Final Statement for the ICAC
To complete and complement the ICAC’s republication of my recent work on the Great Greenwashing Machine, I was asked to reflect on what progress (if any) has been made; where we go from here; and who needs to be involved on that journey.
The ICAC neither funded nor in any way influenced these reflections.
Who?
It is certainly not for me to dictate anything. Indeed, one of the major problems with ‘sustainable’ fashion is an excess of self-proclaimed experts, and an absence of expertise. Sustainability is science - economic, political, and physical science. It is also justice. If fashion is to have any hope of ‘sustainability’, of adhering to global agreements on carbon emissions, biodiversity, and inequality, the industry must stop consulting itself and a handful of generalist Life Cycle Assessment (LCA) and Management Consultancy (MC) providers, and start consulting both those most severely impacted by its activities - the global south - and those with the greatest specialist expertise - from universities, research institutes, Government agencies etc. to multilateral organizations, including the ICAC.
Progress since 2019?
So much for who needs to be involved. As to progress - has there been any since I first started working on sustainability claims in fashion, back in 2019? I would submit that there has been some progress, and we will get to that, but obviously, not nearly enough. As those who have read my companion publication in this issue: “Amplifying Misinformation: The Case of Sustainability Indices in Fashion” will be well aware, the problem is that the prevailing system falls decidedly short in assessing true sustainability, both in terms of what the system is measuring, and in how the system measures it.
I wrote the following words in November 2019. They still apply, not just to organic cotton but to BCI, CMiA, Reel, or any other cotton scheme - large or small. Indeed, these words don’t just apply to cotton. Exactly the same principle applies to all farmed fiber schemes involving smallholder farmers, whether these are indigenous Quechua producing alpaca, or Brazilian smallholders producing silk. And, the principle applies not just when the scheme is organic, but also when it’s ‘Responsible’, ‘Regenerative’ or any other type:
“Most of the world’s cotton farmers are not plantation owners, they are small-holders farming less than two hectares. Many have little or no education and are desperately poor. Even small changes in revenue can leave these farmers unable to fund schooling/health care for their children, or incapable of servicing their debt. Before engaging market forces to push such farmers into organic production - by persuading consumers and brands that organic is the only sustainable cotton to buy - we need to be certain that this is unequivocally best for the farmers themselves.”
No more Poverty/No more Hunger
Fashion - from workers wages to the sourcing of raw materials - is uniquely well placed to contribute to Sustainable Development Goals (SDGs) 1 and 2. But ‘No more poverty’, ‘No more hunger' are not the priority of any major sustainability scheme or metric. From Textile Exchange’s ‘Preferred Fibers’ and the Higg - now Worldly - MSI (Material Sustainability Index), to Kering’s Environmental Profit & Loss (EP&L), ‘sustainability’ still equates almost solely to environmental impact. Indeed, astonishingly, even in UN publications themselves, the focus is almost entirely on environmental impacts and how these can be portrayed to enable brands to sell products. ‘No more poverty’ appears to be almost an afterthought, and, despite recurring reports of hunger and malnutrition from apparel workers, to alpaca farmers, ‘no more hunger’ doesn’t seem to be mentioned. This obviously needs to change.
Water and Land
Moreover, from the EU Product Environmental Footprint (PEF), and Kering’s EP&L, to the Higg - now Wordly - MSI, all major indices are calculated by weighting water (and in the case of the first two, land). What this means is that a subjective judgment has been made that water and land use are particularly important environmental variables. Further, the actual water consumption is not the final value used in the impact calculations. Rather a multiplier is applied to that actual consumption, that is intended to measure ‘scarcity’. And further again, as we can see, in the companion article in this issue, “Amplifying Misinformation: The Case of Sustainability Indices in Fashion”, the assessed impact or water footprint will depend on the methodology and scarcity factor used. A study of milk farms in Australia, found that whilst actual farm consumption varied from 9.1 to 313 liters of water per liter of milk, the average water scarcity footprint for those same farms, using 3 different calculation methods, varied from 18 to 6,616 liters of water per liter of milk! The highest footprint score came from AWARE the most commonly applied water-weighting system (AWARE is used by both the Worldly MSI, and the EU Product Environmental Footprint or PEF).
This massive inflation is to the considerable detriment of the global poor whose cotton, silk, and other agricultural products are demonized as a result. The validity of these - in large part, subjective - weightings aside, it is not clear that the EU or the USA have any moral authority whatsoever, to rule on what constitutes an appropriate use of water or land in Mali, Pakistan or Laos. There is moreover, no impact justification for interfering in the sovereign use of such resources. Whether Cambodia choses to irrigate silk, India to irrigate cotton, or Peru to devote land to alpaca, has absolutely no impact on the land and water resources available to citizens of the EU or the USA.
