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Ecommerce Europe and EuroCommerce today jointly published the 2021 European E-commerce Report. In 2020, total European e-commerce grew to €757 billion euros, up 10% from €690 billion euros in 2019.

2020 was an exceptional year, marked by the COVID-19 pandemic and the consequent important role of e-commerce for both society and economy. This is also reflected in the growth figures, which remained significant (10%), but dropped slightly compared to 2019 (14%). COVID-19 gave a significant boost to e-commerce sales, but the sharp decline of online sales in the tourism and services sector (events, tickets, etc.) contributed to holding back overall growth.

The pandemic had a massive impact on developments in the retail sector. The lockdown accelerated the existing trend towards the digital and green transition of stores. Their investments in digital and omnichannel, which were originally planned over several years, were carried out in just a few months. E-commerce was a lifeline for consumers, as government restrictions such as forced shop closures, prevented them from buying what they needed in stores. While e-commerce has not fully compensated the losses that many brick-and-mortar SMEs experienced, it has absorbed a large part of the economic shock. However, further work is needed to ensure the wider retail sector can optimally benefit from the solutions offered by the digital transformation.

Luca Cassetti, Secretary General of Ecommerce Europe, commented: “The past year has exposed the importance of digital transformation. E-commerce has proven to be exceptionally well placed to facilitate the digitalisation of retail and create a seamless shopping experience for consumers. Physical stores opened up new online sales channels, SMEs have been able to access new markets through e-commerce, and merchants have increasingly adopted omnichannel commerce solutions, such as click-and-collect, to accommodate the ever-changing health requirements and consumer needs. However, the transition is not yet completed. Policymakers need to recognise the potential of digital commerce and invest more in new technologies and digital skills while creating a harmonised, channel-neutral and future-proof legislative framework”. 

Christian Verschueren, Director-General of EuroCommerce, commented: “The retail and wholesale sector is going through a significant transformation process. Government restrictions and rising consumer demand accelerated digitalisation. Consumers who were hitherto unfamiliar with buying online or on their mobile devices have become accustomed to it, and are likely to continue to use this and a mixture of channels. Before the pandemic, 70% of retailers and wholesalers had no facilities for online sales, and those physical stores who did have an online presence overcame the challenges better.  But the problem remains, and we are calling on governments and EU policy makers to support the digital transformation of the sector, address unjustified manufacturer restrictions on selling on online platforms, and create a regulatory framework that provides for a channel-neutral and future-proof policy environment”.

Ecommerce Europe and EuroCommerce would like to thank the Centre for Market Insights of the Amsterdam University of Applied Sciences for preparing this report.

To download the light version of the report, please click here.

Marking the first annual EU Organic Day, EuroCommerce Director-General Christian Verschueren said today:

“We have seen consumers increasingly choosing organic foods over the past 20 years and this trend continues, with a double digit annual growth in the sales of organic products. Retailers and wholesalers have been active in promoting organic, both in fresh produce and in their own brands. They have worked to forge close long-term supply relationships with farmers, including helping them to make the transition to organic. They have also helped make this economically attractive by providing a market for increased volumes.

We see this as an important element in building sustainable food systems. We are therefore pleased to see Commissioner Wojciechowski’s initiative in launching the EU Organic Day today as the UN general assembly discusses sustainable food. The EU Organic Day will, we hope, each year help the growth of successful organic production in Europe, and underline the other prerequisite for success in doing so: further building consumer demand for and appreciation of the benefits of, organically produced food.”

EuroCommerce and its members have shown their commitment to sustainable food, being both closely involved in the drafting of the EU Code of Conduct and one of its first signatories when it was launched in July.  We have also shown how our sector has been proactive in adopting best practice in sustainability and promoting healthy lifestyles in our dedicated website #sustainablecommerce.

It is therefore natural that we also support this new Commission initiative, which fits closely with the objectives of the Farm-to-Fork strategy.  A recent EuroCommerce/McKinsey report showed that over half of consumers want to buy more sustainable products, but that many also need to look at the price.  Affordability will be important if organic products are to be available not just to the better off, but to everyone. Helping consumers to understand the benefits of organic production can also help to overcome this barrier.

An important factor in boosting the market for organic is ensuring that the right level of supply.  Consumers will turn to organic if they see more on the shelves; and demand is therefore likely to increase with adequate supply from within the EU or from outside where there is a need. Retailers and wholesalers have already helped by providing scope for increasing volumes for organic and thus the viability of producers. This will allow them to sell at a price which is both attractive to consumers and adequately rewards their efforts. It is important that EU and national policy helps the market develop in this positive way.

