The Debates Surrounding Textile Environmental Impact Scores

Impacts to Consider for an Environmental Labeling Representative of Fashion Footprint

The goal of an environmental score for apparel is to reveal their impact on the environment so that consumers are encouraged to choose truly virtuous garments.

However, the French official methodology, which will become mandatory, has not yet been finalized, mainly due to challenging decisions on the choice of indicators to consider and their weighting.

In France, a methodological foundation has been formed by ADEME (Agency for the Ecological Transition), which you can read more about in this article. The choices made are challenged by various stakeholders in the textile industry (e.g., DEFI Mode, UIT) and impact calculation specialists (e.g., Clear Fashion), who have proposed alternative methods during the Xtex call for projects organized by ADEME.

Here are the main challenges that arise when choosing indicators for the environmental score.

The number of indicators to integrate into the environmental score calculation

Two dimensions must be considered when selecting impacts to integrate into the environmental display methodology: feasibility and the quality of indicators.

A too limited choice of indicators does not capture the product's impact on the environment, but the multiplication of indicators can make the environmental score calculation too complex and costly, thus hindering its feasibility.

Moreover, some impacts are challenging to measure with quality indicators. Ecobalyse, the automated impact calculation tool developed within the Ministry of Ecological Transition, classifies environmental indicators of the PEF (Product Environmental Footprint European) score into 3 levels of recommendation:

• Level I: Satisfactory quality
• Level II: Satisfactory quality but needs improvement
• Level III: Incomplete data, use with caution

For example, indicators used to model land use, mineral or metallic resource use, and fossil resource use – although the best available to date – are classified as level III.

When using indicators for comparison purposes, such as for the environmental score, Ecobalyse indicates that level II indicators can be used – with precautions in their interpretation. However, it expresses a reservation about level III indicators and recommends discussing results obtained with and without their integration into the calculation method.

Two priorities emerge from the reflection on the selection of environmental display indicators:

1. Choose indicators that model the most significant impacts of clothing, with a focus on data quality.
2. Continue working towards continuous improvement of data and calculation methodologies so that more and more indicators are of satisfactory quality and can be added to the method.

Weighting of Indicators in the Final Environmental Score of a Garment

Once the indicators have been selected, they need to be aggregated into a single environmental score. To achieve this, decisions must be made regarding the weight assigned to each indicator in the final result.

This weighting should reflect the objectives set for environmental labeling and how they have been prioritized.

The PEF method prioritizes greenhouse gas emissions, as they represent 21% of the aggregated score, while other indicators range between 1 and 9%. You can find the coefficients of the 16 impacts considered in the PEF score here.

Article 2 of the French Climate and Resilience Law states that environmental labeling must account for relevant impacts for each product category, impacts that will be published through an implementing decree. The law still emphasizes greenhouse gas emissions, biodiversity impacts, and the consumption of water and other natural resources.

More specifically, to ensure that the aggregation of impacts does not mask the garment's impact on climate change, the most urgent challenge for legislators, the law requires that environmental labeling specifically discloses greenhouse gas emissions, in addition to the aggregated score.

The Limits of Existing Methodological Foundations for a Comprehensive Consideration of Clothing Impacts

The indicators chosen for the ADEME technical foundation and the PEF methodology have limitations, highlighted by Ecobalyse in a section on methodological limitations, and several impact calculation actors, including Clear Fashion, in a Tribune published on February 27, 2023.

Here are the limitations of life cycle assessment (LCA) references for textile environmental labeling:

1. Biodiversity: Some PEF indicators are linked to biodiversity impact but are insufficient to accurately reflect it.
2. Plastic pollution: Synthetic fiber clothing releases microplastics during washing and use, causing massive environmental pollution and entering our food chain. This significant impact of the textile industry is not considered in the LCA methodological foundation, introducing a questionable bias in favor of synthetic fibers.
3. Physical and emotional durability of clothing: The quality of products and the speed of collection renewal strongly influence how quickly consumers discard their clothes and buy new ones. These parameters have a significant impact on the textile industry's environmental impact. However, they are not considered in existing references; currently, LCAs are calculated based on standard product lifetimes.
4. Production mode: The current LCA reference calculation method does not consider the geographical origin of natural materials, which has an impact (e.g., irrigation needs vary by country), or agricultural practices (organic or conventional agriculture). For example, this does not allow for the valorization of organic cotton compared to conventional cotton, despite its significantly lower impact.

The limitations of the PEF method were confirmed in the European Green Claims directive proposal, highlighting its inability to account for textile microplastic release. The European Commission suggests that a unique environmental label should not rely solely on the PEF method.

In response to these biases, Ecobalyse raises the question of considering labels (e.g., Oeko-Tex, organic agriculture) in environmental labeling. This would allow for a more nuanced reflection of the environmental impact of textile clothing items, such as water pollution.

It is still necessary to find a way to integrate this qualitative information, unlike quantitative indicators in LCA, into the environmental score calculation. For this, inspiration can be drawn from the Ecoscore, used for food products: a bonus system on the score has been established to reward virtuous agricultural practices.

The Level of Specificity of Data Used in the Environmental Score Calculation of Fashion Products

To calculate the environmental score of a garment, three approaches are possible in terms of data specificity:

• The generic approach relies on secondary data available in databases. These data are averages and do not allow for significant differentiation between two products with similar weight and composition.
• The specific approach relies on primary data collected by companies. This approach enables a detailed differentiation between products because it uses real data from the life cycle of each product (e.g., energy consumption in factories, product transport).
• The semi-specific approach, considered by ADEME as the most suitable for environmental labeling, involves companies entering primary data for key parameters and complementing them with secondary data (e.g., the company enters the country of a manufacturing stage, which is supplemented by default data on the energy mix of that country).