GreenHouse Gas Emissions
Obversely, GHG emissions do affect everyone - whether these are generated in Brazil, Belgium, Benin, or Bhutan. But prevailing indices from the Worldly Higg MSI to the EU or French PEF make absolutely no attempt to weight carbon emissions.
It is self-evident that for the SDGs to be achieved, the carbon emissions of the world’s poorest must increase. Oxfam has estimated that per capita emissions of 2.3 tonnes of CO2 equivalents (CO2e) linked to consumption, would still be consistent with the goal of holding global temperature rise by 2030 to 1.5⁰C. However, the emissions of the poorest in the global south are well below that. Our World in Data estimates that 2020 per capita consumption emissions were roughly 18 tonnes of CO2e in Saudi Arabia, 15 tonnes in the USA, and 14 tonnes in Australia. They averaged 13 tonnes in Luxemburg, somewhere around 9 tonnes per capita in Germany and Austria, and around 7 tonnes per capita in the UK and China. In Brazil and India, they were only 2 tonnes CO2e per capita, and they were less than one tonne per capita in Benin and Burkina Faso, respectively.
Around 45% of the global population live in rural areas of developing countries, and they depend primarily on small, family farms for their income and sustenance. It is self-evident that the only way these people will ever have the income to increase their consumption in line with global justice, is by selling more produce. To treat those production emissions as if they were exactly the same as those of Saudi Aramco or BP is neither ethical nor scientific. It clearly runs counter to globally agreed sustainability targets. This too, must change.
Organic Claims
What has changed for the better since I wrote that November 2019 article pointing out that the organic LCA found no savings of either water or GHG emissions attributable to the organic cultivation system? Well firstly, that claim has been very much on the decline. In the light of the 2022 rulings by the Norwegian and Dutch consumer authorities, most of the major brands - Patagonia, H&M, Zalando…. with a few exceptions like New Look - have removed those organic cotton claims from their websites. But as of August 2023, the Higg, now Worldly, MSI continues to claim that substituting organic for conventional cotton reduces climate impacts per kilo of fabric by 14% (8.87 to 7.66 Higgies/kilo) and water consumption by 88% (55.3 to 6.9 Higgies/kilo). And whilst most brands are no longer using this to dupe consumers, they are presumably still using it to set and measure their progress on their Science Based Targets (SBTis).
As a quick aside here, that a single private initiative - The Science Based Targets Initiative -should have gained so much power and influence, is causing concern in some places, and increased scrutiny in others. Certainly the entire procedure seems extraordinarily undemocratic. Neither SBTi nor any of its founder members - CDP, the United Nations Global Compact, World Resources Institute (WRI) and the World Wide Fund for Nature (WWF) - were elected by anyone. And in measuring the carbon emissions of the world’s poorest and most disadvantaged, SBTi, treats them as if they were exactly the same as the emissions of Shell or Unilever - in clear violation of global agreements. The fact that Laudes Foundation - the personal charity of the Brenninkmeijer family, wholly funded by their Cofra Holding Company and therefore partially funded by North American fracking, is listed as a one of the SBTi’s most important funders, is hardly reassuring. And the fact that the United Nations Global Compact seems to have felt no need to include anyone from the global south in any of this is particularly disturbing.
It is surely a wonderful thing that companies should calculate their environmental and social impacts and take steps to improve both. But just like Financial Accounting, the role of private sector bodies should, as it is for accounting firms, be restricted to measurement. The setting of the rules by which these measurements are to be made must be determined and controlled, not by the richest banks and corporations, but by elected representatives of the global community. And this, after full and frank discussion between North and South. Change is definitely still required there.
But I digress, to return to organic cotton, some brands have simply swapped out the old claim for a new one: that organic cotton still consumes less water than conventional, because a greater proportion is rainfed. This claim is no more substantiated than the previous one.
Matching the Textile Exchange (TE) 2022 Organic Cotton Market Report to ICAC data, indicates that 90% of global organic cotton production is irrigated to some extent, and global average water consumption for organic cotton was somewhere around 2,500 L/kg Lint in 2022, compared to 2,068 L/kg Lint for conventional cotton cultivation (Terry Townsend, email of May 11, 2023).
Brands cannot be allowed to continue to persuade consumers to buy more, based on organic fairytales. If US consumption emissions have to drop 13 tonnes per capita, for Another Tomorrow or anyone else to suggest to American consumers that there is something environmentally sustainable about purchasing yet another tee - simply because it is made of organic cotton - is more than deceptive.
