Interim Report on the Sustainability of the Fashion Industry Contents

1Fashion Retailers’ Responses

Table of retailers’ responses


5.Fashion is big business in the UK. We buy more clothes per person in the UK than any other country in Europe.2 The fashion industry was worth £32.3 billion to the UK economy in 2017.3 Concerns have been raised throughout our inquiry into the sustainability of the fashion industry that the current ‘fast fashion’ business model is encouraging over-consumption and generating excessive waste.4 Many such garments are relatively cheap and aimed at consumers who are encouraged to change their wardrobe on a regular, trend driven, basis.5

6.During our inquiry, we heard worrying evidence about labour practices in factories supplying UK fast fashion and e-retailers, particularly in Leicester. Leicester has the second highest concentration of textile manufacturers in the country and 10,000 textile workers.6 Unite the Union, said that Leicester is a garment manufacturing hub with 700 textile factories producing around one million items of clothing per week for online retailers.7 Unite says that while the majority of factories are compliant, there remain a small number of factories which side-step the law to maximise profits. The ‘fast fashion’ clothing market is characterised by intense cost competition and unpredictable demand.8

Evidence from retailers

7.In autumn 2018 we wrote to sixteen leading UK fashion retailers to request information on the steps they are taking to reduce the environmental and social impact of the clothes and shoes they sell. We first wrote to the UK’s top ten fashion retailers by market share in October. Following worrying evidence we heard, about garment factories in Leicester not paying the minimum wage, we wrote to four online retailers. We also requested evidence from two luxury retailers.

8.We received fifteen responses. Kurt Geiger was the sole company we approached which did not engage with the Committee’s work. We are grateful to the retailers for their responses and engagement with the inquiry.

9.We put a number of questions to retailers regarding labour supply concerns and environmental sustainability issues heard during the inquiry’s evidence sessions. From the responses received, oral evidence supplied by a number of the retailers, and other research, we have examined each retailer’s engagement with labour market and environmental sustainability initiatives and provide an overview here. See above for a table of responses.

Engaged retailers

10.Of the retailers we wrote to, ASOS, Burberry, Marks and Spencer (M&S), Primark and Tesco (engaged retailers) appeared to be the most engaged on sustainability issues. They are participating in most of the leading industry initiatives. They have all made specific commitments to reduce the environmental footprint of their products, either as members of SCAP or independently, in Burberry’s case. We were particularly pleased by the comprehensiveness of the responses received from ASOS, Burberry, and Primark.

Participation in labour market initiatives

11.Each of the ‘engaged retailers’ is a member of the Ethical Trading Initiative (ETI), an alliance of companies, trade unions and NGOs which aims to ensure retailers improve the working conditions of people who make their products and engages in auditing of their supply chain. In its submission, Tesco acknowledged the limitations of this system:

Whilst independent audits are helpful they can be limited in their ability to facilitate improvement, so we have a 40-strong in-house team of labour standards experts based across key Asian sourcing countries, visiting factories every day.9

ASOS acknowledged that there are particular problems with sourcing from UK factories and is a member of Fast Forward, an industry initiative to tackle UK supply chain issues. These issues include a lack of management systems and knowledge of labour laws, which can lead to poor working conditions, and subcontracting which makes it difficult for retailers to identify where products are produced.10

12.ASOS, Tesco and Primark are members of Action, Collaboration, Transformation (ACT), an initiative between retailers and the IndustriALL union working towards living wages for garment workers globally. ASOS was also the first online retailer to sign a Global Framework Agreement with IndustriALL, signing up to the best possible standards on trade union rights, on health and safety, and on the labour relations by the company in its global operations.11 M&S and Burberry have not signed up to the initiative. Although not a member of ACT, Burberry says it has taken steps to establish collective bargaining in its supply chain with 77% of third-party goods manufacturers and 75% of key raw material suppliers covered by Collective Bargaining Agreements (CBAs). Where CBAs are not in place, Burberry uses the Fair Wage Network’s Living Wage Database to address any inconsistencies in wages.12

13.M&S uses separate measures to address labour issues in its supply chain. The retailer says that it requires direct suppliers with over 50 workers to have a worker committee or trade union.13 Its Plan A People Principles also says that it ‘respect[s] the principle of collective bargaining’.14 Under questioning by the Committee, M&S stated that it engages with workers through Business Involvement Groups:

For our 85,000 colleagues we work very, very closely with business through business involvement groups. They have a really good voice in the direction of travel of the Marks and Spencer business. [ … ] We have nothing to hide. We absolutely support the need for freedom of association in supply chains, absolutely in terms of the audits that we do. We are working with worker representatives to understand the reality of what is going on in the factory.15

We note that M&S was initially involved in ACT but decided not to participate.

