What We Heard Report: Feedback on the consultation addressing plastic waste and pollution from the textile and apparel sector

Introduction

Canadians are demanding that plastic waste and pollution be addressed. Commitments are being made across all sectors. Measures are being introduced to increase the circularity of plastic products, to keep them in the economy and out of the environment.

Textiles made of plastics (synthetic textiles) are a significant source of plastic waste and pollution in Canada. In 2020, textiles represented about 6% of Canada’s plastic waste. Most ends up in landfills and some is incinerated for energy recovery. Textiles also contribute to plastic pollution as they shed small plastic pieces called microfibres during regular wear and tear and through laundry. These microfibres can make their way into the environment. 

To address the situation, Environment and Climate Change Canada (ECCC) prepared a consultation document to solicit feedback on the key elements of a proposed roadmap for addressing plastic waste and pollution from the textile and apparel sector.

The consultation document:

• Outlined the current knowledge of the sector
• Identified the range of actors and their effort to reduce waste and pollution, and
• Explored potential additional actions that could eliminate waste and pollution from, and advance circularity in, the textile and apparel sector

How we consulted

A public comment period on addressing plastic waste and pollution from the textile and apparel sector was recently held. Stakeholders were notified of the published consultation papers via e-mail. Additionally, ECCC hosted a consultation webinar. Consultation activities included:

• Written comment period: ECCC solicited written input by mail or email from all interested parties between July 4 and September 1 2024; and
• Webinar: ECCC hosted a webinar open to all interested parties through Microsoft teams and in-person. This webinar which took place on July 15, 2024 included:
  • a presentation from ECCC officials
  • a question-and-answer session, and
  • a chat box to post questions or comments

Who participated

The Government of Canada extends its gratitude to everyone who contributed their valuable input. Participation was high across each of the consultation opportunities. There was a broad range of industry sectors, non-governmental organizations, governments, and individuals represented. Provincial and territorial governments were also consulted extensively.

The consultation process allowed to gather perspectives from stakeholders across the following categories:

• Industry-upstream: comments were from companies and industry associations dealing with textiles earlier in their life cycle, such as manufacturers or producers
• Industry-downstream: comments were received from entities that manage end-of-life textiles, such as recyclers
• Associations: comments were received from textile and apparel industry associations
• Government entities: comments were received from municipal governments
• Non-government organizations (NGO): comments were received from NGOs involved in the textiles sector, such as charities and social organizations
• Other: written comments were received from the public

Written comments on the consultation papers

The Government received 62 written comments on the plastic waste and pollution from the textile and apparel sector consultation paper. These comments represent the views of stakeholders and partners.

Figure 1: Number of written comments received during the consultation process by type of organization

Webinar

The webinar allowed both virtual and in person participants and was open to anyone who registered. Figure 2 shows the number of participants and a breakdown of stakeholder participation. A total of 95 people attended the webinar.

Figure 2: Webinar Participants by Type of Organization

What we heard

This section presents a summary of numerous comments received during the consultation process, organized into overarching themes. The following statements are not intended to be attributed to specific organizations or individuals.

Addressing Fast Fashion

• Suggestions were made regarding how to address fast fashion, including the potential consideration of amending the duty drawback legislation, or preventing textile and apparel waste from being exported (i.e. under the Basel Convention). For example, the European Union’s Strategy for Sustainable and Circular Textiles aims to address the challenges related to halting the export of textile waste.

Extended Producer Responsibility (EPR)

• Many stakeholders discussed the importance of introducing EPR schemes to help combat textile waste, and how EPR schemes could work in Canada
• Refashion, a Producer Responsibility Organization in France leading their EPR schemes, could be mirrored similarly in Canada
• Stakeholders mentioned that EPR schemes are not without risk, noting the complexities across provincial and territorial jurisdictions
• EPR schemes could also impact the existing reuse and charity market by diverting resources from this market, increasing costs to businesses and consumers and reducing affordability in Canada
• Input from stakeholders suggested that EPR schemes could be complemented with other services such as repair or include educational components
• Some expressed that EPR needs to be supported with regulations and enforcement in order to have significant participation
• Additionally, financial support could be helpful for companies to accurately track logistics for EPR schemes
• Stakeholders cautioned that EPR schemes would need to ensure participation from all stakeholder groups across both upstream and downstream segments of the industry, and establish infrastructure (e.g., recycling) to be successful
• Suggestions were provided on which Canadian entities could, or could not manage EPR schemes (e.g., producers and charities)

