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Written evidence submitted by Planet

Written evidence submitted on behalf of A Plastic Planet – an international campaign group with a single goal: to ignite and inspire the world to turn off the plastic tap. Pro-business, A Plastic Planet works with all stakeholders – industry, retailers, packaging suppliers, the public, NGOs and governments - to accelerate the pace of essential change by educating and connecting them with plastic-free solutions.

1. What progress has been made in reducing the environmental and social impact of the industry since the Fixing Fashion report came out?

Whilst some in the fashion industry are making meaningful moves to lower the environmental impact of the industry, one area that is still overlooked is the amount of plastic used to produce our and its impact on the plastic waste crisis.

Some 60 percent of materials made into clothing contain plastic, including , acrylic and nylon textiles. These have been chosen due to their lightweight, durable, affordable and flexible qualities, however they’re having huge impact on our natural environment.i

Using these materials means textiles are responsible for some 35 percent of primary microplastics entering the ocean through machine washing.ii One machine load alone can shed more than 700,000 microfibres.

It is estimated that there are some 1.4 quadrillion chemically-laced plastic microfibres floating in the world’s oceans.iii The UN Environment Programme estimates around half a million tonnes of plastic microfibres are released into the ocean every year – equivalent to three billion polyester .iv

In recent years the fashion industry has started to take measures to reduce its environmental impact. But much of the focus has been on reducing the industry’s contribution to carbon emissions and wastewater, with little thought given to its impact on .

Recent research from the University of California, Santa Barbara estimates the total amount of microplastics entering the wider environment as we wash our clothes stands at around 5.6 million tonnes since we first started wearing polyester and nylon garments in the 1950s.v By 2050, it’s estimated some 22 million tonnes of microfibres will enter our oceans as a result of the fashion industry.vi These microfibres are consumed by marine life and enter our food chain.

Despite this, only 20 percent of companies have a strategy in place to prevent microfibres shedding from their clothing.

Additionally, plastic microfibres are a contributing source to air pollution as they shed from clothing. Tumble dryers have emerged as a significant source of plastic pollution into the air, something which has been predominantly overlooked.

A study from Central Wyoming College, in Jackson, found tumble dryers spray thousands of plastic clothing fragments over distances of up to nine metres every time they are used.vii Researchers found an average of 12,570 plastic fibres per square metre. Considering around 58 percent of households in the UK are estimated to own a tumble dryerviii, and FFFU0026

these will be used several times a week, we’re seeing huge amounts of nanoplastics being pushed out into the environment.

Academics around the world are becoming increasingly convinced that microplastics in our air can be traced back to clothing.

Kings College London researchers conducted a study on microplastics in the air of London. They analysed the roof of a nine-story building in London’s city centre to see how many microplastics were descending onto it. They were found in all eight samples taken, with deposition rates ranging from 575 to 1,008 pieces per square metre per day, with 15 different being identified. Most microplastics were fibres made of acrylic, most likely from clothing, suggesting millions of microplastic fibres are raining down upon London alone as a result of plastic in clothing.ix

Action to tackle the huge amounts of plastic the fashion industry contributes to the world’s waste crisis has been painfully slow. But there are solutions, and it is essential that the Government implements measures which will not only shift the fashion industry’s attention towards tackling its problem plastic, but also ensure plastic pollution from the fashion industry is stopped at source.

2. What impact has the pandemic had on fashion waste?

The pandemic has exacerbated the volume of plastic pollution, particularly plastic microfibres, entering the environment as a direct result of washing clothes.

A survey carried out by the UK’s sole washing machine maker, Ebac, found the use of washing machines soared during lockdown as people hoped clean clothes would prevent them from contracting Covid-19. The survey found that the average UK household carried out some 36 percent more washes during three months of lockdown than normal.x It was estimated that this released an average of 14 million extra plastic microfibres from clothing per household into the UK’s sewer system and on into the oceans.xi

While the virus has presented us with the opportunity to secure a green recovery, it should also be noted that our habits have changed. With regards to fashion, it’s crucial for major brands and suppliers to place sustainability front-and-centre of the products they manufacture. Plastic microfibres and nano-fibres are preventable with a host of new technologies and materials being invested in and readily available today.

3. How can stimulus after the Coronavirus crisis be used to promote a more industry?

Tackling the fashion industry’s use of plastic must be placed at the forefront of the fashion industry’s sustainability drive. If it is not, a major contributor to the plastic crisis will not be addressed.

Government stimulus must be used to incentivise the use of plastic-free materials in the fashion industry. We should invest in new and improving technologies which will increase scale and efficiency in processing clothing waste – increasing collection and promoting new materials which can be used in clothing and will biodegrade. FFFU0026

A report by the Ellen MacArthur Foundation outlines the opportunity for using public procurement as a means to stimulate market demand for plastic-free and sustainable clothing. In the Netherlands, the A Circular Economy in the Netherlands by 2050 programme set the target of a 50 percent reduction in raw materials use by 2030. The use of recycled fibres for sourcing are listed as a beneficial criterion within the Dutch Government, leveraging the buying power of public procurers to stimulate demand for sustainable clothing.xii

The UK Government has an opportunity to go a step further and scale-up this approach, using stimulus measures to incentivise the production and purchasing of plastic-free clothing.

4. Is the Sustainable Clothing Action Plan adequate to address the environmental impact of the UK fashion industry? How ambitious should its targets be in its next phase?

While we accept the Sustainable Clothing Action Plan (SCAP) addresses some key environmental issues which the fashion industry contributes to, more must be done to address the amount of plastic the industry contributes to the waste crisis.

