Fast Fashion and the European Union (EU) Product Environmental Footprint (PEF) Method
A guide to the basics with an aim to redefine sustainability to better address the textile industry’s environmental impact
What is fast fashion?
Fast fashion is the “constant provision of new [clothing] styles at very low prices1” that comes at the expense of the planet and all life forms that inhabit it. Fast fashion is usually characterized by its low prices, poor quality, synthetic materials, human rights violations2, and environmental (land, air, and water) pollution3.
What is the EU PEF method, and what is its intended purpose?
The Product Environmental Footprint (PEF) is a proposed method that seeks to improve upon current Life Cycle Assessment (LCA) methods that was launched in 2013 by the EU Commission4. PEF seeks to become the standardized methodology for labeling industry products’ environmental footprints by measuring environmental “impacts occurring from raw material extraction to their end of life5”. PEF is part of the EU Commission's goal to move “away from the linear “take-make-use-dispose” model6” and to a more circular approach where the “value of products, materials and resources is maintained in the economy for as long as possible, and the generation of waste is minimized7”.
PEF’s claims include reducing the amount of greenwashing that occurs across industries by providing a framework in which manufacturers must substantiate their green claims. For the consumer, these claims would appear as a simple aggregated score based off of – in the case of textiles – the Global Apparel and Footwear PEF category rules (PEFCR)8. This score, however, shows an incomplete picture.
The problem with PEF:
PEF, aside from its CRs containing numerous incomplete sections, is non-holistic in its approach to evaluating environmental impacts. PEF does not account for PFAS9 – a group of complex, highly toxic synthetic chemicals – used in manufacturing10, nor does it take into account “social impacts such as worker health and wellbeing or socio-economic, cultural, and health impacts of recommending one fibre over another11”. “A true measure of a product’s life cycle would take into consideration the environmental, economic, and social costs of a product using a framework that accounts for the entire life cycle, including impacts at the end of the product’s life or when it is disposed of12”, but “Andrew Martin, vice president of membership and stakeholder engagement at the Sustainable Apparel Coalition (SAC), which develops Higg Index methodology, told Ecotextile News: “The PEF was never meant … to capture elements such as social and labour impacts13”’, which are arguably the largest drivers of fast fashion.
How PEF fails to address fast fashion:
As part of the EU Strategy for Sustainable and Circular Textiles14, PEFCRs should provide a holistic view of the life cycle of textiles. However, textile PEFCRs do not currently include deadstock15 – unsold merchandise/product – in its calculations, nor does it address fast fashion and the “link between fast fashion and the growing use of fossil-based synthetic fibres16”. In fact, a number of NGOs have come together to warn the European Commission against relying on PEF17 which they see as hardly better in its current state than the widely used and criticized Higg Material Sustainability Index (Higg MSI). The Higg MSI – operated as a for-profit company – has faced numerous controversies over greenwashing – “the act of making false or misleading statements about the environmental benefits of a product or practice18” – so much so that the SAC – which develops Higg methodology – has halted its use19, yet fully endorses PEF20.
Higg MSI claims to be able to compare the environmental impact of different materials so design and development teams can make more sustainable choices21 yet “uses different methodologies across fiber types – rendering the measurement framework arbitrary22”. PEF seeks to assign consistent methodologies across textiles, but still fails. Part of the problem is because “[w]hile the product-focused PEF serves well to compare manufactured industrial goods23”, when applied to agriculturally derived natural products – such as wool, cotton, and flax – “PEF gives misleading results, since the more extensive the agricultural practice is, the worse it scores24”. When aggregated, this has led to a subtext in which petroleum-based textiles are supported over natural plant and animal fibers.
In an open letter to Executive Vice-President Timmermans of the European Commission, a coalition of NGOs voiced their concerns that “the PEF method has proved ineffective at capturing the non-physical durability (or ‘emotional’ durability) of a product, i.e. the idea that it is not only the physical properties of a product (such as fibre strength) that determine whether it will be used and worn for a long time; factors such as price and trend temporality play a role too. In this respect (and due to all lifecycle aspects not being covered as outlined above) there is a risk that the method favours the synthetic fibres which have driven overproduction25”.
