Shooting sparrows with cannonballs.
Reflections from the Action Season 5 - “ESPR collective feedback: Should we?” spring 2026
UCRF’s Action Season during the early spring of 2026 decided to address the feedback for Ecodesign for Sustainable Products’ Regulation (ESPR), as UCRF’s Policy and Social Change Group has for many years followed EU regulation related to the Textile Strategy.
On March 12th, five of us convened online to discuss how to approach the open feedback opportunity, which required reading of the 600-page long 3rd Milestone, answering a 110-page questionnaire and ideally also attending a two-day online seminar arranged by the EU’s Joint Research Center. Tone was the only one of us to have gone through all three, having also revisited the comments in the seminar chat. She and Professor Ingun Grimstad Klepp from Consumption Research Norway at Oslo Metropolitan University also went through the questionnaire together and attempted to answer all the sections. Tone gave a concise summary of the process and the results in the meeting. What follows should therefore be read as a reflection emerging from this Action Season discussion process.
The main point is that the current strategies and regulative suggestions come across as both too broad and too narrow, as all the Design Options (DO) as they are called, are meant to cover all products, with no differentiation (one exception which we will come back to).
These are as follows (very simply put):
· measuring ‘robustness’
· setting standards for recyclability,
· evaluating thresholds for recycled content
· and measuring environmental or carbon footprint.
Repairability has not disappeared entirely from the DOs, but is no longer one of the main modelled DOs; in the current architecture it is narrowed mainly to information on available repair services. The former ‘durability’ parameter has been replaced by ‘robustness’. The 3rd Milestone proposes several measurable aspects:
· two that are to be actually measured, namely spirality (twisting) and dimensional change (shrinkage)
· and four that are to be visually evaluated, including color changes and surface changes (such as pilling) after five washing or equivalent 'cleaning cycles'.
For the first two, there are different values for knitted and woven materials (this is the difference earlier alluded to), regardless of the type of garment.
The JRC also explicitly states that the proposed robustness framework is not capable of providing an estimate of service lifetime and only describes resistance to selected external stresses rather than product ageing more broadly.
This brings us to the underlying assumptions that have informed the reasoning for EU’s continued search for durability or robustness measures - the assumption that more durable products would lead to keeping them for longer and thus buying less. The available evidence does not justify assuming that robustness scores can predict real service life or reduced purchasing. Just as importantly, the JRC’s own user-behaviour analysis shows that disposal is driven not only by intrinsic durability, but also by perceived value and fit. Acquisition is therefore not simply a matter of replacement needs.
What research to date shows is that haphazard care practices and accidents also make products unusable – when one looks at the category for technical failures. Pilling is one of the largest reasons for saying something is ‘used up’ or worn, even though much pilling can be remedied.
See: Sigaard, Anna Schytte; Laitala, Kirsi (2025). Repairability of clothing and textiles: Consumer practices and policy implications. International Journal of Sustainable Fashion & Textiles. Vol. 4. https://doi.org/10.1386/sft_00064_1
So, as a Norwegian saying goes, the measures are shooting sparrows with cannonballs.
Another major aspect of these limited, yet broad measures, are the unintended consequences. ESPR aims to build on the assumed success of the energy labelling regulation, where household appliances and electronic devices were given an energy-efficiency score from A to E (or G-ish), with the aim to save consumers money and to phase out energy-inefficient products. The unintended consequence for laundry machines was that the clothes were not clean enough, people ended up using the too short cycles, which then forced the detergent producers to make their products harsher in order to work.
Similarly, we see several potential unintended consequences based on ESPR’s 3rd Milestone. One is how the demand for testing, documentation and verification will affect SMEs and micro-sized businesses, especially where runs are small and style turnover is high. The issue here is not that testing is inherently wrong; many good brands already use extensive pre-market testing, chemistry control and traceability systems. The problem is that policy can overclaim what such auditable intrinsic tests can prove about real-world service extension. The questionnaire itself shows that key assumptions on documentation, verification and per-unit administrative costs remain open for consultation. Another risk is plastification, if thresholds on dimensional changes, appearance retention or similar parameters unintentionally reward more plastic-intensive constructions.
More broadly, no single metric can stand in for real textile sustainability. Product-level tests can tell us something about physical integrity, chemistry and recoverability readiness. Market-flow data can tell us something about throughput, virgin-material dependence and unsold stock. System outcomes such as repair, reuse and active life are more difficult to interpret because they are shaped not only by firms, but also by consumers, culture, infrastructure, price and informal practices. Good policy therefore needs a layered framework rather than a single proxy.
To simplify and better target what represents unwanted products entering the market, we suggest better alignment with logic already implicit in the document’s recyclability scale. If some of these product features were restricted or heavily taxed, the effect could be both quicker and more targeted. This could, for example, include prestressed denim (chemically or physically), large prints on merch that make products more or less non-recyclable, unnecessary elastane in products such as denim, sequins and other easy-to-lose plastics, apparel treated with PFAS, and apparel with electronics and batteries. The case for targeting such features is not only that they are problematic for recycling, but that they can obstruct safe repair, direct reuse, design for disassembly and genuine textile-to-textile recovery.