The key challenges it is currently tackling are a:

Reduction in carbon – achieving 13.4 percent reduction against a 15 percent target Reduction in water – achieving 18.1 percent reduction against a 15 percent target Reduction in waste to landfill – achieving 4 percent reduction against a 15 percent target Reduction in waste across the whole product life cycle – achieving 1.4 percent reduction against a target of 2.5 percent

In its next phase, A Plastic Planet strongly urges the SCAP to address the issue of plastic pollution in fashion. There must be ambitious and specific targets pertaining to decreasing ocean microplastics directly resulting from textiles.

There should also be a greater focus on regulation on all washing and drying machines, both domestic and industrial. A Plastic Planet believes that as the fashion industry moves towards more sustainable clothing, there should be a focus on prevention as well as reduction. As outlined above, millions of nano plastics are being pushed into the environment from our daily wash. We believe regulation to reduce this impact can begin with the introduction of nano fibre filters into both washing and drying machines. These filters, which are available now, but have not yet been adopted by the industry, will prevent plastic microfibres entering the environment as the fashion industry transitions to materials which in their clothing which will not have a long-lasting impact on the planet.

5. What actions could the Government take to improve the collection of fashion waste?

The introduction of a comprehensive extended producer responsibility scheme will improve the collection of fashion waste. The current status-quo sees major organisations within the industry produce materials, which are then bought by the consumer, who is then responsible for their end of life. A Plastic Planet believes this must change.

The industry should be actively designing materials with their beginning and end of life considered. By taking the onus for processing fashion waste away from the consumer, it can be given back to the industry to ensure infrastructure and correct collection procedures are in place for the products they create. FFFU0026

If the fashion industry is to truly achieve sustainability, the design of their products should consider how it will be processed post-use, or whether it can be reused or recycled. With regards to plastic, a fundamental measure should be to dramatically reduce the amount of plastic nano and microfibres in their clothes.

6. What actions could the Government take to incentivise the use of recycled or reused fibres and materials in the UK fashion industry?

When encouraging the use of recycled or reused fibres, the Government’s position should be based on the material being used. Recycling plastic fibres is never going to improve the environmental impact of the fashion industry. Recycling other materials, which can be used time and time again is desirable, however recycled plastic based materials in clothing will continue to release microfibres into our air and oceans when washed. The only answer, with regards to plastic, is to inspire a dramatic reduction the amount of plastic used in clothing in the first place. Anything which does not do this will fail to have the environmental impact needed.

In tackling pollution from textiles, the Government’s priority should be to inspire a shift away from plastic fibres as a go-to material in the production of clothes and other materials. Any measures which fail to place a dramatic reduction in plastic as a key component of clothing will fail to curb the impact of the fashion industry on the world’s environment.

Incentivising major brands and organisations within the industry to adopt alternative materials in production of their garments must be a key policy going forward. This can be achieved through taxation. The Government has an opportunity to incentivise a shift away from plastic use in the fashion industry by introducing a tax on the worst offending materials used including polyester and nylon.

The tax would be designed not to punish organisations, but to inspire them to seek to use materials which will not have a devastating and long-lasting impact on the environment. Funds recouped from taxation can be invested in new and emerging technologies and waste processing to further drive the fashion industry’s move towards sustainability.

7. How could an Extended Producer Responsibility scheme for the textiles be designed to incentivise improvements in the sustainability of garments on sale in the UK?

The Government has already taken action to introduce an extended producer responsibility scheme for packaging in 2023. A Plastic Planet believes the same should be done for the fashion industry.

For too long the onus of dealing with waste has been placed on the consumer who act in good faith to deal with their fashion waste correctly, but as a result we are seeing huge amounts of clothing piled in landfill and more plastic pollution entering the environment. Like plastic packaging, there is an urgent and pressing need for the onus to be placed on major organisations within the industry who continue to produce products which are having a detrimental impact on the environment.

An extended producer responsibility scheme should be designed to encourage a complete mindset shift within the industry to designing clothes and materials with their end of life considered. Producers should be actively considering how they can reuse the materials in FFFU0026

their products, how they can be collected, how they can be processed and ultimately what impact their product will have on nature. Unless this approach is hardwired into the initial design phase throughout the industry, it will fail to achieve a sustainable future.

Any extended producer responsibility scheme must have transparency at its core. The industry must be held accountable for its contribution to the plastic waste crisis, but there will never be accountability until we know the true scale of the crisis, and this means publishing transparent data against an enforced metric system to ensure consistency.

This will also enable the Government to assess where measures can be implemented and will open the door for industry to collaboratively work with stakeholders to address the challenges they face in their drive towards sustainability.

In tackling the plastic pollution resulting from the industry, major brands and organisations have the power, influence, connections and financial clout to make a real impact at an accelerated pace. With plastic pollution representing one of the world’s most prominent environmental challenges its essential that they do.

A Plastic Planet firmly believes that business has the power to drive change. We believe the Government can help inspire industry through measures such as an actionable extended producer responsibility scheme.

November 2020 i https://www.unenvironment.org/news-and-stories/story/fashions-tiny-hidden-secret ii Ibid iii https://www.ellenmacarthurfoundation.org/assets/downloads/A-New-Textiles-Economy.pdf iv Ibid v https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0237839 vi https://www.fashionrevolution.org/our-clothes-shed-microfibres-heres-what-we-can-do/ vii https://inews.co.uk/news/environment/tumble-dryers-major-source-plastic-pollution-682090 viii https://www.statista.com/statistics/289140/tumble-dryers-in-households-in-the-uk/ ix https://www.theguardian.com/environment/2019/dec/27/revealed-microplastic-pollution-is-raining-down- on-city-dwellers x https://inews.co.uk/news/environment/coronavirus-latest-washing-machine-use-soars-lockdown-hygiene- 568467 xi Ibid xii https://www.ellenmacarthurfoundation.org/assets/downloads/A-New-Textiles-Economy.pdf