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Sustainable is the New Mainstream - European Commission’s Circular Economy Action Plan 2022 and its

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On 30 March 2022, the European Commission brought forward a package of measures as part of the European Green Deal and previously announced in the Circular Economy Action Plan (CEAP). While the European Green Deal presented the general principles, the EU Circular Economy Action Plan is a policy paper with green strategies and to-do lists for different areas to achieve the EU’s 2050 targets:

  • climate-neutral economy;

  • no net emissions of greenhouse gasses by 2050;

  • sustainable growth decoupled from resource use;

  • no person and no place left behind;

  • putting a halt to biodiversity loss.

This new legislative package aspires to make almost all physical goods in the EU market more durable and, hence, more environment-friendly, circular and energy-efficient throughout their whole lifecycle - from the design phase to daily use, repurposing and end-of-life. The above measures are meant to address not only the retail and wholesale sector, but also the production and design sector since, according to CEAP 2020, up to 80% of products’ environmental impacts are determined at the design phase.

The CEAP is the Commission’s answer to the growing energy use and inefficient use of materials and subsequent waste issues especially in relation to resource-intensive sectors such as textiles.

So, what did the new CEAP bring for the fashion industry? Let’s find out!


The Commission is proposing several amendments to the Unfair Commercial Practices Directive.

  • The list of product characteristics about which a trader cannot mislead consumers is expanded to cover the environmental or social impact, as well as the durability and reparability.

  • New potentially misleading practices were added after a case-by-case assessment, such as making an environmental claim related to future environmental performance without clear, objective and verifiable commitments and targets, and without an independent monitoring system.

  • New practices were added to the existing list of prohibited unfair commercial practices, the so-called ‘black list'. The new practices will include, among others: making generic, vague environmental claims where the excellent environmental performance of the product or trader cannot be demonstrated. Examples of such generic environmental claims are ‘environmentally friendly', ‘eco' or ‘green', which wrongly suggest or create the impression of excellent environmental performance, as well as making an environmental claim about the entire product, when it really concerns only a certain aspect of the product.

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New requirements were introduced to make products more durable, reliable, reusable, upgradable, repairable, easier to maintain, refurbish- and recycle, and energy and resource efficient through improving product design.

  • Fibre-to-fibre recycling: other popular recycled materials such as bottle plastic derived polyester is no longer applicable.

  • Separate textile waste by fibre: Fibres that are often blended with others, make recycling more difficult due to low availability of technologies to separate textile waste by fibre.

  • Mandatory recycled fibre content will help minimise and track the presence of substances of concern and reduce the adverse impacts on climate and the environment. By 2025, Member States must provide guidance on how to achieve high levels of separate collection of textile waste.

  • The CEAP provides 2 examples on what to keep in mind when designing a product for recycling: a. Elastane is often added to increase the functionalities of fabrics, but it acts as a contaminant in almost all textile fibres recycling technologies, impacting the economical feasibility and environmental cost of the recycling process b. Thermo-mechanical recycling: blending of different types of polyester can also adversely affect the processing of textile waste and the quality of the recycling output.


  • Reuse, rent and repair, take-back services, second-hand retail and tax breaks, will help create cost-saving opportunities for citizens.

  • Companies will need to extend the lifetime of clothing.

  • Companies with fast changing fashion trends have to reduce the number of collections per year, take responsibility and act to minimise their carbon and environmental footprints.

  • Re-shaping the purchasing habits of consumers is difficult unless companies provide for new circular business models, such as product-as-service models, take-back services, second-hand collections and repair services.

  • The Commission will introduce mandatory criteria for green public procurement by the end of 2022.

  • Reusing products: as a part of Mandatory Ecodesign requirements, increased durability will enable consumers to use clothing for longer and at the same time support circular business models such as reuse, renting and repair, take-back services and second-hand retail, in a way that creates cost-saving opportunities to citizens


  • Under the new Ecodesign for Sustainable Products Regulation a Digital Product Passport will be included for textiles based on mandatory information requirements on circularity and other key environmental aspects.

  • To comply with this new piece of legislation, the Commission will also review the Textile Labelling Regulation, which requires textiles sold on the EU market to carry a label clearly identifying the fibre composition and indicating any non-textile parts of animal origin. Along with, a mandatory disclosure of other types of information (circularity parameters, products’ size and, where applicable, the country where manufacturing processes take place).

  • The Commission will also consider the possibility of introducing a digital label.

  • Product-specific information requirements will ensure consumers know the environmental impacts of their purchase to help them make more informed choices.

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  • EPR systems have already proven to be an effective method for sorting and collecting plastic bottles and cans but an EPR system for textiles has yet to be introduced across the EU in a substantial way.

  • Large companies will be required to publicly disclose the number of products they discard and destroy, including textiles to increase transparency.

  • The waste isn’t waste until we waste it! With the new CEAP initiated a complete ban on the destruction of unsold products.

  • Several EU Member States already have or are considering the introduction of EPR requirements for textiles; given that the obligation under EU waste legislation demands establishing separate collection of textile waste by 1 January 2025.


  • The EU is looking to digital tech to reduce the high percentage of returns from clothing bought online, encourage on-demand custom manufacturing, improve the efficiencies of industrial processes and reduce the carbon footprint of e-commerce.

  • The process of co-creation with stakeholders will kick-off in the second quarter of 2022. By the end of 2022, this process should result in an agreed vision for the ecosystem and specific pledges.

  • Once the Transition Pathway has been established, it will also monitor the progress in achieving the twin transitions and bridging the investment and innovation gaps, thereby also boosting the textile ecosystem’s competitiveness. This collaborative tool can serve as a discussion forum in anticipation of actions under the Ecodesign for Sustainable Products Regulation, including the Digital Product Passport.

  • The Transition Pathway, will engage with stakeholders to facilitate the scaling up of resource-efficient manufacturing processes, reuse, repair and other new circular business models in the textiles sector.


Fast fashion is highly reliant on fossil-based synthetic fibres and creates significant microplastic pollution. To illustrate the point, approximately 60% of fibres used in clothing are synthetic (primarily polyester). Now it’s time to connect the dots. The highest amount of microplastics are released in the first 5 to 10 washes. Up to 40,000 tonnes of synthetic fibres are released every year in the effluent of washing machines. New CEAP measures will also target manufacturing processes, pre-washing at industrial manufacturing plants, labelling and the promotion of innovative materials. Further options include washing machine filters, which can cut by up to 80% the volume released from laundering, development of mild detergents, caretaking and washing guidelines, end-of-life textile waste treatment, and regulations for improved wastewater and sewage sludge treatment.


  • Product-specific information requirements will ensure consumers know the environmental impacts of their purchase.

  • Long-lived and recyclable made of recycled fibres.

  • Free of hazardous substances and produced in respect of social rights and the environment.

  • The EU intends to hold brands accountable for their products along the value chain, including when they become waste.

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