When negotiators convene at the fifth International Conference on Chemicals Management (ICCM5) in Bonn, Germany, in September 2023 to decide on a new global framework for the sustainable management of chemicals and waste, they will consider draft targets, and one of the proposals for implementation of the new framework seeks to encourage select “chemical intensive economic sectors and value chains” to scale-up global action that produces concrete results. One specific draft target calls for the development of sustainable chemical and waste management strategies in chemical intensive sectors and industries across value chains. The negotiations seek to develop a new global framework to replace the Strategic Approach to International Chemicals Management (SAICM) created by ICCM1 in 2006.

At a January 2023 workshop convened in Paris, France, by the proponent of the implementation proposal, the Inter-Organization Programme for the Sound Management of Chemicals (IOMC), textiles was discussed as a candidate sector for implementation. The IOMC plans a further stakeholder consultation from 20-21 June 2023 to flesh out ideas for guidance to support strategies and a possible global programme on advancing chemicals and waste management in economic industry sectors and their value chains.

At a negotiating session held in Bucharest, Romania, in August 2022, the textiles sector was an active participant in the talks: the Zero Discharge of Hazardous Chemicals (ZDHC) – a multi-stakeholder organization comprising over 150 contributors, including leading brands such as Adidas, Nike, and Levi Straus – made statements about the sector’s desire to actively engage in the future framework, and offered proposals for framework elements such as sectoral targets and indicators.

The UN Environment Programme (UNEP) has identified textiles – which encompasses not only apparel and footwear, but also some home furnishings (e.g., carpets, curtains, and upholstery) and “technical textiles” (e.g., medical textiles, geotextiles, seat covers, and protective clothing) – as a high-priority industry sector in shifting to a circular economy. Its importance to economies, natural resource management, gender equality, and sustainable development has been reflected in UNEP’s Medium-Term Strategy, resulting in the development of UNEP’s Textile Flagship Initiative. The Initiative aims to align UNEP’s work across three priorities needed to deliver system change towards sustainability and circularity – shifting consumption patterns, improving practices, and investing in infrastructure. These priorities are reflected in UNEP’s forthcoming report titled, ‘Sustainability and Circularity in the Textile Value Chain: A Global Roadmap.’ One of the impact areas of the project aims to reduce pollution in the environment and its impacts on human health by managing chemicals of concern across the textiles value chain.

This Policy Brief discusses SAICM’s longstanding interest in the textiles sector, the IOMC’s proposal, and how an implementation programme under the successor framework might engage with the industry.

SAICM and its interest in the textiles sector

SAICM grew out of a goal endorsed by the 2002 World Summit on Sustainable Development (WSSD) for the world to use and produce chemicals by 2020 in ways that minimize significant adverse effects on human health and the environment. The WSSD also called for developing “a strategic approach to international chemicals management” by 2005. This led to SAICM’s launch at ICCM1 in 2006 as a flexible, voluntary, non-binding, multi-stakeholder, and multi-sectoral initiative dedicated to promoting collaboration aimed at achieving the 2020 goal.

As originally conceived, SAICM was due to expire when ICCM5 convened in 2020. However, by the time ICCM4 convened in September 2015, it became clear that the 2020 goal would not be achieved in most countries. ICCM4 decided to launch an intersessional process aimed at designing a post-2020 framework or platform for the sound management of both chemicals and waste for consideration by ICCM5 in 2020. Due to delays in negotiations caused by the COVID-19 pandemic, ICCM5 was postponed until September 2023.

SAICM’s interest in the textiles sector as a significant user of chemicals came early, primarily through its Chemicals in Products (CiP) initiative. CiP was designated as an Emerging Policy Issue in 2009, and a CiP Programme was created by ICCM3 in 2012, led by UNEP, with a focus on four priority sectors, one of which was textiles. In the run up to ICCM3, UNEP produced a CiP case study on chemicals in textiles.

SAICM has also produced relevant knowledge products, such as the report and a policy brief on addressing per- and polyfluoroalkyl substances (PFAS) as a chemical class in the textile industry. The report and brief suggest how SAICM might advance the concept of approaching PFAS as a class of chemicals for control purposes, rather than chemical-by-chemical as the Stockholm Convention on Persistent Organic Pollutants (POPs) does, and phase out non-essential uses, the textile sector serving as a test case.

IOMC’s proposal for sectoral implementation programmes under a new global framework

The IOMC is an international coordinating group bringing together nine Participating Organizations to promote sound chemical management worldwide through coordination of policies and activities. Participating Organizations include UNEP, the Food and Agriculture Organization of the UN (FAO), the International Labour Organization (ILO), the UN Development Programme (UNDP), the UN Industrial Development Organization (UNIDO), the UN Institute for Training and Research (UNITAR), the World Health Organization (WHO), the World Bank, and the Organisation for Economic Co-operation and Development (OECD).