With regards to another two decisions made by JRC for the 3rd Milestone:
1. that the fiber-formation stage (LCS1/raw materials) is excluded from DO4, since DO4 is limited to environmental and carbon-footprint indicators for the manufacturing stage (LCS2) rather than the full lifecycle comparison.
and
2. that fragmented fiber release is currently out of scope as a design option because of unresolved measurement, definition, and standardization challenges across the value chain; we have some further comments and suggestions.
For further context, recent findings on microfibers, as summarised in an IWTO position paper discussing a 2024 Nature Communications study that estimates that the global apparel sector generated about 21 Mt of plastic waste in 2019 and that about 8.3 Mt (midpoint) of plastic leaked from the global apparel value chain into the environment that year. The study estimates this is about 14% of total global plastic leakage (about 60 Mt/year) - roughly twice the annual global production of all natural fibers. Critically, the largest driver of apparel plastic leakage is mismanaged synthetic end-of-life clothing in primary and secondary markets (including second-hand export destinations): about 6.6 Mt/year, representing 88% of plastic leakage from the synthetic apparel value chain. By mass (not by particle count), microfiber releases during synthetic fiber production and apparel washing represent less than 1.5% (about 0.11 Mt/year) of total plastic leakage from the global apparel industry. https://iwto.org/wp-content/uploads/2026/03/IWTO_Position_Paper_Microplastics_JRC_3rd_Milestone_03112026.pdf
For SMEs and micro-sized businesses this needs to be navigable. At the same time, replacing one oversimplification with another would not help. For the fiber-formation stage (LCS1), a more progressive and manageable approach would be to complement classic LCA parameters with a broader decision logic such as:
Is the fiber fossil-fuel based or dependent on virgin fossil feedstock?
Is it persistent, or realistically biodegradable under relevant environmental conditions?
Does it contribute to increased virgin-material demand and long-term volume growth?
Is robust traceability back to source available?
Is it compatible with safe recirculation and textile-to-textile recovery?
This is similar to the earlier question of which products or features could justifiably be treated as products-non-grata on the European market. The point is not that classic LCA-parameters should simply be abandoned at the fiber stage, but that they should be complemented by criteria that better address fossil dependence, persistence, traceability and compatibility with safe recirculation. That would move a future PEF for apparel and footwear closer to something that is decision-useful rather than merely technically comparable.
Recently a Norwegian project, led by the Trimco Group and Green Score Capital, compared products using the PEF 3.0 database where the fiber formation stage was included. The results show that a fleece polyester jacket scored 1476 points and a Merino sweater scored 18264 points. For the fleece jacket, the raw material is estimated to constitute 17.52% of the PEF score, and 24.23% of GHG emissions, while transformation, manufacturing and finishing constituted about 79% of the PEF score, and 70% of GHG emissions. For the wool sweater, raw material formation constituted 91.511% of the PEF score, and 84.52% of the GHG emissions, while transformation, manufacturing and finishing constituted about 7% of the PEF score and 13% of the GHG emissions. The problem is that if this was transformed into a consumer-facing comparison, it can create false certainty when function, expected use, replacement rate and end-of-life pathways are not being handled clearly enough. If this is allowed to be consumer-facing as it stands, the confusion will be enormous.
All in all, we commend the JRC analysis of the historic backdrop for why we are in the current conundrum with massive over-production and aggressive marketing encouraging consumers to buy stuff they have absolutely no need for. The phasing out of the Multi Fiber Arrangement and the rise of cheap synthetics is correctly described as the core of the problem. But the policy tools proposed in this milestone still rely heavily on highly abstract product level measures that do not sufficiently address the core target of less.
Instead, the current design risks producing more process intensity, more material reinforcement, more chemical intervention and more administrative burden, without adequately addressing overproduction and underuse.
Through recent conversations with Indigenous and marginalized groups, with small-scale artisan businesses, and also within our small discussion group, we see a very real risk of the disappearance of heritage, craftsmanship, resilience and self-sufficiency. This risk arises not only from cost, but from a policy architecture built around industrial comparability, certification capacity and standardised testing burden that are much easier for large-scale actors to absorb. These are unintended consequences that can be very difficult to reverse once local capacity has broken down.
Additional documentation:
MALDINI, I., KLEPP, I. G. & LAITALA, K. 2025. The environmental impact of product lifetime extension: a literature review and research agenda. Sustainable Production and Consumption, 56, 561-578.
SANDIN, G., LIDFELDT, M. & NELLSTRÖM, M. 2023. Does large-scale textile recycling in Europe reduce climate impact? A consequential life cycle assessment. IVL Swedish Environmental Research Institute.
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