All in the supply chain have found the long-term relationships which our companies have built up with farmers and the food industry helpful in driving the move to organic and in meeting growing consumer demand. Uptake of organic is uneven, with most production, processing and sales focused in Western Europe, and still low in Central and Eastern Europe. All these efforts could be reinforced by more activity at national level to promote organic products with producers and consumers, particularly in those countries where uptake is still slow.

The 2021 Report, jointly published by Ecommerce Europe and EuroCommerce, presents the main figures and trends related to the e-commerce sector in Europe, with country-by-country and sectorial analyses, interviews with heads of leading national ecommerce associations and other valuable information for merchants, policymakers and other stakeholders.

The 2021 report shows that Western Europe is the strongest region in terms of B2C e-commerce turnover, holding 64% of the total turnover for 2020. Southern Europe follows in second place with just 16% of total turnover, while Central Europe (8%), Northern and Eastern Europe (both 6%) come in last. The leaders in B2C e-commerce turnover remain the United Kingdom (€236 billion), France (€112 billion), Germany (€93.6 billion), and Spain (€68.4 billion). However, the highest growth rates in e-commerce turnover were found in Greece (77%), Moldova (49%), Russia (41%), Switzerland, North Macedonia (37%), and Sweden (36%).

Other key findings show that internet use in Europe increased to 89% in 2020, up from 87% in 2019 and 85% in 2018, with Western Europe (95%) catching up with Northern Europe (96%). The number of online shoppers increased faster during 2020 than in the last 4 years with 71% of the population having purchased from an e-store (up from 66% in 2019, and 64% in 2018). Western Europe boasts the highest share of e-shoppers (86%), followed by Northern European consumers (82%). The United Kingdom had the highest share of online shoppers (92%), followed by the Netherlands (91%), Denmark and Switzerland (90%), Germany and Norway (87%), and Sweden (86%). The lowest share of online shoppers was found in for instance Moldova (34%), Albania (37%), Ukraine and North Macedonia (40%), Bulgaria (42%), and Russia (43%).

In the latest of the series of EuroCommerce Policy Talks, Agriculture Commissioner Janusz Wojciechowski is speaking today on his vision for the future of European agriculture, and addressing a range of issues related to it.  These include the impact of the COVID crisis on agriculture, sustainable food systems and the EU Farm-to-Fork strategy, food waste and food security, farmers’ income and regulation in the food supply chain, and the global and trade aspects of agriculture.

EuroCommerce Director-General Christian Verschueren said:

“As world leaders gather this week in New York to discuss sustainable food systems, we are very pleased to welcome Commissioner Wojciechowski to our Policy Talk on sustainable agriculture. As a vital link with consumers in the food supply chain, retailers and wholesalers have been very active in supporting the Farm-to-Fork objectives and addressing the accelerating transition to sustainability across the supply chain. They have been working with suppliers both of branded goods and our retailer brands to respond to and encourage consumer demand for sustainable food options and a healthy lifestyle, as well as reducing the environmental impact of their own business. Although retailers buy very little directly from farmers – less than 5% of what they sell – they have a shared interest in a globally competitive agriculture sector which prospers and successfully embraces this transition.  This needs a regulatory regime which supports dialogue and cooperation rather than national protectionism or inappropriate legislation from which neither farmers nor consumers benefit”.

Retailers and wholesalers are fully committed to realising the overall objective of the Farm-to-Fork strategy to create a sustainable food system.  EuroCommerce was one of the first to sign the EU Code of Conduct on Responsible Food Business and Marketing Practices launched in July, and has set out examples of a wide range of initiatives on sustainability and healthy lifestyles on its dedicated website #sustainablecommerce.

The Policy Talk can be accessed online on the dedicated EuroCommerce Policy Talks website or directly on YouTube.

EuroCommerce Director-General Christian Verschueren is speaking at the World Retail Congress conference in London today, and said

“COVID is a global pandemic and its impact is global, particularly for a people-facing sector such as retail.  We have heard from many of our members in Europe that a worrying number of shops will not stay open once current support measures end.  This is in part the result of repeated and unpredictable government lockdowns over the last 18 months, but also a symptom of the acceleration by the pandemic of the fundamental transformation of the sector to digital and online sales.  Retailers small and large, suffering from historically low margins, need urgent government support to make the investment necessary for digitalisation and sustainability. This is an economic and social imperative needing decisive action not only for our sector but all the other parts of the economy and the local communities we serve.”

He is speaking to OECD G20 and G7 sherpa Nicolas Pinaud, and in a panel with Matt Shay, President and CEO of the US National Retail Federation, and Helen Dickinson, CEO of the British Retail Consortium, on issues surrounding the measures needed to maintain the signs of positive recovery in recent months, in part due to government support.