In an industry where garment workers receive only 55% in wages what they need to survive26 and in a scoring system where “[a]n apparel manufacturer or producer that pays a living wage scores the same as those that pay below subsistence wage27”, there is a clear need to continue reforming the way textile producers approach the concept of sustainability28. PEF does nothing to combat the mentality behind fast fashion29, nor does it penalize destruction of product in an industry where billions of dollars worth of merchandise is destroyed annually30. Finally, PEF does not account for the difficulty of recycling textiles31 (it is “estimated that less than 1% of all textiles worldwide are recycled into new textiles32”), the effects of microplastic pollution on the environment33, or any other number of major impacts that result from the fast fashion industry34. In fact, it doesn’t measure renewability, recyclability, or biodegradability at all35, all of which the fast fashion industry ignores in the first place.
Defining ‘sustainability’ to find a way forward:
In order to address fast fashion and amend initiatives like the PEF method, it’s important to return to “Our Common Future”, the Report of the World Commission on Environment and Development, also known as the Brundtland Report, published in 1987 by the UN. The Brundtland report established UN Sustainable Development Goals (SDGs), and when the EU states that “[w]e are committed to implementing the SDGs in all our policies and encourage EU countries to do the same36”, it means the EU must adhere to the Brundtland definition of sustainability.
Brundtland makes it clear that economic growth, the environment, and social equity are inseparable: “[t]he "environment" is where we all live: and "development" is what we all do in attempting to improve our lot within that abode37”. It is precisely this admission of inseparability that makes PEF incompatible with sustainable development, since PEF fails to include social equity of any kind into its calculations. With Brundtland’s holistic definition of ‘sustainability’ in mind, there are a number of ways to move forward in making positive change in this climate of fast fashion and ever-increasing social inequity.
The main goal: Procedural justice as a framework for positive change
As consumers, we have the ability to make choices about the textiles we consume. However, the fault does not lie with our small decisions, but with manufacturers’ decisions to continue employing exploitative methods of production and advertising. Moreover, the fault lies with policy makers’ inability or refusal to make sustainable policy decisions a priority, and “governments' failure to make the bodies whose policy actions degrade the environment responsible for ensuring that their policies prevent that degradation38”. The individuals and organizations that are responsible for managing resources and protecting the environment need to become institutionally connected with those responsible for managing the economy39.
The real world of interlocked economic and ecological systems will not change; the policies and institutions concerned must40. Policies must be changed on the national and international level of all countries, because as Brundtland puts it, “[H]ope for the future is conditional on decisive political action now to begin managing environmental resources to ensure both sustainable human progress and human survival41”. As it stands, the EU PEF as policy does not promote the necessary change within textile manufacturing to reduce – let alone reverse – the environmental and human degradation it has, and continues to, cause.
What can we do about PEF and fast fashion?
Within the procedural framework, we can support policy makers who uphold the values of sustainable development. We can vote, lend our support by signing petitions, attend town halls, and generally become more involved in the procedural process as regular citizens. We need to put pressure on policy makers to become aware of the facts regarding current textile productions’ impacts on the environment and on humans, and we need to push them to hold corporations responsible for the damages they actively choose to cause. We must remember that fast fashion – and the limited scope of methods like PEF – affects all of us. As non-EU members, we can take warning from PEF and its limitations to address issues of domestic manufacture here in the U.S.
As individuals, we need to keep in mind that “[t]he concept of sustainable development does imply limits – not absolute limits but limitations imposed by the present state of technology and social organization on environmental resources42”. What this means is that there needs to be a change in mentality towards textiles and their relationship with the environment. We need to become educated on the propaganda fed to the public by Big Oil43 (it was British Petroleum that created the term ‘carbon footprint’ to divert attention from their carbon pollution to the individual’s ‘footprint’44) and on how to make natural fiber cultivation regenerative and non-toxic. In order to compete with synthetic fibers, many natural fiber agricultural systems have had to adopt ways of maximizing earnings while minimizing costs, usually at the expense of the environment45.
New ways of thinking about production and consumption need to be adopted in order to make change, and one way is to begin by learning about truly sustainable ways of working with natural fiber agricultural systems. There is so much misinformation surrounding fibers like wool, silk, and cotton, mainly because the large producers competing with synthetic fiber manufacturers have adopted the very methods that are harmful and damaging in the first place. With proper management and care, silk production can be ethical to its silk worms, the environment, and its farmers46; cotton can be raised without pesticides and with vastly reduced water intake when heritage breeds are selected for particular regions47; and wool can be gathered from sheep in a cycle that is not only carbon neutral, but carbon positive by actively sequestering carbon into the soil48. In order to do this, however, mentalities towards these natural fibers need to change. Value needs to be reappropriated49 to these fibers as well as to the regenerative farming practices that can produce them with positive – rather than just neutral – effects.
