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Greenwashing: as EC prepares key proposals, MTLC issues warning and plea

Mar 21, 2023

As the European Commission prepares to announce key proposals for legislation to tackle greenwashing this week, advocacy groups have a clear wishlist of what they want to see.

Photo: Pixabay/Public domain

And the The Make The Label Count (MTLC) coalition has said it’s important the EC gets it right as it's treading a fine line between making a real difference and creating extra problems.

The MTLC is an international coalition of organisations working to ensure that sustainability claims for textiles in the EU are fair and credible.

It’s also worth noting that while this is all about EU-specific legislation, it will also affect countries trading with the EU but not part of it — including the recently departed UK.


On March 22, the Commission is due to publish its proposal on substantiating environmental claims — a hot topic at present. And based on reports of the proposal, it looks like it may be flexible to opening up this substantiation to go beyond the current Product Environmental Footprint (PEF) methodology.

MTLC spokesperson Dalena White — who’s also Secretary General of the International Wool Textile Organisation (IWTO) — told Fashionnetwork.com that the legislation means “companies will be required to substantiate claims they make about the environmental footprint of their products/services by using standard methods for quantifying them. This is an extremely important piece of legislation that will be crucial in fighting greenwashing, but we must get it right first time”.

The group had assumed (based on initial comms from the EC) that the Product Environmental Footprint (PEF) will be the primary tool used. But other recent reports also suggest the Commission may be open to other methodologies.

And that’s where the MTLC isn’t happy.

Though the PEF methodology is far from perfect, we believe it can be improved and is the most robust methodology currently available to us,” White explained. 

She recognises that it needs to be updated and added: “The European Commission first started working on the PEF nearly a decade ago, and since then, we’ve had major advancements in research and knowledge around the environmental impacts of the textile industry. But these are not reflected in the methodology today. The PEF must be brought in line with the latest science.”

And if other methodologies start being added into the mix, “this could lead to more harm than good, creating fragmentation and consumer confusion. Likewise, if PEF is disregarded with no alternative suggested, we will continue without a defined methodology which means vague claims and shaky data”.

So we’re at a key point in the road where a misstep could set back the attempt to combat greenwashing.

And it’s clearly an important issue. In the UK, for instance, the Competition and Markets Authority has been investigating some big players over their green claims, while consumers have become ever more conscious of the issue. And the same is true in EU and countries not in the EU but in the single market.

White added: “2022 was a year of increased scrutiny of the environmental claims made by fashion brands. We saw this signalled by consumer authorities in both the Netherlands and Norway when they issued joint guidance on the use of the Higg Material Sustainability Index (MSI) tool to communicate product sustainability, stating that environmental claims based on [its] methodology need to be revised to mitigate the risk of misleading consumers.

In a sweep of clothing and textile webpages, the Commission found that more than 50% of green claims are unsubstantiated or simply untrue. It’s an industry flooded with greenwashing and self-governed definitions of sustainability.

Retail has been writing the rule book for retail and it is clearly not working. As consumers, we need scientifically-based green claims, guaranteed to create a better and more sustainable world for future generations.”


As mentioned, the MTLC sees the PEF as they key tool to help improve the situation but is pushing for gaps in it to be filled.

White told us: “If the PEF is recommended in its current form, the Commission risks licensing greenwashing and creating an unlevel playing field for different fibres.”

So what will it take to make it work? The group believes other key indicators “must be included”, including microplastic release and plastic waste. 

That’s particularly important for clothing, which is one of the biggest contributors to microplastic pollution. The Ellen MacArthur Foundation has said that each year, plastic microfibres equivalent to more than 50 billion plastic bottles resulting from the washing of textiles are estimated to be released into the ocean. 

And that’s not currently measured in PEF. “It should be reflected in the overall PEF score as a main indicator and given sufficient weighting against the other 16 impact indicators to have meaningful impact”, White believes. “Too much is known about the scale of microplastic pollution and its environmental harm to prevent this information from influencing consumer purchasing choices.”

The group is pushing a clearly defined plastic waste indicator, given the big contribution of synthetic clothing to fast fashion and plastic waste. Almost 70% of all clothing on the planet is made from plastic, and more and more ends its life in landfill. 

White continued: “Currently only minimal weight is given to plastic waste. This will not serve to influence consumer choices and will allow for the growth of the fast fashion business model that relies so heavily on fossil fuel-derived materials.

The inclusion of a circularity indicator is essential to delivering the EU’s circular economy goals. Renewable and biodegradable raw materials are inherently circular compared to those made from fossil fuels, which are finite and will never biodegrade. Including circularity as an indicator in PEF is the best means of equitably assessing the sustainability of raw materials originating from renewable and non-renewable sources. To achieve the EU’s circular economy goals, we must see the inclusion of a circularity indicator prioritised and given sufficient weighting.”

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