In a discussion paper presenting its proposals for an implementation programme under the new global framework, the IOMC suggests encouraging further action “based on industry initiatives that have been initiated voluntarily, resulted from regulatory requirements, or responded to pressure from public interest groups.” It also suggests choosing industry sectors and product value chains whose retailers have already undertaken “frontrunner” initiatives demonstrating commitment and willingness to engage, with a view to strengthening, linking, and expanding such initiatives.

The textiles industry qualifies on all counts. Major brands and retailers form the backbone of ZDHC. They have already developed several chemical restriction lists, management guidance, and standards, and backed certification and labeling schemes. Major brands, retailers, trade associations, and others in the sector have also engaged in the Ellen MacArthur Foundation’s Make Textiles Circular initiative, the Fashion Pact, the Policy Hub, and the Fashion Industry Charter for Climate Action.

In addition, the Global Environment Facility (GEF) can be recruited for realizing this implementation programme, as it is already committed to such work under GEF-8 programming directions. The GEF’s new Elimination of Hazardous Chemicals from Supply Chains Integrated Program commits the Facility to work on the textiles supply chain. A recently launched UNEP-implemented GEF project will work with four Asian nations – Bangladesh, Indonesia, Pakistan, and Viet Nam – representing 15% of global clothing exports to address chemicals of concern in their textiles industries.

The IOMC paper suggests engaging a candidate economic industry to develop, through dialogue, a sector vision and roadmap concerning important sustainability parameters, such as minimizing the use of hazardous substances, or advancing circularity objectives, which cover at least four areas:

• advancing the science on chemicals of concern;
• advancing green and sustainable chemistry technology innovation;
• strengthening regulations and policies; and
• mobilizing finance.

The textile sector already has a head start on this front, since it has been engaged with UNEP in dialogue to develop the aforementioned global roadmap for sustainability and circularity for the sector.

The paper further suggests that each sector and industry initiative outline specific measures or steps to take, such as:

• developing a list of hazardous substances causing concern in raw materials and supplies and production processes, such as a manufacturing restricted substances list (MRSL);
• developing standards that specify acceptable levels of chemical residues in finished products, either through a restricted substances list (RSL) or maximum residue levels;
• developing and implementing risk reduction measures to minimize occupational and public exposure, as well as emissions to air, land, and water, when hazardous substances cannot be phased out;
• identifying and implementing sustainable practices and alternatives, including through green and sustainable chemistry innovation, such as changes in processes, recipes, or product design, based on robust criteria and guidance on what constitutes safer alternatives; and
• developing sector-specific indicators to measure progress.

Here, too, the textile sector has a head start on these tasks. Oeko-Tex, the American Apparel & Footwear Association (AAFA), Apparel & Footwear International RSL Management Working Group (AFIRM), and Bluesign have developed RSLs, and most major brands have developed their own RSLs aligned with one or several of these four. Oeko-Tex and ZDHC have developed MRSLs, and individual companies, if they have an MRSL, tend to align theirs with ZDHC’s. There are also several relevant certification and labeling schemes (see Figure 1), and textile-sector goals and targets have been developed to provide indicators for measuring progress (see Figure 2).

Figure 1: Relevant restricted lists, certification schemes and labels regarding chemicals in textiles

Figure 2: Existing goals/targets regarding chemicals/circularity in textiles

Focusing on chemicals of concern in textile production under a future framework implementation programme

The textile sector may have a head start, but much work on chemicals management in the sector remains that could be taken up by an implementation programme under the new global chemicals and waste framework.

For example, while ZDHC’s MRSL is well regarded, its adherents currently account for only a limited percentage of the industry and the list notably is not taken up by the many small and medium-sized enterprises (SMEs) that comprise much of the textile value chain.

As for RSLs, while many companies have adopted their own, these vary, as do the competing attempts at developing harmonized RSLs (Okeo-Tex, AFIRM, AAFA). Furthermore, existing RSLs tend to reflect only the chemical restrictions currently in place by major regulators – primarily the European Union (EU) – and the principal international convention restricting hazardous substances, the Stockholm Convention on POPs. In addition, these restrictions cover only dozens of the thousands of chemicals used in textile production, usually do not address all categories of concern (prioritizing carcinogens, mutagens, and teratogens, but not always toxins to aquatic life, endocrine disruptors, allergens, or irritants), and involve substances selected on a slow substance-by-substance basis that requires years to arrive at final regulatory decisions.