Standards

• Input was provided on how durability standards could be implemented. For example, the American Association of Textile Chemists and Colorists (AATCC) TM212-2021, the International Organization for Standardization (ISO) 4484-2:2023, UL verified marks, and Global Reporting Initiatives, and more, were provided for reference
• Stakeholders identified risks related to standards such as: enforcement, harmonization within Canada and internationally, potential to increase prices and stifled innovation
• There were discussions on where the standards should target within the supply chain, with many suggesting standards should target the manufacturing of textiles and apparel
• Many stakeholders provided information on different methods for laboratory testing for durability, such as testing for apparel shrinkage, abrasion, and tear strength
• Stakeholders cautioned ECCC against one-size-fits-all standards, as each item is different and presents unique challenges
• Stakeholders provided ideas on how to improve textile labelling in Canada. Warnings for health, social, and environmental footprints could be integrated into labels, with better enforcement of existing labelling regulations to help reduce misleading labels
• There were recommendations on the amendment of the Canada Textile Labelling Act as a possible action to improve labelling requirements or to enforce standards for durability

Reuse and Repair

• Concerns were expressed that targeting fast fashion may disproportionately affect poorer individuals
• Suggestions were made by stakeholders to support charities and organizations that aid underprivileged people in getting access to clothing to reduce the reliance on fast fashion
• Stakeholders advised that jurisdictions and organizations such as municipalities and textile rental services can play a role in promoting sustainability and reuse in the textile and apparel sector
• Some suggested that reuse and repair needed to be encouraged both through educational programs and through mandates
• Educational programs for repair and reuse activities could help raise awareness of the environmental risks associated with the textile and apparel sector. It could also address overconsumption, and allow consumers to make informed choices
• Other suggestions were to provide tax incentives and financial support for repair activities and develop reuse and repair networks in Canada

Recycling

• Some stakeholders cautioned the use of food-grade recycled polyester in textile and apparel production. They suggested that food-grade recycled polyester, such as from plastic bottles, should remain in the food packaging system for as long as possible
• There was discussion on the importance of investments at all technology readiness levels in the supply chain to help support sector innovation and help bring concepts to commercial solution
• Publicly available disposal units for textile products, i.e., personal protective equipment disposal units in building entryways, were highlighted as valuable tools to prevent textile waste from entering landfills
• Alternatives to mechanical recycling, such as depolymerization, were discussed, however there were concerns of hesitation to adopt these or similar strategies that could prevent or slow scale-up
• Several stakeholders supported traditional textile recycling. However, some raised the potential complication of recycling efforts due to the use of more fibre blends They discussed how mixed fabrics and trims pose issues when attempting to recycle fabrics and stressed the importance of supporting sorting/grading infrastructure and requiring accurate labelling
• It was suggested that new products be designed with requirements to ensure they are recyclable
• Financial incentives could be offered to companies that use recyclable materials and follow recyclability standards. For example, federal procurement of products containing recycled materials could build demand
• Many cautioned against recycling and suggested to focus on more upstream activities, such as increasing durability, reuse and repair, to prevent textile and apparel waste

Microfibres

• Stakeholders called for a mandate requiring microfibre filters on washing machines to reduce the amount of microfibre pollution due to laundering. It was suggested using France’s proposed microfibre ban as an example
• Others indicated that requiring microfibre filters is premature and could cause financial stress on small businesses and households. They suggested that managing the microfibre issue be the responsibility of garment manufacturers or municipal wastewater treatment facilities
• Some stressed that any implementation of microfibre filters should not come at the cost of energy efficiency or water consumption of laundering machines
• Stakeholders noted the importance of redesigning apparel to not produce as many microfibres during its lifespan
• There were discussions on alternative avenues to reduce microfibre pollution instead of a mandate requiring filters on washing machines. For example, educational initiatives could be adopted, or pre-washing of clothing could capture microfibre shedding before being sold
• Stakeholders encouraged harmonization efforts internationally to address microfibre pollution, especially between the US and Canada as they share a common market in this sector. Options could include common mitigation requirements within North American, common definition for microfibres, and common way to detect/measure microfibre releases
• Stakeholders cautioned that standards for microfibre shedding in clothing could be difficult to achieve. There are many variables that influence the amount of microfibres shed from each piece of clothing

