Fixing fashion: clothing consumption and sustainability Contents

Conclusions and recommendations

Introduction - fashion & sustainability

1.We want to see a thriving fashion industry in the UK that provides decent work, inspires creativity and contributes to the economic success of the UK. The fashion industry’s current business model is unsustainable, especially with growing populations and rising levels of consumption across the globe. Over-consumption and climate change are driving widespread environmental damage. The exploitative and linear business model for fashion must change. The various parts of the fashion industry must come together to set out their blueprint for a net zero emissions world. This will require reducing their carbon consumption back to 1990 levels. Given scientists’ stark warnings on climate change and biodiversity loss, we need to fix fashion. (Paragraph 22)

The social cost of our clothes

2.We were shocked by the treatment of Missguided’s auditors. If this is how factory owners treat potential customers, we dread to think of the conditions endured by their workers. (Paragraph 49)

3.‘Made in the UK’ should mean workers are paid at least the minimum wage in a safe workspace. It is unacceptable that some workers in the UK making clothes for fast fashion retailers are not paid the minimum wage and are suffering serious breaches of health and safety law in their workplaces. We support calls from the Director of Labour Market Enforcement for a more proactive approach to the enforcement of the national minimum wage. HMRC’s National Minimum Wage team needs greater resourcing in order to increase their inspection and detection work. We also recommend that Boohoo engage with Usdaw as a priority and recognise unions for its workers. We recommend that textile retailers operating internationally follow the example of Asos, H&M, Esprit and Inditex in signing up to Global Framework Agreements. These put in place the highest standards of trade union rights, health, safety and environmental practices, across the retailers’ global operations, regardless of local country standards. (Paragraph 50)

4.There must be more transparency in supply chains and there is a strong case for the Modern Slavery Act to be strengthened. The current requirement to produce a statement does not ensure that action is taken by big retailers and even this is not adequately monitored. The Government should publish a publicly accessible list of all those retailers required to release a modern slavery statement. This should be supported by an appropriate penalty for those companies who fail to report and comply with the Modern Slavery Act. This will increase transparency and require the establishment of formal monitoring of whether statements comply with legislation. (Paragraph 63)

5.The Companies Act 2006 requires that a statement be made on human rights issues in a company’s Annual Report only ‘where necessary’. This system lacks accountability and places too much reliance on companies to self-disclose. We recommend that the Companies Act 2006 be updated to include explicit reference to ‘modern slavery’ and ‘supply chains’. Statements on a business’ approach to human rights in its supply chain should be mandatory as part of the Annual Report. The Financial Reporting Council’s (FRC) Corporate Governance Code and UK Stewardship Code, and the Financial Conduct Authority’s (FCA) listing rules should likewise be amended to require modern slavery disclosures on a comply or explain basis by 2022. If this is not possible then a Corporate Duty of Vigilance Law, as in France, should be considered. Fashion retailers must not be allowed to turn a blind eye to labour and environmental abuses in their supply chains. Retailers should be investing in technology that allows them - and their customers - to track where their materials and products are sourced and made. We recommend that the Government strengthen the Modern Slavery Act to require large companies to perform due diligence checks across their supply chains to ensure their materials and products are being produced without forced or child labour. We also recommend that Government procurement should be covered by the Modern Slavery Act. (Paragraph 64)

6.We recommend that the Government works with industry to trace the source of raw material in garments to tackle social and environmental abuses in their supply chains. Digital technology is widely used in other supply chains. We do not understand why a modern high-tech industry like fashion does not have these systems already in place. Some companies told us they can trace their materials down to Tier 4 suppliers. This begs the question - if one can do it, why can’t all? This first step is essential if fashion is to tackle its waste, water, chemical and carbon footprint. This also reduces the opportunities for sub-contractors to take their cut along the supply chain. (Paragraph 65)

Fashion’s environmental price tag

7.We are unwittingly wearing the fresh water supply of central Asia and destroying fragile ecosystems. Consumers can play their part by avoiding products with pre-made rips and tears and seeking sustainable or organic cotton wherever possible. Governments should oblige retailers to ensure full traceability in their supply chains to prove decent livelihoods and sustainably sourced materials. (Paragraph 72)

8.The Government should facilitate collaboration between fashion retailers, water companies and washing machine manufacturers and take a lead on solving the problem of microfibre pollution. Ultimate responsibility for stopping this pollution, however, must lie with the companies making the products that are shedding the fibres. Further research needs to be carried out into how design can be used to limit emissions of synthetic fibres and the lessons applied quickly. The need for more research should not be used as an excuse for inaction by retailers. Fashion retailers should be testing new synthetic garments for fibre release and publishing figures. (Paragraph 92)

9.More research also needs to be carried out urgently into the occupational health risks of working with synthetic fibres. The Government should ask the Health and Safety Executive to review the evidence and take action accordingly. Manufacturers must be mindful of potential risks now and should seek to reduce the exposure of garment workers to airborne synthetic fibres. (Paragraph 93)