The panel with Christian Verschueren, Matt Shay and Helen Dickinson is part of the regular WRC Industry Leaders’ Forum exchanges, bringing together the heads of some of the world’s most important retail trade associations in order to hear how they see the current challenges and the action they are taking to support their members. They will discuss the impact of COVID on the sector, what governments can learn from it, and the government support needed to avoid a crisis in a sector dependent on, but also a driver of consumer confidence and growth.

The European Parliament agriculture and environment committees are today finalising their joint report on the Farm to Fork strategy.  EuroCommerce Director-General Christian Verschueren commented:

“Our sector has for many years driven sustainable practices, working with suppliers, for example on organic production and other quality standards, and creating a market for farmers and expanding choice for consumers. I am therefore happy to restate today our readiness to contribute to sustainable food systems under the Commission’s Farm to Fork strategy. The Covid crisis has shown that retail and wholesale is an essential sector, ensuring efficient distribution of daily essentials to consumers. We also work hard to do so in a sustainable way and in promoting healthy lifestyles. A wide range of actions already initiated by retailers and wholesalers can be seen from our website #sustainablecommerce.”

In a consumer survey as part of the joint McKinsey/EuroCommerce report on the State of Grocery Retail released earlier this year, 50% of consumers said that they planned to buy more healthy, local or environmentally-friendly foods this year, but 26% wanted both to save money on groceries and move towards sustainable lifestyles. This is a clear message to retail and wholesale to work with farmers and the whole supply chain to continue to increase the supply of sustainably-produced, affordable food. 

Before the summer, EuroCommerce and many of its members signed up to the Farm to Fork Code of Conduct, confirming our commitment to work on responsible food business and marketing practices.  The joint report voted on today reflects the advantages and opportunities presented by a sustainable food system but also some of the challenges which still need to be addressed by all supply chain actors, NGO’s and regulators. These include action on consumer information, enhancing organic production, reducing pesticides, supporting primary producers in the transition to name but a few. The report rightly highlights the many interlinkages with other policies at EU and international level and the need for full coherence between them.

Our sector has responded rapidly to consumer needs, and we are ready to share our experience through constructive dialogue with all players in the supply chain, and use the collaborative platform to be established under the Code of Conduct to share good practice in support of a sustainable food system.

We are looking forward to working with members of the European Parliament when they come to consider upcoming proposals on important related legislative files such as the framework for sustainable food and food information to consumers.

Background

Retailers and wholesalers take of their role in addressing key societal challenges seriously, including how to address potential risks in their supply chains. Sustainable initiatives are the result of a lengthy process involving internal actors and engaging partners in the supply chain and as a minimum relying on appropriate enforcement of national legislation. Success is embedded in cooperation, and it is built on long-term and trustworthy relationships based on but not limited to strict criteria defined according to International guidance and standards.

The sector has long been committed to be part of the solution and has been involved in setting measurable and transparent actions such as

• Respect for Human Rights through own voluntary due diligence measures, corporate Human Rights policies and grievance mechanisms.
• Respect for Human Rights among suppliers by voluntary initiatives and responsible business agreements.
• Developing and participating in company schemes focused on improvements in their commodity or regions or both
• Cooperation among multinationals  to tackle human rights and environmental challenges.

General Considerations

Support reference to the International guidance and existing schemes

The sector has long been committed to measure and improve the impact of its activities in this supply chain. To do so, we rely on both International and regional guidance and on private certification and verification schemes.

Consistency with current work led by EU institutions

The European Commission is currently working on assessing and preventing impacts of business activities on stakeholders and the environment, including a proposal for corporate sustainable governance and due diligence, expected to be released in October 2021.

While directors should be incentivised to integrate sustainability into their consideration, some proposals in the platform draft’s report such as defining the remuneration of board members seems out of scope and may be falling under the same criticism as the one expressed by the Board of Scrutiny. We do not believe that it is up to EU legislation to define the board directors’ criteria for remuneration as it may create unrealistic demands directors.  

Social taxonomy goes beyond EU competences or national legislation

As mentioned in the draft report, the definition and scope of the social taxonomy should be clearly framed and scoped.