Figure 3: A timeline of existing initiatives on chemicals of concern in textiles

What would it take to address all potential chemicals of concern in the textile value chain?

Among the fibers used in textile production globally in 2021, cotton has the largest share among natural fibers (22% of all fibers), and polyester the largest among synthetic fibers (54% of all fibers). Other inputs include man-made cellulosic fibers, nylon, acrylic, leather, wool, polyurethane, bamboo, and silk.

In the case of natural fibers, chemical use starts during farming. Cotton is a significant consumer of chemical pesticides and fertilizers. In 2019, cotton accounted for 4.71%, by value, of all the chemical pesticides sold globally, and 10.24%, by value of all insecticides used in global crop protection. In 2018, cotton accounted for around 4% of global nitrogen and phosphorus fertilizer consumption. A push for greater global adherence to an organic cotton or organic textile standard, while recognizing the need for in-conversion/ transitional periods and support for farmers to move towards organic practices, could significantly cut consumption of chemicals at this stage in the value chain.

Whether made from natural or synthetic fibers or some combination thereof, all textiles undergo significant chemical treatment at many production and processing stages before their sale to the final consumer.

Figure 4: Types of Chemicals Used in the Textiles Industry Source: Adapted from NRDC, A Review of PAS as a Chemical Class in the Textile Sector (2021)

Currently, obtaining complete, accurate, and up-to-date information on the number, volumes, and identities of the chemicals used in textile production is difficult. Two oft-cited estimates are that over 8,000 chemicals are used in textile production and that for every one kilogram (kg) of cotton textiles made, 0.35-1.5 kg of chemicals are used. However, the origins of both estimates are hard to pin down. These figures are also from over ten years ago and may not reflect current market realities.

A comprehensive survey, inventory, or database of chemicals used in textile production would be difficult to complete due to the complexity and global nature of the textiles value chain, involving stages and actors across many countries and jurisdictions with varying ranges of capacity, regulation, industry standards, and diligence. Inter-party communication about, and tracking of, chemicals used among the points in the chain is often minimal. A concerted effort by IOMC Participating Organizations, governments, industry (including SMEs), and non-governmental organizations (NGOs) from across the globe under the umbrella of an implementation programme such as the one the IOMC proposes might be able to accomplish this task.

Without better accounting of the universe of chemicals used in textiles production, it is difficult to identify, triage, assess, and regulate chemicals of concern, deciding which need to be banned, which need to be subjected to occupational exposure and/or emission limits (wet processing of textiles, for example, is a major source of wastewater discharges), and the presence of which chemicals in textile products (and at what levels) should be mandatory to disclose to consumers. Some have already been identified (see Figure 4), but the current extent of their use worldwide remains unclear – another data gap an implementation programme might address.

Figure 5: Some Chemicals of Concern Used in the Textiles Industry Source: Compiled by the author from various sources

The stakeholder consultation process involved in an implementation programme could address how to prioritize and allocate reviews of possible chemicals of concern, possibly through the chemical class or family approach instead of substance-by-substance, such as the Natural Resources Defense Council (NRDC) has suggested for PFAS. Identified chemicals of concern could be added to a globally harmonized MRSL. The value chain could then use the MRSL to prioritize chemicals for restrictions or phaseout and for targeting for substitution without waiting for regulatory agencies to act. A commonly agreed certification and/or labeling scheme could identify which brands and products align with the harmonized MRSL. In those cases where emissions or occupational exposure are involved, maximum permissible levels could be identified in accordance with best practice and shared as guidance across the value chain, as ZDHC is seeking to do with its wastewater guidelines.

Another chemicals in textiles issue an implementation programme might address is trade. Several recent studies have shown that even when a jurisdiction outlaws chemicals of concern in textiles, imported apparel found for retail sale in that jurisdiction still contains values violating the restrictions. The new programme can identify trade issues for follow-up in appropriate fora such as the World Trade Organization (WTO) and could also identify and/or provide support required to downstream chemical users, including SMEs.

A possible waste management component for a textiles sector implementation programme?

While SAICM has tended to focus more on chemicals management than waste issues, negotiators of the successor framework conceive of it addressing the latter as well. The IOMC’s proposal for an implementation programme reflects this expected broader mandate, although it elaborates on chemicals management but not on waste management.

The textiles sector is very wasteful and almost entirely linear, so there could be much to discuss under an implementation programme of the type conceived by the IOMC. While textile production volumes doubled from 2000-2015, the clothing utilization rate, that is the number of times a garment is worn before it ceases to be used, decreased by an average of 36%. Reportedly, more than half of “fast fashion” is disposed of within a year. Of the total fiber input used to produce clothing, 87% ends up being landfilled or incinerated – the equivalent of one garbage truck full of clothes disposed every second. Less than 1% of material used to produce clothing is recycled into new clothing, a recycling rate ranking below that of most single-use plastic packaging.

