A public consultation was opened from May to August 2021, to gather feedbacks on the Roadmap issued by the EC as first step in the pathway towards Strategy. In that occasion, EUCTL expressed its first views on this project.

First of all, EUCTL fully supports the aim of the Strategy, as described in its roadmap: “to set in place a comprehensive framework to create conditions and incentives to boost the competitiveness, sustainability and resilience of the EU textile sector”.

Considering that textiles and clothing make up a wide industrial ecosystem, with different types of products and value chains, globalised an in many cases very long, the objective of the Strategy is very ambitious: just a complex combination of actions, addressing different actors, can lead to such a goal.

Focusing on the issues more strictly related to the use of chemicals in the value chain, EUCTL highlights that:

1. production and use of chemicals in EU are subject to a huge set of rules aiming at sustainability (REACH and CLP, IED, etc.); considering the high rate of imports in the textile value chain, we claim for an effective control system to check that imported products comply with EU rules, to grant fair competitiveness;
2. the public consultation refers to “chemicals of concern” which could hamper recyclability; today the presence of chemicals is not among the main causes of this lack of circularity: the demand for recycled textiles is low, separate collection is yet to come many MS and sorting/recycling technologies able to select, disassemble and treat all the components of a garment have to be developed; only during the development of such technologies, chemicals hampering some processes could be identified: these are the ones to be defined “chemicals of concern”, to be regulated for circularity;
3. chemicals are fundamental for many processes of the value chain: from fibre production to dyeing and printing, up to finishing; they give final products different characteristics, from softness and colour to resistance and durability, elements to be considered too, when we refer to circularity (durability of products VS waste production).