Social objectives are inherent in company practices and more homogeneous across sectors compared to environmental impacts, which depend largely on the type of economic activities. Moreover, social investments are usually a mix of public and private financing. It would be much more complex, if not impossible, to quantify the contribution of a company on social aspects, as the impact of, e.g. collective bargaining, investment in skills etc. is more difficult to measure. For example, government investments in the unemployed may yield very different results. Likewise, employers’ skills investments may lead to iverse levels of productivity improvements depending on the engagement and motivation of workers. Different from an environmental taxonomy, social taxonomy cannot rely on evidence in the same way. Decisive criteria in an environmental taxonomy are usually developed on the basis of scientifically validated research results. A social taxonomy might be driven by political undertones.

National law and practice have made collective bargaining the norm in retail and wholesale, with collective agreements providing appropriate levels of protection for employees. Some 88% of staff in our sector are on permanent contracts and are ensured good levels of social protection. Women account for 62% of the workforce in retail and the sector gives millions of young people their first step-up into employment. As a sector, we  are  committed  to  giving  all  involved  in  retail  and  wholesale  as  good  working  conditions  as possible.  Experience has  shown  that  autonomous  collective  bargaining,  particularly  through  constructive engagement with our social partners at the level closest to the workplace, works better in agreeing positive change rather than top-down legislation. As social partners, we therefore strongly disagree with new political induced criteria for remuneration. Also companies already now have to comply with many social requirements through legislation. Companies also understand well and take action to mitigate any negative impacts of their activities on society, including on the communities in which they operate and on human rights. That is why many companies have already integrated different global social standards or social aspects of sustainability frameworks into their business strategies. Lastly, governance aspects, including those related to tax, corporate governance etc., are not social aspects as such. We therefore do not see the added value in a sustainability linked remuneration.

The best way of meeting the current challenges is through stronger  EU  investment  in  promoting  autonomous  and  voluntary  social  dialogue  throughout Europe. This was why, together with our social partner UNI Europa and other leading players in the service sector, we  recently  called  upon  the  Commission  for  capacity-building  in  this  area  and  not  pursue  further proposed cuts to EU sectoral social dialogue

However, as per due diligence activities in the supply chain, we recognise the need to align with International guidance such as the UN Guiding Principles to clarify expectations on human rights.

Administrative requirement on reporting

Furthermore, we would like to remind the Platform that our sector is composed by 99% of Small and Medium Enterprises. Some of retail or wholesale companies may not have the adequate resources to undertake such an exercise.

Extraterritoriality

On specific points

Scope

It would be necessary to clarify the depth and scope of social impact considered and it should be aligned with Due Diligence scope of liability defined. Principle 17 of UN Guiding Principles recognizes that where business enterprises have large numbers of entities in their value chains it may be unreasonably difficult to conduct due diligence for adverse human rights impacts across them all. Moreover, UN Guiding principles settles a clear distinction to be made between cause, contribute and direct linkage.

Stakeholder –centered approach

Although the consideration of stakeholders is essential, there is varying degree of relevance depending on the type of decision to make, on the sector, the size, the location(s), overall business environment etc. of individual companies. It is each company’s responsibility to define these parameters, including which stakeholders are relevant to different part of the business operations to secure meaningful engagement.

Vertical dimension

Measuring social impacts

While the sector supports the development of the EU taxonomy on environmental activities, we are aware of the challenges that reporting of such activities implies for our sector.

Firstly, generally speaking, we would insist on highlighting the specificity within this sector and the complexity of our supply chains. Our companies are part of a global, highly complex value creation and economic system. They are subject to intense international competition.

Secondly, with respect to social activities, we believe that there is for the moment little science-based criteria to measure and report on substantial contributions or do no significant harm. For environmental activities, measurement mechanisms such as CO2 emissions can be used, which is not the case for social activities.

We recognise the reference to International declarations, agreements and guidance such as the International declaration on human rights, this provides little certainty on the methodology to measures the impact in the supply chain for our sector. A common reporting framework and guidance seems more appropriate, rather than multiple reporting schemes across various regulations. A streamlined approach would support companies by relieving their expert resources to focus on the social and environmental work needed on the ground rather than on increased administration.

We note that a social taxonomy would not regulate social affairs, but rather determine criteria to provide access to investment. Despite this, some members still have concerns that it would not be possible to define activities as either socially positive or negative, as it depends on the context, which in the area of social affairs, is predominantly about the national level, including the industrial relations system. For example, it would not make sense to evaluate whether a company, under German labour/social law is performing better from a social point of view than a company operating under Danish or Spanish labour/social law, as the contexts are different. Furthermore, compared to environmental or climate issues, it is far more difficult to establish KPIs on social matters. We fear that in this area, KPIs would not be based on evidence but rather on politics. Depending on the approach, we are concerned that the extension of the Taxonomy Regulation could target investment only to certain companies, potentially creating obstacles for some companies that make a positive social contribution to access important investment.