14.Recent media reports that workers in some garment factories producing clothing for M&S and Tesco, amongst other, are working up to 16 hours a day and being paid as little as 35p per hour, raise serious concerns.16 We also note the wider political context in Bangladesh which saw widespread protests from garment workers over low wages in early January 2019.17

Participation in sustainability initiatives

15.All five ‘engaged retailers’ are working toward ambitious sustainability targets, by industry standards. M&S says it is aiming to source 50 key raw materials, representing 80% of materials used by volume, from ‘sustainable sources’ by 2025. Primark’s long-term goal is to source all cotton in their supply chain sustainably and they have established a sustainable cotton programme with supply chain managers CottonConnect. They also called for a strengthening of government initiatives such as SCAP and the introduction of compulsory take-back schemes.18 ASOS is committed to 60% of raw materials for ASOS products to be sustainably sourced by 2020 and is working toward 100% by 2025. Burberry is aiming to become carbon neutral and source 100% of its cotton through the Better Cotton Initiative (BCI) by 2022. Tesco has pledged to adopt 100% sustainable cotton by the end of 2019 and 100% recycled polyester by 2030. We welcome Tesco’s ambitious targets to demonstrate that it is possible to integrate high volumes of sustainable and recycled fabrics into supply chains.19

16.We were keen to question retailers about their policies for unsold stock in the light of reports detailing Burberry’s incineration of £28.6m of stock in 2017.20 We heard evidence that ‘the Burberry stock-burning example has exposed only the tip of the iceberg’.21 We were told by the retailers that they do not destroy unsold stock unless there is a health and safety reason for doing so. Schemes outlined to tackle unsold stock include discounting through outlet stores, donating to charity and rebranding for sale through third parties. We welcome Burberry’s commitment to end incineration and acknowledge that the company is engaged with a range of other sustainability initiatives to reduce its environmental impact.22

Moderately engaged retailers

17.We received responses from Arcadia Group, Asda Group, Debenhams and Next Retail that showed each retailer has taken some steps to address labour market and environmental sustainability issues. Debenhams particularly deserve credit for the range of programmes it is involved in and its intention to have in-store Corporate Social Responsibility Ambassadors.23 We acknowledge these efforts but believe these retailers have the potential to go further.

Participation in labour market initiatives

18.We are encouraged by these ‘moderately engaged retailers’ engagement with labour industry initiatives. All excluding Asda are members of ACT. Debenhams also participates in Swasti LIFE, a programme to empower workers in its Indian supply chain, and The China Collaboration which addresses critical issues in its China supply base.24 Each retailer, except for Arcadia, is also a member of ETI. At our retailer evidence session, Jamie Beck, Head of Supplier Management at Arcadia, commented that, ‘we have a strong fashion footprint programme, an ethical trading programme, which we have had for many years’.25

Participation in sustainability initiatives

19.Arcadia and Next are both members of the SCAP initiative. Although not a member of SCAP, Debenhams has signed up to the ‘Better Retail, Better World’ pledge which focuses on issues of ‘modern slavery, decent work, sustainable economic growth, inequalities, climate change, responsible consumption and production.’26 Debenhams and Asda run take-back schemes in store. In oral evidence, Arcadia confirmed its take back scheme is limited to its head office and flagship Oxford Circus store.27 Next does not run a take-back scheme.

20.Debenhams makes use of the recycled fibre REPREVE in its sustainable products.28 Both Next and Arcadia say they are investigating using greater amounts of recycled cotton and polyester in the future. Next identified the cost of recycled cotton as a key barrier to using recycled cotton. Arcadia highlighted the limited availability of recycled fabrics as a factor.29 Asda said they do not currently have the facility to measure recycled content in their products.30

21.We recognise the efforts of these retailers and the steps taken on labour market and sustainability issues to date, but we believe these retailers have the potential to do more.

Less engaged retailers

22.Our analysis highlights that a number of retailers have not prioritised sustainability in their company policies. This included online retailers Amazon UK, Boohoo and Missguided along with traditional retailers JD Sports, Sports Direct and TK Maxx (‘less engaged retailers’). We accept that TK Maxx and Amazon UK are subsidiaries of international corporations who manage their initiatives, however, this does not absolve them of responsibility given their role in the UK fashion industry. The lack of engagement from Amazon was particularly notable. We received a two-page response which did not engage substantively with the questions posed. While we understand that Amazon is a logistics provider and a seller on behalf of other businesses, Amazon UK is a growing member of the UK fashion industry, with own label brands and as a patron of the British Fashion Council. Its size, online reach and potential for growth as a fashion retailer means it will have to engage more seriously with its sustainability responsibilities in future.31

