O o d h e a d p u b L i s h I n g L i m I t e d

Eco-wool and the EU eco-label
The term ‘eco-wool’ in this chapter will be used to define wools (at various
stages of transformation) that meet the requirements of a Type 1 ecolabel.
Examples are the EU Ecolabel for Textiles and the Australian Good
Environmental Choice label. Various forms of the term ‘eco-wool’ have
been trademarked and used for marketing purposes but these wool products
may not comply with the requirements of the above Type 1 eco-labels.
Type 1 eco-labels provide the greatest degree of transparency and the
greatest assurance that the product has been manufactured with minimum
environmental impact. The criteria in Type 1 eco-labels are set and assessed
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independently, they are readily available, they cover the total processing
sequence and they apply to the processing stages with the greatest environmental
impact.
The EU eco-label is arguably the most important standard for good
environmental processing of textile fibres. It contains criteria that exceed
‘environmental best practice’ for textile processing as defined in the EU
BREF document (EIPPC, 2002) and the Integrated Pollution Prevention and
Control (IPPC) legislation (EC, 1996). Other international Type 1 textile
eco-labels have usually taken their criteria from the EU eco-label.
The EU eco-label includes three groups of criteria:
1.
All fibres have a clean fibre requirement. For the natural fibres, the
clean fibre criteria are based on pesticide content.
2.
The fibres must be processed using low environmental impact processing
conditions (all processing agents must be biodegradable and there are
strict limits on discharges of high organic load effluents and toxic
materials).
3.
There are ‘fitness for use’ criteria that guarantee that the product will be
durable. This provides an assurance to consumers, but it also reduces the
environmental impacts associated with processing of a replacement
garment.
Some of the derived Type 1 standards (but not the EU eco-label itself) may
add some social elements (fair pay, safety, child labour), but this is often
accompanied by removal of some of the processing compliance stages.
Because of the international proliferation of the term ‘eco-wool’ and to
provide clarity and guidance to the wool processing trade, the IWTO established
an international working group from many of the grower and user countries
to establish definitions for the term ‘eco-wool’. The following definition was
endorsed at the 2008 IWTO Conference in Beijing:
Eco-wool:
Wool in which residual pesticides on the greasy wool fibre do not
exceed the limits set by EU Eco-label.
Eco-wool product:
A product manufactured from Eco-wool (defined above), which has
been processed and/or transformed in accordance with the specifications
of the EU Eco-label. The processor must meet the trade waste requirements
of the local environmental control authority where these are more restrictive
than those defined for the EU Eco-label.
In the 2002 revision, the EU eco-label recognised the value of the IWTO
Draft Test Method 59 (DTM 59) as the method for measurement of pesticide
residues in greasy wool. DTM 59 has a number of ‘hidden’ benefits for wool
as it not only ensures that the analytical laboratory is accredited to ISO/IEC
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17025 and that the laboratory is currently proficient, but it also requires that
the wool is sampled according to IWTO core test regulations. This not only
ensures that representative samples are analysed, but it also provides traceability
that relates the chemical test result to the wool that is offered for sale. DTM
59 also incorporates all of the EU eco-label pesticides.
The EU eco-label requirements differ from the main organic standards in
five main ways:
1.
The EU eco-label applies good environmental practice criteria for most
textile fibres including synthetic fibres. All fibres have their own ‘clean
fibre’ criteria.
2.
The EU eco-label includes strict and auditable processing requirements
that have been established by experts familiar with textile processing.
These criteria have been established by examining the life-cycle impacts
for production, processing and use of the product, and limits are imposed
on the key discharges with potential to damage the environment. There
are many areas where the EU eco-label criteria go well beyond the
requirements in organic processing. As an example, there are wool scours
that have been certified for organic processing but which would not
meet EU eco-label standards.
3.
Organic standards focus on ‘accreditation’ of a farm or a textile processing
mill whereas the EU eco-label focuses attention on specific certification
of each processing batch. The differences are most obvious on-farm; in
most (but not all) organic productions systems, any use of synthetic
pesticides disqualifies the property from its organic status for some
period of time. With the EU eco-label, farmers may offer specific batches
of wool depending on its treatment history within the current growing
season.
4.