Tax transparency

Retailers and wholesalers are, notwithstanding the burdens involved, committed to providing detailed, country-based information to tax authorities all over Europe, as already required under the DAC 4 provisions. This applies both to companies operating in a single Member State and operating throughout the EU. However, we find that the proposal for systematic reporting present some shortcomings.

Definition of harmful activities

For many years now, retail and wholesale companies have been expanding their cooperation with industry-specific standards on a voluntary basis, also in order to take various social aspects into account more closely in the supply chains. The sector relies on numerous International guidance and national legislation such as the- UN Guiding Principles on Business and Human Rights (UNGPs), OECD Guidelines for Multinational Enterprises (OECD MNE Guidelines), as well as the fundamental rights set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the ILO Tripartite Declaration of Principle concerning Multinational Enterprises and Social Policy (ILO MNE Declaration, the Sustainable Development Goals; and consider the existing specific regulations applicable in some EU countries (France, the Netherlands, etc.).

The sector works with its suppliers and stakeholders and identifies the risk and impacts that their activities can have on communities and their environment.

The UNGP are already targeting human rights at the level of an economic entity. The UNGPs provide a good basis to assess and ensure a process regarding respect for human rights in supply chains. A thorough assessment is critical to evaluate if new criteria would add any value on the ground.

We are pleased to share the 'Value of European Retail’, a graphic factbook aimed at giving an overall impression of, and a solid fact base for the many-faceted activities of European retail.

We hope that the factbook will help you in gaining a clearer picture of the value retailers contribute to the European economy, the diversity of their businesses, and the benefits they bring to Europe’s citizens.

The graphic factbook is based on a comprehensive slide deck, also named 'the Value of European Retail’ (comprising 150 slides). The slide deck is available here.

We hope that you will find this booklet both interesting and useful.

Commenting today on the creation of the new Epic Partners retail alliance, EuroCommerce Director-General Christian Verschueren said:

“This new development demonstrates the important role retail alliances play in supporting competition and providing better prices and more choice to consumers. The efficiencies and synergies in sourcing in the EU single market can help balance the significant market power of multinational brand suppliers who operate across the globe. As we have seen recently, these large manufacturers are again piling on pressure, sometimes even collectively, for unreasonable price increases. Alliances are consumers’ best allies at a time when many families are still feeling the impact of the COVID pandemic. These alliances help address the impact of manufacturers’ active fragmentation of the single market, which is costing consumers at least €14 billion a year.”

The new alliance will negotiate contractual arrangements for complementary international services and marketing activities with the largest international brand manufacturers, with a focus on packaged processed products. Vegetables, fruits and unprocessed foods are not part of these activities, and the alliance will have no dealings with SME suppliers or farmers. The Commission has on numerous occasions recognised the pro-competitive role that retail alliances play within the strict boundaries set in competition rules, including a recent report by the European’s Joint Research Centre which underlined their positive role in increasing consumer welfare.

A few facts to provide context behind retail alliances:

• Europe’s retailers and wholesalers operate in a limited number of countries, with high fixed costs and low and decreasing net margins, typically around 1-3%. The global manufacturers seeking to undermine the role of alliances, on the other hand, still enjoy net margins of 15-30% - ten times those of retailers - and their margins continue to increase.

• Individually, retailers’ purchases from a global brand supplier make up no more than a tiny fraction of that large brand’s global sales (normally well below 5%).

• In many product categories, an individual manufacturer holds a significant position on the relevant market, and this should be the criterion for judging relative bargaining power.

• The imbalance in negotiating power is directly reflected in large manufacturers’ repeated and unreasonable demands to retailers for often double-digit price increases, and the suspension of deliveries if these demands are not met, along with restrictions on the free movement of goods. The Commission is currently conducting investigations of abuse of market power and breach of other competition rules by a number of manufacturers in relation to retailers and distribution.

• The new Epic Partners alliance brings together Edeka (Germany), ICA (Sweden), Jeronimo Martins (Portugal), Magnit (Russia), Migros (Switzerland) and Picnic (Netherlands). The partners involved are represented with their stores in a total of 10 European countries.

In the new Circular Economy Action Plan the Commission announced that a dedicated EU strategy for textiles is planned for 2021. We welcome that the Commission is working on a comprehensive strategy dedicated to all textiles and EuroCommerce would like to express that our sector wants to be part of the future dialogue towards a systematic and positive change in the textile ecosystem. We encourage the EU Commission to continue the closest collaboration with retailers and wholesalers in the further materialization of the EU Strategy for Textiles as clarified in the roadmap.  