Participation in labour market initiatives

23.During our inquiry, we heard worrying evidence regarding labour practices in factories supplying UK fast fashion and e-retailers, particularly in Leicester. At our first hearing journalist Sarah O’Connor told us, ‘the going rate for a garment worker in lots of places in Leicester is £3.50, £4 an hour. I was told that £5 was like a really top rate.’32None of these retailers are members of ACT. Missguided is the only ‘less engaged retailer’ which is a member of ETI and was critical that its ‘direct competitors’ have not also joined.33

24.In its submission, Missguided acknowledged that ‘there are significant issues in Leicester with compliance to UK employment law and ensuring workers are paid the minimum wage.’34 ETI confirmed Missguided is actively participating in its Leicester Working Group. As part of its work with the ETI, Missguided has banned cash payments, stopped working with 60 factories in Leicester and funds a whistleblowing helpline.35 We recognise that Missguided is engaged on this issue and acknowledge the efforts they have made, particularly in Leicester.

25.At our hearing with fashion retailers, Carol Kane, co-founder and joint Chief Executive of Boohoo, confirmed the retailer works with 94 suppliers and 76 cut, make and trim units (CMT) in Leicester.36 They also have a sourcing and compliance team based in Leicester. The retailer is not a member of ETI.37 At our evidence session, we questioned Carol Kane on Boohoo’s reluctance to join ETI. She said that, ‘ … we have been struggling to see where the benefits would be to some of our suppliers. We are not closed to the idea.’38

26.When we pressed Carol Kane on why Boohoo Group would not sign up to the ETI, Ms Kane replied:

… we are using all of the same standards. We are not doing anything differently from the ETI. All our audits and all our standards are based upon their code and their conduct, so we are utilising all of that. The only difference today is one of a commercial decision. Being members we will be required to publish our whole supply chain, which is currently our engine room.39

27.ETI subsequently disputed this assessment. They said that Boohoo’s assessment was ‘based on a limited understanding of what ETI does and what we expect from our members.’40 ETI said that adoption of its labour standards (the ETI Basecode) is just one of the basic requirements for company membership and that it also expects members ‘to show active engagement around the core principles of ethical trade and to demonstrate continuous improvement in their supply chain practices.’41 ETI further said it expects its members ‘to take a proactive approach to identifying and resolving issues, and to demonstrate clear improvement over time.’42

28.At our evidence session with retailers, we questioned the joint Chief Executive, Carol Kane, about union recognition within Boohoo. She told us that Boohoo would recognise a union ‘if the workers would like it’ but that ‘there does not currently appear to be a demand for our workers in our Burnley warehouse to require a union’.43 Following this session, the union, Usdaw, provided a written submission contesting Boohoo’s evidence. This included a timeline dating back to January 2017 outlining 23 recruitment and awareness activities for Boohoo’s Burnley staff and written communications to Carol Kane and Boohoo’s HR Director to secure union recognition for Boohoo workers. They said:

Overall, it is clear that despite Carol Kane’s assertion to the committee that Boohoo is open to recognising a trade union to represent their workers, the company has, over a prolonged period of time refused even the most basic level of engagement with Usdaw and appears hostile to the very idea of recognising a trade union.44

We recommend that Boohoo engage with Usdaw as a priority and recognise unions for its workers.

29.We were also concerned about the buying practices of e-retailers and reports of samples meetings being ‘like a cattle market’.45 In their written evidence, both Missguided and Boohoo stated that they do not allow buyers to order from suppliers at any price and that they provide training on costing. Missguided said that, ‘we simply do not allow our buyers to order from suppliers at any price and have invested in significant and robust training to ensure colleagues have a deep insight into manufacturing costs.’46

30.Responding to allegations raised at our first hearing Boohoo admitted that negotiations were carried out in front of other suppliers but denied that manufacturers were played off against each other. Carol Kane told us, ‘I do not know of any instances and I do not accept there are any instances where suppliers are played off against each other.’47 This evidence was challenged in a written submission to the Committee from a supplier to both retailers, who said:

… these firms work with suppliers across the world, each factory/supplier is willing to undercut the next in order to get the orders, so people are working [for] 10 pence profit sometimes per garment–this is due to the buyers in these fast fashion firms being told to hammer down the prices and make the supplier reduce the cost.48

Participation in sustainability initiatives

31.Our research found that Amazon UK, Boohoo, Missguided, JD Sports, Sports Direct and TK Maxx participate in few industry sustainability initiatives. Recycling waste and complying with the Government’s Carbon Reduction Commitment is not sufficient to offset the environmental damage caused by the fashion industry. None of these retailers have signed up to SCAP’s targets to reduce their carbon, water and waste footprint. Use of recycled materials in products is limited.

