modern Slavery Act, but who is actually regulating and who is punishing? The UK can’t even regulate single use plastic succinctly, so how could they regulate on standards of fashion practices?
Right to Repair — this was placed here, presumably because it’s somewhat down to the design phase. Companies must design for an item to be able to be repaired, and provide instruction or do the repairs themselves. However, myself and another pointed out that you can already legally repair your own clothing, so how could you further legislate on this? The only way would be through Extended Producer Responsibility where companies must take back their products for repair, reuse or recycling (and not for a profit-spinning reason!)
Images: 1. One of SHEIN’s promotions on their mobile app showing “up to 70% off” offers; 2. Stella McCartney’s Stellasport dress made using Bolt Threads’ bio-engineered spider silk (and marketed as ‘vegan silk’); 3. The Better Cotton Initiative in 2019 were forced to changed when and where on product packaging their BCI label could be used after they were criticised for some products not containing any BCI cotton [Credit: EcoTextile News].
→ Environment.
Farming + fibre infrastructure — I was the only one to mention this. Well, maybe someone would’ve mentioned it later if I hadn’t. But early on I questioned if the researchers were speaking with farmers when analysing material flows; already then you have insight into the amounts of wool clip, sheep skins and cattle hides going unused, not fetching a proper price (valuing the material), or disappearing completely into the system without traceability. Then you have the conversations regarding lack of fibre processing infrastructure for the likes of flax and hemp, plus access to hemp licensing, and farming subsidies that could see farmers being more willing to implement alternative crops (inclusive of dye plants). When food and fibre is so inherently engrained, these industries cannot be separated when it comes to creating policies. You create a policy, for instance, on reopening small-scale abbatoirs (or allowing mobile processing units) and you allow for greater traceability of hides and a reintroduction of small-scale tanneries, and then an opportunity for truly made in Britain products as designers flock for local materials. You’re then able to flip the conversation on what’s a “good” and “bad” practice if we need that determining, as there’s a visualisation of material flows, the effect to a landscape, and impact on regenerating economies.
This whole segment is a session in itself. What policies exist in food that should transcend to fashion, and vice versa?
Deadstock — I missed what the full comment was, but a regulation anyway on deadstock (presumably inclusive of overstock and unsold goods, so ultimately overproduction). In the current policy check-in, France was mentioned as a country with regulation on incineration of unsold inventory, so something similar. In my opinion, the resulting market from customer awareness of deadstock as a “sustainable” solution just gives brands and retailers a get-out-of-jail-free card. Could policy here look to cap how much inventory they produce (including textiles) and fine them if they produce over this? Again, big businesses would just pay a fine (or hide away) rather than finding a solution. It also requires the companies to be transparent, which through the likes of the Fashion Transparency Index, isn’t always going to be the case.
Chemicals — a ban on chemicals was mentioned. We already have in place the ZDHC’s Manufacturing Restricted Substance List that gives guidelines on sustainable chemical management, but this requires stakeholders to want to sign this. There are EU regulations on ingredients; REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is an EU law that demands companies to demonstrate how they are managing potential risks as well as how chemical substances can be safely used. There’s similar in the US. Yet, consumers don’t see these ingredients lists anyway, so how can we really be assured that these “safe limits” have been met or even underserved? Perhaps then — apart from the UK continuing to adhere to REACH and not allowing other products in that haven’t met safe lists — there needs to be regulation on labelling, so that consumers are given the full information. We’re sort of back to EPDs and maybe RFIDs for product traceability.
Images: 1. Salted hides from pasture-farmed cattle hang before tanning [Credit: British Pasture Leather]; 2. Hundreds of tons of clothing in colour-sorted piles in an abandoned factory [Credit: Francois le Nguyen on Unsplash]; 3. Blue-coloured effluent enters a river in Africa from textile factories [Credit: Water Witness].
→ Economy.
Living wage — if sustainability needs to be a mindset to shift overconsumption, then the argument is that ensuring a universal basic income or standard living wage will mean more disposable income for purchasing those “better, more sustainable” products and increasing time capacity for upskilling in such things as repair. The four-day-working-week also slots into this. Personally, I despise this notion, because it further separates folk out into those in particular professions who can indeed work across four days, and those you can’t, or those who choose not to (because e.g. they run their own business).