Environmental Metrics Alone are Not Fit for Purpose
There is absolutely no justification for anyone in the global north to believe that any purchase that they might make, is sustainable based purely on environmental metrics. The only grounds for labeling a product ‘sustainable’ and so encouraging consumer purchases, are socio-economic - specifically, ending poverty and hunger in the global south. Neither Another Tomorrow, nor New Look, nor anyone else, has any robust data showing that farmers become better off after switching to organic cultivation.
Quite the contrary. Study after study has shown that organic farmers lose money after switching to organic, and so attrition rates are high. Indeed, it is precisely the problem that brands demand large volumes of organic cotton, without being willing to pay any significant price premium to cover the increased risk, harder work, and lower yields involved, that appears to have led to widespread fraud. Terry Townsend, former Executive Director of the ICAC has published a number of articles, highlighting this recently. As Townsend points out, TE is proclaiming headline global organic production increases, when they know that 72% of that volume comes with a data reliability of 1. The lowest possible. If brands know this but then still tell consumers: "Buy our clothes. They're better. They're organic cotton". It would not be unreasonable to argue that this is little better than chicanery. Surely there should be at least some acknowledgement that it is more than likely that the cotton may not be organic at all?
None of this is acknowledged by the sector, and brands and their funded initiatives continue to market organic cotton as ‘more sustainable’ and to press the poorest, most vulnerable, and ill-informed, into producing organic cotton, without first ensuring that adequate and reliable compensation is in place. Perhaps the most egregious example of this is the construction of a brand new gin - specifically and uniquely for organic cotton - in one of the world’s poorest and most disadvantaged nations: Burkina Faso. To cite the World Factbook, targeted by terrorist groups since 2016, “by early 2023, insecurity in Burkina Faso had displaced more than 2 million people and led to significant jumps in humanitarian needs and food insecurity. In addition to terrorism, the country faces a myriad of problems including high population growth, recurring drought, pervasive and perennial food insecurity, and limited natural resources. It is one of the world’s poorest countries.”
The cotton gin appears to have cost the people of Burkina Faso US $12 million, which they presumably have to repay - plus interest. Why the USDA decided that all the people of Burkina Faso were missing was a gin to promote organic cotton production, when we are talking about some of the poorest people on the planet, and only 0.2% of US cotton production (5,821 tonnes/3,181,000 tonnes) is organic, is beyond me. If organic production is not good enough for the vast majority of US cotton farmers, where is the evidence to demonstrate that it is better for Burkinabe farmers?
As it is, as Textile Exchange themselves point out, Burkina Faso produced only 647 tonnes of organic cotton fiber in 2020/2021 - on a total cotton output of 196,000 tonnes. This is expected to drop in 2021/22:
“Two years after its inauguration, SECOBIO–the new ginnery for organic cotton in Koudougou–is far from reaching capacity, which stands at 17,500 tonnes of seed cotton per year. Burkina Faso continues to face serious security challenges. Many cotton farming families belong to internally displaced people and could not find land in refugee camps to continue their farming activities. Aside from these challenges, the season was very good in terms of rainfall. However, it’s forecasted that production will experience a slight decline in 2021/22.”
Even if the gin was a gift from the good people of the United States, in such a hard pressed nation, surely a better use for $12 million could have been found?
To conclude, for the past ten years or more, ‘sustainable’ fashion has been focused solely and entirely, not on what would enable the poorest in the supply chain to thrive, but on what would enable brands to sell more: “Make environmental claims with confidence….Increase revenue by up to 25%” is the all-pervasive refrain. This must change. Brands should not be allowed to suggest to consumers in the global north that there is anything remotely environmentally sustainable about their purchasing another dress, jacket, or shirt - because, per se, there isn’t.
How?
So much for what needs to change. How do we do it? Brands are not going to voluntarily lose money in the name of the greater good. Indeed, if they are publicly quoted, they presumably have a fiduciary duty not to. It is pointless to write papers and give presentations exhorting fashion to: “eradicate messages of overconsumption.… portray alternative models of status and success…. decoupling identity from newness and recalibrating what is deemed aspirational so as to social proof a sustainable future.” There is only one thing brands and their senior management want to future-proof, and that is their growth and profits.
If we want fashion brands’ growth and profits to also be sustainable - and they could be - we must alter the economic incentives until they are. The rest is just talk. Indeed, arguably, the interminable publication of aspirational reports with no concrete counterpart, merely serves to mask and perpetuate business as usual.
Let’s consult the global south.
Let’s seek out genuine expertise.
Let’s start crafting meaningful legislation that is based on economics - not wishful thinking.
Let’s count nature in, and let each and everyone of us pay the real cost of whatever we might use.