There is a significant challenge here, also raised by the Green Claims directive proposal, to find the right balance between:

• Default data, which are approximations but make environmental labeling accessible to all actors, including SMEs.
• Real data, which would enable the calculation of very precise environmental scores but are complex and costly to collect.

An approach suitable for all actors, regardless of their data collection capacity, should be adopted to generalize environmental labeling. However, it should encourage refining the data to continuously improve the precision of environmental labeling.

ADEME proposes an incentive solution for continuous data improvement: using default, conservative data (which tends to overstate the score), to be replaced when possible by specific company data.

A major challenge for fashion brands is to collect data on the entire life cycle of their products to refine their environmental scores and highlight their products. Given the opacity of textile supply chains, traceability processes must be established.

Textile Environmental Score and the Consumer

Once the environmental impact of the garment has been calculated, it needs to be presented to the consumer in the form of a score that allows them to compare the environmental performance of different garments.

Here, once again, questions arise about what the environmental score should precisely allow for comparison and its communication modalities to the consumer.

Scale of Rating

Once the impacts have been calculated and weighted, a grade must be assigned to the textile product.

To do this, a rating scale must be determined using market-representative products as benchmarks for grading. This requires extensive sampling of references available on the market and calculating their environmental performance. This will configure a scale that captures the diversity of products and highlights the most virtuous ones.

Achieving an A grade should be possible, corresponding to ambitious goals compatible with the trajectory outlined by the Paris Agreement, to encourage brands to transform in this direction. These benchmark goals must be regularly revised upwards as the industry progresses, while ensuring a certain stability in the rating scale over time.

The type and granularity of the scale (Letters from A to 5, a score out of 100 or 10, colors, absolute score, etc.) must also be chosen.

The Level of Detail to Display to the Consumer

One of the objectives of environmental labeling is to inform the consumer in a simple and clear manner about the environmental impact of clothing items. This aligns with a single score that aggregates all impacts, allowing for a quick interpretation of environmental labeling.

However, ADEME also aims to educate consumers and make them aware of the multi-criteria approach reflected in the environmental score.

So, should the detailed impacts be displayed? Multiple thematic sub-scores per impact category?

This depends on the available space on the product, but it is certain that the aggregated score must be prominently featured to serve as a tool for consumer comparison, and sub-scores should only serve to illuminate the methodology and meaning of environmental labeling.

Regardless of the level of explanations displayed on the product, the methodology must be transparent, and its details must be accessible to the consumer.

Additional information can also be added to environmental labeling to provide more references to consumers: the score of the "average product" in the category (with a methodological challenge in defining this average product), a CO2 "budget" reference per person, etc.

The Appearance and Communication Medium of Environmental Labeling

The visual presentation of environmental labeling is crucial to guide consumers' clothing purchases toward the most sustainable options. A clear color code should be chosen to enhance the impact of the score and comparability between products at a glance.

The question of the medium arises when selecting the modalities of environmental labeling: should it be physically affixed to the product? Accessible in a digital format?

In a report on its discussions with the working group responsible for food environmental labeling, ADEME emphasizes the complementarity of these two solutions:

Physical labeling allows environmental labeling to be immediately accessible to the widest range of consumers.

Digital labeling provides more information and ensures the transparency of the methodology without overloading the label with information.

The Prohibition of Alternative Methods for Calculating Environmental Impact

To enable consumers to compare all textile apparel products based on harmonized criteria, the Climate and Resilience Law plans to prohibit alternative environmental labels: only the official methodology, to be validated by decree by the end of 2023, will be authorized.

This raises concerns among several environmental impact assessment actors (Clear Fashion, Ecoeff Lab, Good Fabric, Green Score Capital, La Belle Empreinte), who fear censorship of additional information and the widespread adoption of an imperfect methodology without the possibility of improvement.

So, should there be one or multiple authorized methods of environmental labeling?

It is obvious that for the sake of clarity and the cross-applicability of the environmental score, a singular system of calculation and display must be featured on products. The coexistence of multiple competing scores, based on different calculation methods with incomparable results, would only contribute to consumer confusion.

However, it should still be possible to provide supplementary information on the product's environmental performance (e.g., social impact, impact on human health, animal welfare).

The method chosen by public authorities must also be updated and refined as data quality improves, methodologies evolve, and market dynamics and relevant impacts change. The working group currently engaged in constructing environmental labeling must persist even after the official methodology is implemented and continue working towards its continuous improvement.

Conclusion

According to ADEME, if consumption patterns do not change, the fashion industry will account for more than a quarter of greenhouse gas emissions by 2050. Urgent transformation is therefore essential, and environmental labeling must serve as an effective tool to address this urgency.

To achieve this, the development of environmental labeling must be guided by ambitious public policy objectives, and the system must be aligned with existing standards to avoid multiplying tools and creating uncertainty that could foster greenwashing.

The choice of methodology indeed involves a significant challenge in combating greenwashing: environmental labeling should enable the distinction between actors genuinely committed to ambitious eco-design initiatives and those whose strategies do not truly align with a trajectory of substantial reduction in greenhouse gas emissions and impact on biodiversity.