B 12 - svar på spm. 1 om ministeren vil oversende det brev, hvor Danmark sammen med ti andre EU-lande presser på ambitionerne, og vil ministeren særligt uddybe, om et udvidet producentansvar specifikt indgår i det, fra miljøministeren

Miljøministeriet • Slotsholmsgade 12 • 1216 København K
Tlf. 38 14 21 42 • Fax 33 14 50 42 • CVR 12854358 • EAN 5798000862005 • mim@mim.dk • www.mim.dk
J.nr. 2021 - 5141
Den 5. januar 2022
Miljøministerens besvarelse af spørgsmål nr. 1 til B 12 stillet den 16. december 2021 efter ønske fra
Rasmus Nordqkvist (SF).
Spørgsmål nr. 1 til B 12
”Ministeren oplyste under 1.behandlingen, at Danmark sammen med ti andre EU-lande har presset på,
for at det udspil, der kommer fra Kommissionen, er blevet ambitiøst. Vil ministeren oversende det
brev, hvor Danmark sammen med ti andre EU-lande presser på ambitionerne, og vil ministeren
særligt uddybe, om et udvidet producentansvar specifikt indgår i det”
Svar
Danmark har i samarbejde med 10 andre EU medlemslande d. 4. oktober 2021 sendt vedlagte fælles
henvendelse til EU-Kommissionen med en samlet opfordring til en ambitiøs tekstilstrategi. Det
fremgår af side 2 i henvendelsen, at der støttes et fokus på fælles harmoniserede EU-principper for
udvidet producentansvar, i overensstemmelse med forureneren-betaler-princippet.
Jeg kan i tillæg oplyse, at den danske regering i februar 2021 sendte et høringssvar til EU-
Kommissionen vedr. den kommende EU tekstilstrategi. Jeg sendte samtidig et brev til EU-
Kommissionen med en opfordring til at fremlægge en ambitiøs strategi. Høringssvaret og dette brev er
ligeledes vedlagt og relaterer sig til EU-Kommissionens daværende roadmap for det videre arbejde
med tekstilstrategien (LINK). Det bemærkes, at et udvidet producentansvar for tekstiler indgår her.
Lea Wermelin / Janne Birk Nielsen
Folketingets Miljø- og Fødevareudvalg
Christiansborg
1240 København K
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Dear Executive Vice-President Timmermans, Commissioner Sinkevičius and
Commissioner Breton,
We would like to share our views on the announced EU Strategy for Sustainable Textiles. This
paper serves as a follow-up to the Roundtable on Textiles that took place on the 1st of June 2021.
We wish to thank Commissioner Sinkevičius for his participation and the much appreciated
opportunity to have an open discussion on this very relevant and important initiative.
General reflections
 The textile sector is a resource-intensive sector with significant climate and environmental
impacts, which is identified as a key value chain in the EU Circular Economy Action Plan and as
one of the priority industrial ecosystems to address the twin green and digital transitions in the
context of the EU industrial strategy.
 We therefore very much welcome the announced initiative of the Commission for an EU
Strategy for Sustainable Textiles.
 We would like to emphasise the need for an ambitious and comprehensive EU Strategy, that
focuses on the entire textiles value chain. To achieve the ambitions of the Green Deal and a
future competitive European textile industry, the transition towards a safe, sustainable, just,
circular and climate-neutral economy is crucial.
 We stress the urgency, which has become even more apparent during the COVID-19 crisis. We
need to act now to facilitate the textile industry to recover in a more resilient, circular and
sustainable way that increases the competitiveness of the EU on the global market. Besides
our dependency on linear models with long supply chains, which are susceptible to disruption,
the crisis also highlights the emerging awareness among consumers and civil society of our
wasteful patterns and aspirations to different lifestyles and ways of doing business.
 With the upcoming requirement for separate collection of textile waste in the EU, combined
with recent achievements in sorting and recycling technology, there is a clear possibility for the
EU to become a competitive leader in secondary textile materials.
 We therefore would strongly welcome the introduction of clear, incremental and ambitious
targets on collection, reuse and recycling of textiles and the necessary EU-actions to ensure
that these goals are achieved.
 In doing this, we urge the Commission to take an integrated approach and focus on both
environmental and social aspects in the textiles sector.