As described in the Commission’s Annual Single Market Report 2021 from May 2021, that accompanied the update to the 2020 EU Industrial Strategy, the Retail Ecosystem and the Textile Ecosystem are two separate, but linked industrial ecosystems, because textile retail is one of the biggest subcategories of retailers and the shutdown of retail outlets also impacted the textile producers. Therefore, the Commission needs to differ between retailers and wholesalers and producers within the EU Textile Strategy, because not all retailers and wholesalers have a direct influence of how the products they sell are produced. This distinction is often missing in the questionnaire and should be taken into account in the final strategy.   

In light of the Covid-19 pandemic and the current socio-economic context this initiative is needed more than ever. With the closure of non-essential retail, the very low in footfall in town centres, and the dramatic loss of consumer confidence, the COVID-19 pandemic is having a severe economic impact on the whole textile and fashion supply chain.


We have estimated the loss of turnover for European non-food retailers in 2020 to amount to €300 billion. An appropriate recovery plan is therefore essential to ensure the survival and transformation of the whole textile and fashion supply chain. In this regard, the EU Textile Strategy will be central to ensuring that the recovery will lead to more sustainable textiles. Our sector is committed to contributing to this goal, with its all its environmental, circular and social dimensions.

• This statement aims supplement and expand on the response from the retail and wholesale sector regarding the public consultation about the EU strategy for textiles.
• We aim to highlights critical success factors that must be taken into account to make the EU Textile Strategy impactful, sustaining and efficient:

• Scaling-up innovative technologies and processes and further knowledge valorisation will be key to ensuring the transition towards a circular production and consumption system for textiles, especially financing of and investing in high-value recycling technologies is needed. Retailers and wholesalers need to be involved and financially supported in their efforts to support this.
• There is an urgent need for increased investment and upscaling of industrial waste sorting and recycling capacities, as this is essential to developing a well-functioning market for secondary raw material that provides safe and secure recycled content at competitive prices. The supply side of post-consumer material needs to be strengthened.

On question 1.2. “Which of the tools listed below should be given priority at EU level to recover from the crisis and promote resilience and sustainability of the textile industry?”

For the second choice “Propose regulation and policy frameworks (e.g. for emerging technologies and processes)” we choose to answer 3 to express that we think that a framework is needed, but that the Commission should also leave room for innovation. Therefore, a policy framework that helps to achieve the objectives of the EU Textiles Strategy should focus on upscaling and supporting the wider adoption of existing and to be developed technologies (e.g. for sorting or recycling). It should not be based on a regulation, because such an approach would be too prescriptive and detailed and could hamper this development. Furthermore, because this option is not very detailed, we are not sure what kind of regulation the Commission would foresee under this option, which is another reason for us to answer with 3. However, we would also want to highlight the importance of consistency among the different existing and planned pieces of legislation to avoid contradicting measures. It is very important to have a coherent and coordinated policy framework, not only among member states but also with other EU policy initiatives that will contribute to the circular economy, such as the Sustainable Product Initiative, the initiative about substantiating green claims and the initiative about empowering consumers in the green transition.

For the third choice “Set binding requirements at EU level to foster product sustainability” we answered 3 to express that the Commission should only set minimum requirements at EU level to foster product sustainability but should also give businesses the opportunity to go further if they choose so.  

For the fourth choice “Require Member States to implement mandatory Extended Producer Responsibility for textiles (and footwear)” we would like to comment that this is already planned in several Member States. Therefore, in our view it would be very important that the Commission provides guidelines, harmonisation and facilitates the exchange of best practices to avoid fragmentation. As with all waste streams the aim should be to create and support a well-functioning Single Market for Waste to ensure the availability of safe and secure secondary raw materials at competitive prices. Similar to the Waste Framework Directive a dedicated Textile Waste Framework Directive could be used to ensure common rules and criteria about secondary raw materials, reutilization and end-of-waste status.  

In addition, we have several additional options not listed under 1.2. that should be also considered. Because the textbox in the questionnaire does not allow for answers with more than 200 characters, we would like to list our additional options hereafter: 

• Industrial scale waste collection and sorting capacities
• Secondary raw material market with recycled material available at scale and competitive price
• Targets and commitments concerning product features based on impact of these features  
• Upscale textile to textile recycling  
• Common guidelines and assessment methods based on scientific methodology
• Incentives for recycled content  
• Harmonized EPR requirements (reporting, eco-modulation)  
• Tools to ensure traceability and common reporting framework on end of life/textile waste
• Financial support during the transition for companies of all sizes

On question 1.3.    “In your opinion which of the following technologies will contribute most to support a competitive and sustainable textile sector in the EU?”

