Extended Producer Responsibility for Textiles? Not So Fast…..

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Written by Calvin Lakhan, Ph.D, Faculty of Environmental Studies at York University

In the Ontario Environment Ministry’s Reducing Litter and Waste in Our Communities Discussion Paper, the question was posed:

What additional materials do you think should be managed through producer responsibility to maximize diversion?

Stakeholders from across the used textile collection sector highlighted textiles as being a potential candidate for extended producer responsibility (EPR).

Given the hundreds of thousands of tonnes of used textiles being generated annually, it seems only logical that producers should be tasked with the physical and financial responsibility for managing these items at their end of life.   

However, when the university was asked to take a position supporting a producer responsibility scheme for textiles, I hesitated.

I want to preface this by saying that I feel that producer responsibility has a place in promoting a circular economy – In theory,  EPR is supposed to encourage design for the environment (have producers use more sustainable materials), promote positive environmental outcomes (increased diversion), and contain costs (incentive to minimize costs associated with end of life management).

Would EPR for textiles achieve these desired outcomes?

Before answering this, let’s remember what EPR is actually designed to do –  EPR is a cost recovery tool to finance the operational and administrative expenses associated with managing a material at its end of life.

Steward fees (what industry pays to finance a producer responsibility program) is based on net cost of material management. As an example, the fees associated with Blue Box materials are in direct proportion to the system costs attributable to said material. For packaging like plastics film and polystyrene, producers pay an extremely high steward “fee” because the net cost of material management is in excess of $1500 a tonne. Conversely, aluminum producers do not pay any fees, as they have a negative net cost (the revenue received supersedes the cost of material management).

Why this matters for textiles is that at present, net cost of material management for textiles is negative. Due to the high value of used textiles as a commodity, numerous organizations from across the for profit/not for profit sector collect used textiles, using a range of collection mediums.

Textiles, unlike most other waste streams, are being collected by third party operators, even in the absence of material specific legislation. The value of used textiles results in a self-sustaining collection network that ultimately negates the need for cost recovery schemes such as extended producer responsibility.

There is even an argument to be made that the low diversion rates for textiles is attributable to a lack of opportunity and awareness among households (as opposed to a lack of organizations willing to collect the material).

At present, there are no *net* costs to recover for used textile collectors, and EPR becomes moot.

Where this situation may change is in situations where used textile collectors begins to incur operational expenses that exceed the revenue that they receive from the material. This could be attributable to any number of things – management of low grade materials that have minimal value at end of life, a decrease in commodity value (due to either increasing supply of used textiles, or decreases in demand), and the development of domestic processing/recycling capacity that require infrastructural investments.  In these instances, EPR could be seen as a potential cost recovery tool.

Practical challenges to implementing a producer responsibility scheme for textiles

If EPR is adopted at a provincial (or national) scale, we must be cognizant of the enormous administrative challenges of developing such a program. The creation of an IFO/ISP, calculating and collecting fees, disbursing fees to service providers etc. are all necessary steps when developing a producer responsibility program.

Furthermore, the technical challenges of being able to readily quantify end of life material management costs, and then allocating those costs to specific stewards will require a fundamental overhaul in how we collect and interpret data related to textile generation/recovery. Of note, all EPR programs differentiate fees based on product or material type (i.e. a fee for a television is greater than the fee for a cell phone because of the differences in end of life management costs). This process would need to be replicated for all textile types being sold into the market in order to correctly allocate costs.

Simply put, formal programs for textile diversion are in their infancy, and we are still a long way from having the understanding to conceptualize what a producer responsibility scheme might look like. To provide context, Ontario’s Blue Box, which has had a (partial) producer responsibility scheme for the better part of two decades, continues to struggle with how to reconcile the opposing interests of both stewards and municipalities. It is a highly contentious process that is fraught with difficulty as stakeholders try to determine what is fair and reasonable.

Be careful what you wish for

While most stakeholders involved in used textile collection advocate for EPR, it is important to keep in mind that under a 100% EPR model, stewards will assume ownership of all recovered materials. While yes, they will be physically and financially responsible for all end of life material, they will also be entitled to the revenue received from the sale of that material.  

At present, it is unclear what the implications of a 100% producer responsibility model would be for used textile collectors, particularly in the charitable/not for profit space. Stewards may ultimately decide to rely on the existing collection networks in place (as opposed to doing it themselves), and designate certain organizations as a preferred service provider. It is entirely possible that charities/not for profits would then compete with other collectors to be a service provider, essentially reverting to a “bid/tender” process.

What should we do?

While the future of textile legislation, and what role EPR should play remains unclear, the key to developing a sustainable, circular textile market lies in flexible, non-prescriptive legislation. A necessary first step is to designate textiles as a priority material, but leave it up to the market to organically develop solutions to keep material out of landfill, and maximize the economic, environmental and social impact of recovery. Rapid changes in textile end markets, the types and quantities of textiles being generated, and technologies to recycle/reprocess textiles requires legislation that can grow and adapt to reflect the conditions of an evolving market place.

Note: This article reflects the sole opinion of the author. He does not speak on behalf of the university or any of its stakeholders.


About the Author

Calvin LAKHAN, Ph.D, is currently co-investigator of the “Waste Wiki” project at York University (with Dr. Mark Winfield), a research project devoted to advancing understanding of waste management research and policy in Canada. He holds a Ph.D from the University of Waterloo/Wilfrid Laurier University joint Geography program, and degrees in economics (BA) and environmental economics (MEs) from York University. His research interests and expertise center around evaluating the efficacy of municipal recycling initiatives and identifying determinants of consumer recycling behavior. Calvin has worked as both a policy planner for the MOECC and as a consultant on projects for Stewardship Ontario, Multi Material Stewardship Manitoba, and Ontario Electronic Stewardship. Calvin currently sits on the editorial board for Advances in Recycling and Waste Management, and as a reviewer for Waste Management, Resources Conservation and Recycling and Journal of Environmental Management

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