10.Gaining a full picture of the impact of different fibres is important so that businesses, consumers and policymakers can decide on the most effective solutions. The work that WRAP has done to document the impact of fashion consumption and bring businesses together to share best practice and facilitate change is commendable. However, WRAP has faced significant funding cuts, with budget allocation reducing from £56 million in 2009/10 to less than £10 million for 2017/18. The Government must ensure that WRAP’s Sustainable Clothing Action Plan (SCAP) is adequately funded to provide its services to any retailer that wants to improve its sustainability performance - regardless of its size. Post 2020, SCAP target ambitions must increase. To ensure the scheme continues we recommend that retailers pay for the funding of SCAP. This should ideally be included in the Extended Producer Responsibility Scheme. This should happen whether or not an EPR scheme is introduced. This could be set relative to revenue with discounts available for SMEs. SCAP does not currently include any commitments to reduce microplastic pollution from synthetic garments. Post 2020 SCAP should include new targets following the Ecodesign Directive, including reducing microplastic shedding. (Paragraph 101)

11.Members of SCAP have made some progress in reducing their carbon and water consumption, but action has not been swift enough on reducing waste. We are disappointed that just 11 fashion retailers are signatories. These improvements have been outweighed by the increased volumes of clothing being sold. A voluntary approach has failed. A retailers’ commitment to SCAP targets should be seen as a ‘licence to practice’. We recommend that compliance with SCAP targets should be made mandatory for all retailers with a turnover of more than £36 million–a threshold in line with the Modern Slavery Act. This should be done under a new Extended Producer Responsibility Scheme. The Government needs to provide clear economic incentives for retailers to minimise their environmental footprint. It should implement the EU’s Ecodesign Directive in the Circular Economy Package into UK law in its Resources and Waste Strategy and upcoming Environment Act. (Paragraph 102)

12.A kneejerk switch from synthetic to natural fibres in response to the problem of ocean microfibre pollution would result in greater pressures on land and water use - given current consumption rates. Encouraging a move from conventional to organic cotton and from virgin polyester to recycled PET (in garments designed to minimise shedding) could help to reduce the impact of the clothing industry. We recommend that the Government reforms taxation to reward fashion companies that design products with lower environmental impacts and penalise those that do not. The Government should investigate whether its proposed tax on virgin plastics, which comes into force in 2022, should be applied to textile products that contain less than 50% recycled PET to stimulate the market for recycled fibres in the UK. As part of the new EPR scheme, Government and industry should accelerate research into the relative environmental performance of different materials, particularly with respect to measures to reduce microfibre pollution. (Paragraph 103)

Textile waste and collection

13.While incineration of unsold stock ‘recovers’ some energy from the products, it multiplies the climate impact of the product by generating further emissions and air pollutants that can harm human health. Incineration of clothes made from synthetic fibres may release plastic microfibres into the atmosphere. Climate changing emissions will have been generated when the products were created and more CO2 will be produced when they are burnt. The waste hierarchy suggests that reuse and recycling comes first. This should be a priority means of dealing with unsold stock. Incineration should only be used as a last resort where there is a health and safety case for destroying the stock. The Government should ban incinerating or landfilling unsold stock that can be reused or recycled. (Paragraph 122)

14.Our desire for fast fashion, fuelled by advertising, social media and a supply of cheap garments, means we are disposing of over a million tonnes of clothes every year in the UK. Under the UN Sustainable Development Goals, the UK is committed to ‘to ensure sustainable consumption and production’. We need to reduce the environmental footprint of the UK’s textile production and consumption. To do that, we need to reduce textile waste, improve resource efficiency and reduce the carbon emissions and water footprint of the clothes we buy. We need to simply buy less, mend, rent and share more. To support this we recommend that lessons on designing, creating, mending and repairing clothes be included in schools at Key stage 2 and 3. The creative satisfaction of designing and repairing clothing can offer an antidote to the growing anxiety and mental health issues amongst teenagers. As well as providing a space to promote creative expression, the skills learnt can also provide a potential pathway towards job opportunities. (Paragraph 130)

15.The Government must end the era of throwaway fashion. It should make fashion retailers take responsibility for the waste they create by introducing an Extended Producer Responsibility scheme for textiles and reward companies that take positive action to reduce waste. A charge of one penny per garment on producers could raise £35 million for investment in better clothing collection and sorting in the UK. This could create new ‘green’ jobs in the sorting sector, particularly in areas where textile recycling is already a specialist industry such as Huddersfield, Batley, Dewsbury and Wakefield in West Yorkshire. The Government’s recent pledge to review and consult on how to deal with textile waste by 2025 is too little too late. We need action before the end of this parliament (2022). (Paragraph 131)

16.The Resources and Waste strategy should incorporate eco-design principles and offer incentives for design for recycling, design for disassembly and design for durability. It should also set up a new investment fund to stimulate markets for recycled fibres. (Paragraph 132)

New economic models for the fashion industry

17.We need new economic models for fashion which are based on reducing the material consumption associated with growth. The Government should explore how it can support the sharing economy. The Chancellor should use the tax system to shift the balance of incentives in favour of reuse, repair and recycling to support responsible companies. The Government should follow Sweden’s lead and reduce VAT on repair services. (Paragraph 145)

18.Retailers must take responsibility for the social and environmental cost of clothes. They should use their market power to demand higher environmental and labour standards from suppliers. Offering rental schemes, lifetime repair and providing the consumer with more information about the sourcing and true cost of clothing are all measures that can be more widely adopted. Shifting business practice in this way can not only improve a business’s environmental and social impact but also offer market advantage as they respond to the growing consumer demand for responsible, sustainable clothing. (Paragraph 146)





Published: 19 February 2019