The Ecodesign for Sustainable Products Regulation (ESPR) includes textiles and footwear as priority products to be addressed, given their environmental impact and waste volumes. At Right to Repair Europe, we recently created a working group within the coalition to work on these product groups too, to make sure repairability aspects are considered. Together with Runder Tisch Reparatur, ECOS, EEB and other civil society organisations and repair actors, we sent a letter to the European Commission to make sure footwear is given priority alongside apparel in ecodesign. If you are an organisation working on textile or footwear repair and reuse, join us in advocating! All details about membership and how to join can be found here.
The environmental impact of the textile industry is increasingly well-known and documented. The rise of fast fashion caused greenhouse gas emissions and waste volumes to increase in recent years, and urgent action is needed to regulate the products we wear to reduce their impact on the environment and to extend their lifespans. In particular, footwear is responsible for at least a fifth of the GHG emissions and a third of the resource use of the entire textile and footwear industry. Given its material composition, often with materials that are difficult to separate or cannot yet be recycled, the end-of-life management of footwear is often challenging and leads to large amounts of waste. As if that wasn’t enough, footwear is also often discarded a lot sooner than necessary due to fashion trends and a lack of awareness among consumers about repairability and recyclability of their shoes. We know the problem, but what can we do about it?
Textiles and footwear were included in the ESPR as a priority product group to be regulated under ecodesign, following a scoping study by the EU Joint Research Centre (JRC) that indeed identified them – together – as the product group with the highest relevance for its environmental impact. Then, following the usual legislative procedure, the JRC launched a preliminary study, however focusing only on apparel. It is understandable that apparel and footwear were not addressed together given their differences in function and materials, however it is important that footwear is still addressed through a separate preliminary study and is kept as a priority for ecodesign legislation
To avoid delaying the development of ecodesign requirements for footwear, we called the EU Commission to make sure footwear is included as a priority product in the first ESPR working plan, and for a dedicated preliminary study to be conducted as soon as possible, in addition to the one currently ongoing for apparel. Doing so would send a clear signal across the EU, sparking further research on footwear lifespan extension and end-of-life management, as well as innovative solutions in the industry ahead of the adoption of specific ecodesign requirements.
The inclusion of footwear as a priority product group in the first ESPR working plan is also necessary considering the interaction of the ESPR with other pieces of EU legislation, such as the Waste Framework Directive (WFD) laying out ecomodulation criteria for extended producer responsibility (EPR) fees paid by producers. Since the criteria for ecomodulation will be defined on the basis of ecodesign requirements, not covering a product under ecodesign would lead to discrepancies under the WFD for ecomodulation under EPR schemes.
The ESPR is an essential tool to make sure products sold in the EU are designed to last, emit less and generate less waste. Alongside electronic products, textiles and footwear have a major environmental footprint that cannot be ignored and must be reduced, as their inclusion in the ESPR testifies. What is needed now is to include all of them – apparel and footwear – in the ESPR working plan, and develop ambitious ecodesign requirements that improve durability, repairability and recyclability of the clothes and shoes we wear.
Read our full letter to the EU Commission here!