Sharing economy — examples included; providing incentives for those operating with a co-operative model, introducing the Deposit Return Scheme, more product sharing libraries, retailer take back schemes and community spaces for sharing skills. I’ve got no gripe with this at all, but where does legislation fit in? Retailers must have a take back scheme? Well, that requires infrastructure and not exporting stuff to overseas. Funding for co-ops, then that requires long-term vision not short-term investments. The DRS isn’t suitable for fashion and textiles, but again, EPR could be the option. Upskilling of the community, well that needs resources as well as money, and who’s going to monitor it if the local authorities don’t have capacity and can’t gain more?
Rent support — this involved the regeneration of the high streets as mentioned above. By providing financial support, or regulating rent increases, small businesses could be better placed to establish a brick-and-mortar offering. Charities and not-for-profit organisations may find it more accessible to create a physical space to do the community hubs. It improves the state of towns, could reduce crime, could reduce loneliness and the impact on healthcare, provides a boost to SMEs and essentially fights big capitalism. It’s about degrowth.
Scarcity regulation — made this note, don’t know what it was regarding. I’d written “MOQs” close to it, so think it was probably to do with overproduction. If there’s regulation on how much you can produce somewhere, then you simply don’t overproduce. Or laws such as the one talked about with SHEIN and Temu where levys are imposed if a certain amount is imported. This then forces brands and retailers to look at local production for their supply chains. Although I’m pro the regional local small-scale production value chains, I also note that not all products can be created locally, for instance, your business may be all about giving opportunity to overseas artisans; you allow that to happen because it’s small-scale, and the big guns will simply exploit the system and exploit the people.
Images: 1. Clothes mending workshop from Fast Fashion Therapy run for free for the community with help of the local council [Fast Fashion Therapy]; 2. One of London’s ‘Library of Things’ where household applicances can be hired for a small fee rather than purchased [Seb Rojas]; 3. Old Spitalfields Market in East London, which continuously houses small independent businesses [Cove Collective]; 4. The marketplace for second-hand clothing Charity Super.Mkt sets up home in disused department stores.
This was overwhelming. It was a fundamental starting point to gather citizen insight for sure, especially when participants had their unique backgrounds and propositions. But I left feeling a bit crestfallen that there is so much. Where do you actually start? It’s so dependent on what you see the crux of the issue to be. Is it overproduction? Is it overconsumption? Is it synthetic materials? Is it a need to improve local economies? There is so much crossover, so at least if you look to tackle one challenge then you can usually include other challenges. And therein lies the complication of “what is a priority?”. For UK government it’s of course always going to come back to the economy.
We didn’t discuss recycling infrastructure.
No one actually mentioned the word “regenerative", despite being there for the Regenerative Fashion Hub (maybe because it’s still not a word on everyone’s lips).
We didn’t discuss the onus of designers on impact to waste, and actually how this fits in with a circular economy. We didn’t even really talk about circularity at all.
We didn’t really touch much on how labour rights (or lack of regulation and modern slavery) affects overproduction, greenwashing, local economies, environmental impacts, healthcare - and so should the priority be on actually sorting this out over anything environmental (which is where sustainability always heads).
There was nothing on diversity, though gender equity in roles was mentioned. Reparations for colonialism? Inclusion and accessibility?
Production of materials themselves, and communication of textile knowledge and indigenous wisdom, plus transparency rather than proprietary knowledge.
Water usage and effluent treatment, for raw materials and any recycling or repurposing.
Energy sources across the supply chain.
Biodiversity relating to fibre-growing, land factories are on, product end of life.
And they’re only the challenges I can pull out of my head right now as I’m writing. This is big. Don’t really see how the researchers are going to make recommendations in their report, and honestly, can’t see how the industry is going to shift. One of the closing points was on legislation taking time to kick in, but once it’s there, can have a positive impact — if it’s done right. Problem is, it can take such a long time to see any of these implementations, that the world has moved on, or there’s a consequence people didn’t foresee (or didn’t bother to investigate). The plastic bag charge is one of those plaster-on-the-wound scenarios.
Anyway, it’s urged me to read up on existing and pending legislation.