Other Suggestions

• Stakeholders stressed the need to clearly define textiles and apparel products, especially the differences between Canadian textiles and imported apparel
• Suggestions were made to control the use of per- and polyfluoroalkyl substances (PFAS) in home textiles, which is used as oil and dirt repellents in textile products. PFAS, excluding fluoropolymers, are proposed to meet 1 or more of the criteria set out in section 64 of the Canadian Environmental Protection Act, 1999 (CEPA)
• ECCC was encouraged to investigate other sectors including the textiles in the equestrian industry, small fashion businesses (e.g., Etsy), sanitary wipes, diapers, soft toys, and more
• Suggestions were made to broaden the scope of the roadmap to include natural fibres. Stakeholders also encouraged the promotion of natural fibres (including furs) over synthetics
• Some stakeholders urged ECCC to use a Zero Waste Hierarchy approach in the roadmap

ECCC will take into consideration all comments received as part of this consultation process to inform the development of a draft roadmap for addressing plastic waste and pollution in the textile and apparel sector.

Contact information

By mail:
Environment and Climate Change Canada
Place Vincent Massey, 9th Floor
351 St. Joseph Boulevard
Gatineau Quebec
K1A 0H3
By Email: plastiques-plastics@ec.gc.ca

Appendix

Consultation questions

Below are the questions and areas of interest identified in the proposed elements of the roadmap section for which ECCC is seeking input.

Support research in the textile and apparel sector

• Do you have data on quantities of textile waste and pollution from any source(s) in the industrial, commercial, and institution sector (e.g., from hospitals, schools, restaurants, hotels, etc.) and/or household waste?

Extend the life of apparel products

• How could Canadian entities develop standards for durability? Where in the supply chain should be the focus to achieve greatest effect on reducing waste and pollution?
• What are the risks to the industry in developing and following standards for durability?
• Are there other actions that could be taken to increase textile and apparel repair activities in Canada?
• How might charities and municipalities play an expanded role in collection and reuse?

Improve waste management through take-back programs

• Could take-back programs and/or EPR systems for textiles work in Canada? If not, what are the limitations or challenges? How can members of the Canadian supply chain (e.g., brand owners, recyclers, repairers, recyclers, etc.) come together to create a take-back system in Canada?
• What kind of collaboration needs to happen, and who could, or would, oversee these programs effectively? What are the needed skills and investments?

Support textile recycling infrastructure

• Do you know of any proposed technology (commercial or pre-commercial; please describe the technology and, if pre-commercial, include technology readiness level) to enable automation of sorting and grading processes, and/or identification and sorting based on fibre type and content? What are the common issues with these technologies that impact their accuracy or speed, and how can these issues be overcome?
• With recycled content mandates coming soon for plastic packaging, including rPET, which is the preferred resin type for most polyester blends, how do you expect this to affect textile manufacturing? Does the sector expect shortage of rPET for the textile and apparel sector? If so, how are you going to secure rPET for your manufacturing process?
• How could demand for recycled fiber be scaled up to make recycling textile and apparel products viable and economical?
• Where do the opportunities and end-markets for recycled textile and apparel fibres in Canada lie?
• How could standards for recyclability be developed, and what are the risks to industry in developing and following these standards?

Addressing microfibre pollution

• How could public awareness about negative environmental impacts of microfibers releases be communicated to the public?
• Should product performance standards be developed for microfibre shedding for textiles and apparel products? If so, what could these standards include? What is the industry’s view on this approach and who should lead this work?
• Should there be labelling programs or standards that indicate the amount of microfibers shed from a piece of clothing during a single wash? Should there be design standards to specify the maximum acceptable amount of microfibres shedding from washing machines using standard temperature and spin cycles?
• Should actions be taken to ensure new washing machines have factory installed filters?