Design, product requirements and hazardous substances
Large amounts of unsustainably produced textiles enter the European market that are unfit for
repair and recycling and that do not meet sufficiently high durability standards. We believe this
situation needs to be addressed urgently, and propose the following actions:
 The Strategy should be complementary to other policy initiatives, in particular the announced
Sustainable Products Initiative and Chemicals Strategy for Sustainability. It is crucial to focus
on the entire textiles life cycle and to stimulate the production and use of chemicals, materials
and products that are safe and sustainable from the design stage.
 Within the framework of the Sustainable Product initiative and chemicals and products
legislations, we ask for measures that set clear and ambitious product requirements and
sustainability criteria, with equal conditions for EU produced, exported and imported textile
materials and products in a WTO compatible way. This will boost safe and sustainable
manufacturing worldwide.
 In this regard, we would also like to stress the importance to address products entering the
market through e-commerce.
 We ask to prioritize regulatory actions for minimizing and phasing-out the use of harmful
substances in textiles. These are not only harmful to health and the environment, but also
form an obstacle for recycling. Besides, the level of chemicals safety should not be lower for
recycled based articles compared to the other products on the market. Giving special attention
to PFAS, polybrominated flame retardants and other POPs. Furthermore we stress the
importance to minimize emissions of microplastics and the use of textiles that cannot be
recycled. Regulatory actions in this field should inscribe into (or in coherence with) the REACH
and CLP regulatory frame.
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 We would like to stress the need to foster innovation and utilize available funds to stimulate
research and investments for non-toxic alternatives, high-level recycling technology, resulting
in non-toxic, high-quality secondary raw materials, sustainable bio-based fibres, as well as
utilizing fibres from waste- and side-streams. Thereby ensuring an overall positive
environmental and climate performance.
Closing the loop
The very linear model of the textile sector and the very fast turnover of products (an over-
consumption phenomenon also known as fast fashion) lead to significant and unsustainable
impacts. Therefore, the transition to a more circular model is indispensable. Fast Fashion is a
major issue; the average EU citizen buys 60 per cent more clothing and keeps them for about half
as long as compared to 15 years ago. Measures need to be put in place urgently to tackle
overconsumption and increase reuse and recycling as increasing (over)production and
consumption results in huge amounts of waste and aggravates the overall environmental impact of
textiles.
 We ask for a study on the dynamics of fast fashion and how to address this phenomenon,
including influencing consumer behaviour as well as encouraging new circular business models
to counteract the negative effects of fast fashion.
 We call for the waste hierarchy to serve as a basis in developing the strategy.
 We ask for measures to prolong the lifespan of textiles to be key part in the strategy.
 We would strongly welcome clear EU targets on collection, reuse and textile-to-textile
recycling.
 We furthermore ask to explore for which materials textile-to-textile recycled content
requirements can be established on the short term.
 We would strongly support measures to avoid disposal of unsold goods, for instance via a ban,
as it is unacceptable that products skip the use-phase entirely. While destruction may be
warranted in very specific cases, we ask for measures that tackle the root of the problem. It
could be helpful to oblige companies to provide data on the remains of their products and to
report on measures they undertake to prevent the destruction of goods.
 We support the focus on harmonized EU-wide EPR principles, in line with the polluter pays
principle.
 We stress the important role of green public procurement as a means to help create a new
market for recycled textiles and ask for comprehensive EU criteria and to consider common
targets.
 Measures should not impede reuse initiatives, unless they are required to adhere to
restrictions on the further use of specified textiles, restrictions which are decided following the
REACH regulation.
Transparency and consumer information
Transparency needs to be improved and greenwashing must be avoided. Consumers have a right
to know the environmental and social impact of their purchases, as this enables them to make
informed choices.
 We support the development of a digital product passport for textiles in order to enable
tracking and tracing and ensure access to information about products and their components
concerning; origin and composition including declaration of hazardous chemicals and
substances of concern, their durability if appropriate, reuse, repair and dismantling possibilities
and end-of-life handling, as well as their environmental performance.
 We stress the importance of awareness raising measures among consumers, including the
production, use and disposal phase
 We call for a mandatory label to inform consumers in a direct, simple and comprehensive
manner about both the environmental and social impacts of a garment at the moment of
purchase.
 We would strongly welcome horizontal legislation on due diligence and sectoral criteria and
guidance for textile products.
 We suggest the Strategy to be aligned with the Green Claims initiative.