Figure 6: Global material flows for clothing in 2015

Source: Ellen MacArthur Foundation, A new textiles economy: Redesigning fashion’s future (2017)

Circularity goes well beyond waste management and recycling fibers. As outlined by UNEP (Figure 6), “reduce by design” aims to reduce the amount of material, particularly raw material, and hazardous chemicals consumed during production and during use, from the very beginning of product and service conceptualization. Production and consumption patterns as well as end-of-life processes of textile products are optimized via innovative product designs and business models, resulting in not only eliminated harmful impacts and waste but also improved social protections and business resilience. However, there is a need to reduce the harm of the linear textile system we have today, while preparing for the needs and wants of the circular textile system of tomorrow, and this includes better waste management.

Figure 7. A circular textile value chain

Source: UNEP, Sustainability and Circularity in the Textile Value Chain: Global Stocktaking (2021)

Strategies for a circular economy specific to the textiles value chain have been proposed by UNEP, the Ellen MacArthur Foundation, the EU, Germany, and the Netherlands. The UN Alliance for Sustainable Fashion has engaged the fashion industry in discussions on steps to create a circular economy in textiles, as has UNEP. The Global Fashion Agenda (GFA) has created a Global Circular Fashion Forum and worked with UNEP to identify and converge existing industry targets, including on smart material choices, resource stewardship (including a specific target on chemicals of concern management/phaseout), and circular systems. The GEF has already approved two projects on circular economy and textiles covering four African countries, one implemented by UNEP, the other by UNIDO.

Figure 8: A Timeline of select initiatives regarding a circular economy in textiles

Hence, the building blocks are there to work with in any waste management component of the proposed implementation programme and also look at circularity more widely (with a focus on chemicals), but a rationale for the value added that the SAICM successor can bring needs to be elaborated and the issues for the waste component to focus on remain to be fleshed out.

The new global chemicals and waste framework might contribute to the existing work on circularity in the textiles sector by:

• linking together the disparate country- and regional-focused initiatives, and giving them true global scope, while elevating the challenges and support required into strategic high-level discussions;
• broadening the circular textiles discussions to involve interested IOMC Participating Organizations that are not part of the UN system, such as the OECD and the World Bank, and tabling the central role of chemicals management for circularity in the discussions;
• engaging the GEF in helping to develop the initiative, since IOMC Participating Organizations UNEP, UNIDO, UNDP, and the World Bank are GEF Implementing Agencies, and GEF-8 envisions work in this vein;
• broadening the circular textiles discussions to include more parts of the textiles value chain than just apparel; and
• broadening the discussions beyond the limited group of major brands and retailers already involved in existing circular textile initiatives, particularly by engaging the many SMEs in the chain.

The Road to Bonn: Paving the way for textiles to take the spotlight in implementation of the new chemicals and waste framework

The IOMC plans a stakeholder consultation from 20-21 June 2023 to further flesh out ideas for a possible global programme on advancing chemicals and waste management in economic sectors and value chains. The IOMC, working with Participating Organizations, the SAICM Secretariat, and perhaps engaging the GEF Secretariat as well, should use the stakeholder consultation as a springboard for active dialogue with stakeholders in the months leading up to ICCM5 in September on which chemical-intensive sectors to focus on. The textiles sector is a good candidate to become one of the first focus sectors. With a view to presenting a robust proposal for consideration at ICCM5 in Bonn, the dialogue should outline and flesh out what an implementation programme for the textiles sector might look like, which chemicals and waste management issues the implementation programme could provide value added on and should address, and possible objectives, targets, and indicators for the programme. The dialogue might also highlight global work undertaken in the textile industry which could be relevant for other chemical-intensive sectors facing challenges.

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This document has been developed within the framework of the Global Environment Facility (GEF) project ID: 9771 on Global Best Practices on Emerging Chemical Policy Issues of Concern under the Strategic Approach to International Chemicals Management (SAICM). This project is funded by the GEF, implemented by UNEP, and executed by the SAICM Secretariat. The International Institute for Sustainable Development acknowledges the financial contribution of the GEF to the development of this policy brief.

 This Policy Brief is the sixth in a series featuring cross-cutting topics relating to the sound management of chemicals and waste. It was written by Keith Ripley, Earth Negotiations Bulletin (ENB) team leader and writer. The series editor is Elena Kosolapova, Senior Policy Advisor, Tracking Progress Program, IISD.