Regarding the option “Customisation, production on-demand and virtualisation (e.g. digital twins, bodyscanners, 3D-printers)” we would like to comment while there are useful applications for customisation and similar technologies, we think that the limitations of this technologies will reduce their role in supporting a competitive and sustainable textile sector. The Commission should keep the use of any technology voluntary and not prescribe the use of these technologies, because this would damage SMEs and will hinder innovation. Furthermore, we have doubts that this can be practices at scale and are concerned that this could lead to problems for the second-hand market, because very individualised products would not appeal to everyone and might not be sold, and for recycling, because unusual material used on the request of individual consumers can hamper sorting and recycling processes.  

On question 2.1.1. “Which elements of circularity in the value chain do you consider should be tackled as a priority?”

For the third choice “Promoting slow fashion (e.g. slowing down the rate of clothing consumption)” we choose to answer 2 to express the speed level is not what determines if a product or a business model is sustainable or not. What should be promoted are the right business models, those able to adapt to consumer preferences at all times, including changing fashion trends, thus avoiding unnecessary production and consumption of raw materials. Slow fashion should not be an objective itself, as it does not necessarily imply a lower environmental impact - demonstrated by the high levels of markdown activity due to leftovers resulting from models with slow and long lead times. We agree with efforts to make business models more efficient, aiming to minimize virgin materials consumption at the beginning of the cycle and waste generation at its end, thus decoupling business performance and its impacts. Therefore, we answered 2 to also express that the Commission should focus on supporting this transformation towards a sustainable textile eco-system.  

Regarding the choice 6 “Ensuring transparent, traceable, verified consumer and business information (e.g. on material and chemical content, environmental and social aspects)” we would like to comment that coordination with related policy-initiatives like the Sustainable Products Initiative, the Digital Product Passport, the EU due diligence legislation and international initiatives like the policy recommendation of the UNECE traceability project is absolute necessary to ensure coherence and avoid diverging requirements.  

In the context of choice 7 “Ensuring that no textile products are landfilled/incinerated without ever having been used (e.g. unsold clothes)” we would like to comment that we support the goal to stop landfilling/incineration of textiles, because these practices lead to the loss of material that, depending on the waste and recycling infrastructure could be used as a secondary raw material. As stated above we would like to highlight again that industrial scale waste collection and sorting capacities as well as recycling technologies and capabilities are needed – once these are in place it will be easier to ensure that no textile products are landfilled/incinerated.  

On question 2.2.1.”Which element of raw material selection do you consider should be prioritised in order to promote sustainability?”

On choice 1 “Promoting the utilisation of sustainably sourced/produced fibre types in the EU and globally (e.g. through certification)” we would like to comment that we answered 5 “high preference” to express that the Commission should utilise existing certification to support sustainably sourced/produced fibre types in the EU and globally. We are not in favour of creating new certification to support this goal. Furthermore, we would like to highlight that certification is not the only instrument to promote and improve sustainability. Many companies, especially SMEs, are improving and changing their internal processes to increase the sustainability of their own operations and cannot or don’t want to rely on using third party certification schemes due to high costs or because the certification doesn’t fit or only fits parts of their own operations. However, the Commission should support SMEs economically if they want to use certification to increase their knowledge and open new business opportunities.  

On question 2.4.1.“In order to facilitate the transition to a more circular economy, how would you assess the relative importance of the following product features?”

For the first option “Technical durability and information on the expected lifetime” we choose to answer no opinion because for us it is not clear what the Commission means with this option. For us the options mixes two different issues – information about technical durability and information on the expected lifetime, which not necessarily belong together. In our experience it is not always feasible to exactly state an expected lifetime, because the lifetime of non-technical textiles depends on the individual usage of the textile product (washing, use, maintenance, etc.) which can differ from one consumer to another. Therefore, we decided here to choose “no opinion”.  

For the third option “Reparability: Availability of information on product repair” and the fourth option “Reparability: Product design facilitating maintenance and repair activities and availability of spare parts” we also choose to answer with no opinion to reflect that, while we think that repairability is an important part of the transition to a more circular economy, we would need further information about the possible measures the Commission foresees under these two options. In our view establishing, maintaining and supporting a repair eco-system that also allows for third-party repair is needed, but also measures improving consumer culture and behaviour regarding reparability. If consumers are not using repair services even the best repair service network will not lead to more repair and reuse of textiles. Therefore, we would oppose measures that would forcing companies to offer repair services if they do not want to specialise in these activities. The end of use of textiles and the potential for repair are closely linked to consumer maintenance and daily care of these products. Features like composition, temperature of laundry, types of ironing etc. are directly linked to possible damages to the garments, which in turn influence reparability. Better consumer awareness will be key to ensuring that textiles can find a second life and companies can play a part by providing information and guidance to consumers about proper maintenance, care and ways of prolonging the use of the products.  