Strong weighting is placed on the durability of the final product. An area
where this is very clear in wool processing is shrink resistance. The EU
eco-label allows chlorine-based shrink resist treatments to be used on
loose wool and slivers. The argument is that the environmental benefit
conferred by manufacturing a garment that is robustly ‘wash and wear’
outweighs the small environmental effects from the shrink-resist treatment
conducted under conditions where plant discharges are strictly controlled.
5.
The EU eco-label is silent regarding on-farm issues such as animal
welfare and environmental impacts, whereas this is a major thrust of the
traditional organic standards. Given that the main focus in the EU eco-
label is on reduction of environmental impact in processing, and that
equivalent criteria apply to all fibres, it is appropriate that on-farm elements
are not applied to wool and to cotton. However on-farm issues are relevant
to some consumers and ‘brands’, especially in view of the attacks on the
wool industry by People for the Ethical Treatment of Animals (PETA).
IWTO has also recognised this gap and has encouraged grower countries
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to develop programmes to identify good-management farming practices.
Australia is developing its ‘LandLeader’ programme and other wool-
growing countries such as South Africa are taking similar steps. However,
development of auditable and consistent guidelines for land management
across different climates and land types is difficult. In addition, a reporting
system that allows direct ‘line of sight’ from the purchaser of the wool
product back to the originating properties is needed. Currently, purchasers
requiring on-farm assurances have established personal contacts with
large wool-producing properties from where they source all of their
wool.
The EU eco-label is based strongly on a supply chain approach where
input of toxic materials is limited at all stages. Downstream processors are
assured that only low toxicity and biodegradable components have been
used on the fibre that they purchase. This information flow is often missing
in textile supply chains and especially in wool supply chains.
There is increasing awareness that environmental discharges from a wet
textile process such as dyeing arise from two sources:
1.
the compounds deliberately added to the process by the dyer; and
2.
the materials already present on the fibre when it is received. The identity
of these materials is often outside the control or knowledge of the processor
receiving the fibre and they may contribute a greater pollution load than
the process additives. They may be difficult to remove and they may be
toxic or poorly biodegradable.
The general issue of supply chain communication has been raised as an
important element of good environmental practice in the EU BREF document
(EIPPC, 2002) and by Cooper (2007). The problems are most severe at
dyeing since dye liquors are difficult and costly to treat because of their
volume and temperature. The European IPPC legislation will require EU
dyehouses to better understand the levels of contaminants on the scoured
wool and yarns that they process.
Finished goods processed in compliance with the EU eco-label requirements
will be eligible to apply to a Competent Body in the EU to obtain the EU
eco-label award, a sign to consumers that this particular textile product has
been processed under good environmental conditions and with minimum
environmental impact.
Most of the major manufacturers of textile processing dyestuffs and
auxiliaries now manufacture specific product lines that meet the EU eco-
label requirements. It is relatively simple for most textile mills to purchase
processing agents that already have the necessary EU eco-label paperwork.
An important recent development has been the opening of a database in
the EU eco-label website that allows late-stage manufacturers to find partially
processed fibres, tops or yarns that have been manufactured in compliance
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with the EU eco-label. This is particularly important for wool, which has a
longer supply chain than most other fibres. Because the EU eco-label
requirements start with greasy wool, the task of identifying and then
commissioning the processing of compliant batches of greasy wool has simply
been too difficult for spinners and weavers. It is also possible for wool
processors to obtain EU eco-label certification for their intermediate tops
and yarns and at least one supply chain is moving in this direction.
Unfortunately the EU eco-label, at least in textiles, remains a poor marketing
tool, with only around 70 textile products registered (EU, 2007a). A number
of factors contribute to this poor uptake:
• lack of knowledge of the EU eco-label in the processing and retail
trade;
• the perceived rigour of the processing requirements, partly due to the
complexity of the paperwork at mill level;
• after-chrome dyeing cannot be used and sections of the trade believe
that reactive dyes cannot produce adequate black shades;
• profit margins in the early stages of wool processing are too low to allow
more than minimum compliance with environmental legislation; and
• wool garments are manufactured across several countries in extended
supply chains.
Conversely the great strength of the EU eco-label is that it is a powerful
standard for sustainable textile production with its links to ISO 14024 and
the fact that it can support a claim that products manufactured in accordance
with its criteria have a reduced environmental impact. Currently there is very
wide recognition of the EU eco-label in at least the Australian wool growing
industry, and it is expected that the recognition by the IWTO of the EU eco-
label will increase awareness in the wool supply chains.