Outside of mentality changes, we can support legislation like the Consumer’s Right to Repair in the EU50 and push for similar legislation in our own nation that works to dismantle the practice of planned obsolescence and encourages product warranties. We can spread awareness for the Make the Label Count coalition that works to “ensure that sustainability claims for textiles in the EU are fair and credible51”. We can push for other methods that take into account all of the factors that PEF discounts in its assessment, such as the French Planet Score52 that measures sustainability for food. Incidentally, all of these suggestions depend on a mentality shift from a cradle-to-grave mentality (think ‘take-make-waste’) to a cradle-to-cradle mentality that focuses on extending the life of a product and ensuring that it can return to the earth at the end of its life53. An example of this would be using wool whose quality isn’t good enough for textile production to repair footpaths instead of using plastic membranes54. Plastic is kept out of the environment, and wool gets a chance to contribute to reparative measures that will allow it to biodegrade and return to the soil in a way that is regenerative.
In order to embrace a cradle-to-cradle methodology, we as individuals can support nationally made products. Moving away from an international and global production chain to a national footprint could be a first step in repairing the disconnect between people and the sources of their clothing. Better still would be a shift to supporting local fibersheds, or “place-based textile systems focused on the source of the raw materials, the transparency used in the entire supply chain, and the connectivity among all parts, from skin to soil, back to skin.55” Fibersheds, then, are the antithesis to fast fashion and all that it promotes and consumes in order to maintain itself. Where PEF ignores the holistic elements that sustainable development demands, fibersheds show how that ignorance can be combated and overcome in a way that addresses both the needs of the environment and the needs of the people. With changes like these, policies that look through a narrow lens like PEF can be more easily exposed as being disconnected and ineffective in making positive change against the fast fashion industry and environmental deterioration.
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If you’ve made it to the end of this post, then I encourage you to look into the sources I’ve cited in the footnotes below. This piece was a real work of love and passion on my part, but it couldn’t have been written without the help of all of the people whose works I consulted.
The impact of textile production and waste on the environment (European Parliament, 2020)
What is fast fashion and why is it a problem? (Crumbie, 2023)
See footnote 2
Consumption Footprint: assessing the environmental impacts of EU consumption (European Commission, 2022)
Circular economy (European Commission)
See footnote 6
NGOs question value of EU PEF tool (Remington, 2022)
See footnote 10
EU Strategy for Sustainable and Circular Textiles (The Sustainable Angle, 2023)
See footnote 8
See footnote 11
What is Greenwashing? (Lindwall, 2023)
An Introduction to MSI (Higg index, 2023)
See footnote 12
Why the Upcoming EU Legal Proposal to Prevent Greenwashing Should Use the Right Methodologies (IFoam Organics International, 2023)
See footnote 23
See footnote 11
See footnote 12
The Great Greenwashing Machine Part 1: Back to the Roots of Sustainability (Kassalty, Baumann-Pauly, 2021)
The Mentality Behind Fast Fashion (Zabors, 2023)
Why clothes are so hard to recycle (Beall, 2020)
A New Circular Economy Action Plan (EUR-Lex, 2020)
See footnote 1
Make the Label Count (Make the Label Count, 2021)
Sustainable Development Goals (European Commission, 2023)
Report of the World Commission on Environment and Development (United Nations, 1987, pg. 14)
See footnote 37 (pg. 26)
See footnote 37 (pg. 25)
See footnote 37 (pg. 25)
See footnote 37 (pg. 18)
See footnote 37 (pg. 25)
What You Need to Know About Microplastics and Textile (Fibershed, 2022)
Why wool matters (University of Leeds, 2022)
Parliament wants to grant EU consumers a “right to repair” (European Parliament, 2020)
Make the Label Count (Make the Label Count, 2023)
Planet Score: A Scientific and Transparent Calculation Method (Planet Score, 2022)
Ditching the “Cradle to Grave” Mentality (Kate Huun, 2021)
So, What Exactly is a Fibershed? (Fibershed Southern California, 2020)