Regarding the choice 10 “Increased content of recycled fabrics or fibres” we would like to comment that the Commission needs to take technical feasibility and availability of recycled fabrics or fibres into account. If there is lack of secondary raw materials on the market due to missing industrial scale waste treatment capabilities and recycling technologies, companies will struggle to improve this product feature.  

On option and 11 “Increased content of natural and sustainably grown fibres” we would like to highlight that the Commission needs to analyse the impact of switching towards more natural fibres before taking any measures.

On question 2.4.2. “How can the environmental impact from microplastics shed from clothing/textiles best be tackled without causing environmental problems in other areas?”

Regarding choice 1 “Reducing the use of synthetic fibres in textile products in favour of natural fibres” we would like to state again that the Commission needs to analyse the impact of switching towards more natural fibres before taking any measures.  

On question 2.5.1.“How would you assess the relative importance of the following measures to promote sustainable consumption behaviour at EU level?”

In the context of option 3 “Provide stronger protection of buyers against false and misleading information in environmental claims (greenwashing)” we would like to comment that this is very important and that our sector supports efforts to fight greenwashing. To be effective these efforts need to be based on clear definitions and standards and accompanied by guidance/guidelines like the guidance on the application of the Unfair Commercial Practices Directive as well as proper market surveillance and enforcement actions.  

For the last option “Encourage economic incentives to buy sustainable/circular textiles (e.g. through differentiated taxation levels depending on products’ resource efficiency)” we decided to answer “important” to express that we fully support economic incentives to promote sustainable consumption behaviour. However, we have concerns regarding using different taxation levels because this could lead to additional red tape while not achieving a real behaviour change if such measures are not well-designed.  

On question 2.5.2. Which of the following business models contributing to a circular economy do you believe have most potential for economic viability and upscaling?

On choice 1 “Selling quality durable products with high personal value (e.g. partially designed by or tailored for the consumer)” we would like to comment that there are potential problems for the second-hand market if products are too much customised. For example, several companies stopped offering “company branded products” like vest with the company name and/or logo because these customised products could very fast become obsolete if the buyer changes jobs.  

Regarding option 3 “Second-hand retail (of others’ products)” it is unclear for us what this part of the question refers to. We believe that second-hand can play an important role and these shops are selling products originally sold by other companies to consumers. However, in the context of the option before about “Take-back and resell of own brand products” one could interpret option 3 as asking about the potential for economic viability and upscaling of a business model where businesses would engage in the second-hand retail of competitors products. While some companies might decide to deploy such a business model, we believe most would prefer to focus on second-hand sales of their own-brand products, as they know them and their features. Therefore, we would like to state that our answer regarding this option should be understood as support for the traditional second-hand business. However, we would like to highlight that there should be no requirement to engage in second-hand, this should be a voluntary business decision.  

On question 2.6.2 How would you assess the relative importance of the following challenges to recycling of post-consumer waste textiles into new textiles in the EU?  

Regarding choice 2 “Lack of targets for reuse and recycling to be implemented at national level” we choose to answer with not very important because the Waste Framework Directive already requires that Member States set up separate collection for textiles by 1 January 2025 and to set effective and realistic targets, we need to have background data and, currently, there is no data about reuse and recycling rates available. Furthermore, to achieve the possible targets, first barriers for reuse and recycling, like the lack of both industrial capabilities and recycling technologies for textiles, need to be addressed.

On choice 3 “Lack of traceability of chemical content in textile waste” we would like to comment that the lack of reliable recycling technologies for reprocessing efficiently textile products and effectively recover legacy chemicals may hamper the recycling capabilities needed to reach the circular economy for textiles. Therefore, we call on the Commission to increase investing in and supporting of the development of new recycling technologies and sector-specific standards.   

On question 3.1. Which of the following aspects are in your opinion more effective to promote sustainability (including fair wage, decent working conditions and labour and human rights) across the value chain?

Regarding option 7 “Developing specific guidance on textiles to supplement the EU horizontal due diligence rules in the upcoming sustainable corporate governance initiative covering environmental protection, human and labour rights” we would like to ask the Commission to build upon and base the EU guidance on the existing sector-specific guide from the OECD ("OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector"). Complementary guidance or guidelines on how to implement the new due diligence rules within the companies would be welcome to ensure proper compliance with the regulations.