On 5 January 2021 the European Commission (“Commission“) published the roadmap for the upcoming consultation on the EU’s “strategy for sustainable textiles”.

The textile sector was previously identified as a priority sector in the European Green Deal, the Circular Economy Action Plan and the Industrial Strategy where the EU seeks to develop a carbon neutral, circular economy (see our previous article Strictly Sustainable Products Only for further analysis) and, in light of the COVID-19 pandemic, there is an increased need for sustainable recovery and growth on both the supply and demand side of the textile sector.

The textile sector

The textile and clothing industry employs 1.5 million people across the EU, most of which are part of small and medium sized businesses that operate in long, globalised and diverse value chains. However, the European textile industry faces an uneven playing field due to lower costs, environmental standards and working conditions in developing countries. It is increasingly challenging to prove that textiles are produced under acceptable environmental and working conditions.

Although there is a growing awareness of sustainability within the industry, Europeans still consume on average 26 kg of textiles each year. Of this, around 11 kg of textiles are discarded per person each year, in part due to the continuing “fast fashion” phenomenon, and less than 1% of all textiles worldwide are currently recycled into new textiles.

In order to address this, the Commission suggests that a coordinated and harmonised EU-level response is required to tackle structural weaknesses regarding textile waste collection, sorting and recycling in the Member States, and to strengthen capacity both of the industry and public authorities.

What does the Commission aim to achieve?

The Commission wants to set up a comprehensive framework in order to create conditions and incentives to boost the competitiveness, sustainability and resilience of the EU textiles sector. The new framework should support sustainable investments in production processes, design, new materials, etc. and offer support to new technologies that can help tackle the release of micro plastics and help contribute to the digital and green transition.

The Commission has suggested:

  • setting targets for reuse and recycling efforts and green public procurement in the EU;
  • proposing actions to make the textile ecosystem fit for a circular economy;
  • improving the sustainability of production processes;
  • supporting more sustainable lifestyles (including voluntary approaches like the EU Ecolabel);
  • extended producer responsibility (“EPR“) for promoting sustainable textiles and treatment of textile waste (and the implementation of a legal obligation to collect waste textiles in 2025) (see our publication on EPR for textiles here); and
  • reinforcing the protection of human rights, environmental duty of care and due diligence across value chains, including improving traceability and transparency.

The Consultation

The initial feedback period ended on 2 February 2021 for comments on the roadmap and the full consultation is expected to commence within this first quarter of 2021. Whilst the content of the consultation is not yet clear, we expect to see some of the ideas suggested in the roadmap to be included, depending on the feedback received.

Key Takeaways

Companies in the textile industry should consider potential adjustments required in their supply chains with regard to waste, recycling, and transportation methods, and should familiarize themselves with the new European Green Deal, the Circular Economy Action Plan and the Industrial Strategy. Companies would be well advised to implement more robust onboarding and monitoring processes in their supply chains to ensure third party activities are in line with anticipated standards, and to assess risk given likely additional corporate responsibility for failure to meet future sustainability standards.


Graham is a partner in Baker McKenzie's London office specialising in product regulation and environmental, health and safety law. Graham advises on the regulation of pharmaceuticals, medical devices, chemicals, food, and a wide range of consumer and industrial products, acting for clients in connection with global integrations and reorganisations; product manufacturing, marketing, supply and distribution; EU and UK product authorisation regimes; non-conformities, regulatory investigations and prosecutions. His practice also covers operational environmental, health and safety matters for industrial and manufacturing facilities; the assessment and management of environmental risk in complex multi-jurisdictional projects, mergers and acquisitions; and climate change law and emissions trading.


Jessica's practice focuses on international trade, encompassing: sanctions and export controls; customs; anti-bribery and corruption; and tax evasion. She joined Baker McKenzie from another global law firm in 2015. She studied and worked in both London and Paris, and has knowledge of both the English common law and French civil law systems. Jessica is the lead associate covering Brexit-related developments, analysing how they will affect the UK's trading position generally and clients' businesses specifically. She has helped clients to conduct assessments of how Brexit will impact their businesses and assisted in developing tailored Brexit.


Johanna is an Associate in Baker McKenzie's London office.