32.Missguided is not engaged with any of the sustainability actions we considered in this assessment. On recycled materials, the retailer said, ‘we recognise that most of the work in this area has been done on the use of PET, turning it into polar fleece, but this is not a material which features significantly in our ranges.’49 This demonstrates a lack of understanding of the range of industry initiatives on recycled materials. The retailer has a wide online reach and is influential amongst its target audience of 16 to 29-year-old women. We believe they can do much more to understand, raise awareness and address sustainability issues in the industry. At our evidence hearing, the retailer said it will investigate joining SCAP in its next financial year. We recommend that it prioritise this.50

33.In its response to a question about microplastics, JD Sports discussed their plastic recycling efforts and did not address the issue of microplastics.51 Sports Direct demonstrated more knowledge of the issue but is yet to take significant steps to address the problem.52 Neither are formal members of the Microfibre Consortium. Given their roles as leading sportswear retailers, we believe both JD Sports and Sports Direct should show leadership on this issue.


34.We want to see a thriving fashion industry in the UK that employs people, inspires creativity and contributes to the overall economic success of the UK. We are surprised that there is no one body that speaks for the UK textile industry. The fashion industry’s current business model is clearly unsustainable, especially with a growing middle-class population and rising levels of consumption across the globe. We are disappointed that few high street and online fashion retailers are taking significant steps to improve their environmental sustainability. The current exploitative and environmentally damaging model for fashion must change. We believe retailers have an obligation to engage with these issues and recommend that they show leadership through engagement with industry initiatives. We will publish a final report in the coming weeks setting out recommendations to Government for policies to encourage a more transparent, fair and sustainable fashion system.

2 European Clothing Action Plan, (March 2018).Used Textile Collection in European Cities,

4 Phoebe English (SFI0055); Fashion Revolution (SFI0056); TRAID (Textile Reuse & International Development) (SFI0010); Professor Tim Cooper (SFI0049); ECO AGE LTD (SFI0075)

5 Professor Tim Cooper (SFI0049)

6 Letter from the Mayor of Leicester Sir Peter Soulsby to the Chair (21 Dec 2018)

7 Unite the Union (SFI0084)

8 Unite the Union (SFI0084)

9 Tesco - F&F (SFI0074)

10 ASOS (SFI0080)

11 ASOS (October 2017), Press Release: ASOS signs Global Framework Agreement with IndustriALL.

12 Burberry Limited (SFI0083)

13 M&S (2017), Our approach to Human Rights, p. 32.

15 Environmental Audit Committee (EAC), Sustainability of the fashion industry, Qq127–128

18 Primark Limited (SFI0062)

19 Tesco - F&F (SFI0074)

21 Fashion Revolution (SFI0056)

22 Burberry Limited (SFI0083)

23 Debenhams (2019), Corporate Social Responsibility.

24 Debenhams plc (SFI0061)

25 EAC, Sustainability of the fashion industry, Q143.

26 Debenhams plc (SFI0061). Better Retail Better World is mobilising the retail industry to meet some of the biggest global challenges of the coming decades using the United Nations Sustainable Development Goals as a framework.

27 Arcadia Group Ltd. (SFI0065); EAC, Sustainability of the fashion industry, Q178, Q185.

28 Debenhams plc (SFI0061)

29 Next plc (SFI0063); Arcadia Group Ltd. (SFI0065)

30 Asda (SFI0066)

31 Amazon (SFI0078); Pi Datametrics, Q3 and Q4 Pi Leaderboard Report, UK, Fashion Retail, September 2015 - December 2018.

32 EAC, Sustainability of the fashion industry, Qq47–48.

33 Missguided Ltd. (SFI0076)

34 Missguided Ltd. (SFI0076)

35 Ethical Trading Initiative (SFI0089)

36 EAC, Sustainability of the fashion industry, Qq284–285.

37 Boohoo Group plc (SFI0082)

38 EAC, Sustainability of the fashion industry, Q328.

39 EAC, Sustainability of the fashion industry, Q328, Q330.

40 Ethical Trading Initiative (SFI0089)

41 Ethical Trading Initiative (SFI0089)

42 Ethical Trading Initiative (SFI0089)

43 EAC, Sustainability of the fashion industry, Qq336–339.

44 USDAW (SFI0096)

46 Missguided Ltd. (SFI0076)

47 EAC, Sustainability of the fashion industry, Q289.

48 N/A (SFI0085)

49 Missguided Ltd. (SFI0076)

50 EAC, Sustainability of the fashion industry, Q374.

51 JD Sports written evidence

52 Sports Direct International plc (SFI0077)

Published: 31 January 2019