Yours sincerely,
Austria Minister Ms. Leonore Gewessler
Belgium Minister Ms. Zakia Khattabi
Denmark Minister Ms. Lea Wermelin
Germany Minister Ms. Svenja Schulze
Finland Minister Ms. Krista Mikkonen
France Minister Ms. Barbara Pompili
Luxembourg Minister Ms. Carole Dieschbourg
Netherlands
Norway
State Secretary Mr. Steven van Weyenberg
Minister Mr. Sveinung Rotevatn
Spain State Secretary Mr. Hugo Moran
Sweden Minister Mr. Per Bolund


Miljøministeriet • Slotsholmsgade 12 • 1216 København K
Tlf. 38 14 21 42 • Fax 33 14 50 42 • CVR 12854358 • EAN 5798000862005 • mim@mim.dk • www.mim.dk
The Danish Government's comments on the Roadmap for an EU
strategy for textiles
The Danish Government appreciates the opportunity to comment on the
Commission’s roadmap for an EU strategy for textiles.
The Danish Government strongly supports the Commission’s decision to launch a
common European strategy for textiles, as well as achieving a green transition. A
more sustainable textile industry requires a common and coordinated effort.
The Danish Government advocates for an ambitious textile strategy that
contributes positively to environmental, climate and health outcomes, whilst
considering the current covid-19 crisis. The Danish Government supports the
outlined scope of the textile strategy, as presented in the roadmap. Thus, we would
encourage the Commission to consider additional content in the final strategy
within five prioritised areas, which we consider to be in line with the roadmap:
1. Increased focus on prolonging product lifetime via design and ecolabels
2. Minimise harmful chemicals and plant protection products
3. Less waste – more and higher quality recycling. Establishing a market for
recycling and secondary raw materials
4. Use of business models and public procurement to promote the transition
to a circular economy
5. Combating micro plastics, biodiversity loss and climate change
1. Increased focus on prolonging product lifetime via design and
ecolabels
Based on the knowledge that the design phase of products is a deciding factor for
products' environmental impact and durability, Denmark calls for a coherent
product policy that supports circular design of products with increased focus on
resource efficiency and prolonged product lifetime. This requires an increased
focus on quality, durability, reparability, re-usability, recyclability and substitution
of chemicals of concern in regards to design practices.
With an increased focus on more sustainable design, avoiding the
overconsumption of goods is central, and should therefore be included in the EU
strategy for textiles. Furthermore, the strategy should discourage overproduction,
as this causes an unnecessary use of resources. An opportunity to achieve this is
focusing on innovation that reduces by-products and waste in production and
increase the opportunity for production-on-demand.
To inspire to more sustainable design, encouragement for more traceability
throughout the value chain should be included in the textile strategy. This would
also be a first step to minimise green washing.
More sustainable product design practices could be achieved e.g. by innovations
and digitalisation. Both factors are important in regards to accelerating the green
transition and should therefore be a strong focus area of the coming strategy.
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2
Moreover, Denmark supports the widening of the eco-design directive to the
widest range of products possible, including textiles as part of the Sustainable
Products Initiative, to set minimum requirements and thereby removing the worst
performing products from the market.
Denmark finds that in order to ensure transparency and coherency - a common
underlying methodology is required for the various instruments assessed in the
Impact Assessment Study for the Sustainable Product Initiative (SPI), as well as
the Sustainable Product Policy Framework (SPPF), including the three legislative
initiatives, as a whole. The Product Environmental Footprint (PEF) developed by
the Commission is an important instrument that should serve this purpose.
Furthermore, it is essential that the common underlying method is based on a
common knowledge base, with updated and validated data of high quality.The EU
Ecolabel and national Type I ecolabels has proven useful for companies promoting
their products and substantiating green claims. The ecolabels include
environmental and quality criteria, as well as “how to use” information (wearing
and washing).
2. Minimise chemicals and plant protection products
The Danish Government supports the aim to address challenges regarding the
widespread and diverse use and presence of substances of concern in textiles.
Thus, the strong connection to the Chemicals Strategy for Sustainability and the
Circular Economy Action Plan is essential. The Danish Government supports the
aim to propose actions to promote more sustainable production processes
(including for raw materials used for textile production) and tackling the presence
of chemicals of concern throughout the entire life cycle of textiles and in recycled
raw materials for textile production. In addition, the Danish Government supports
the use of green diplomacy from the EU to globally phase out the use of the most
harmful substances in textiles and use of pesticide active substances not
authorized in the EU. The diplomatic work should also focus on enhancing the
flow of information on most harmful chemicals throughout the supply chains.
It is worth highlighting the importance of including the effects that chemicals and
plant protection products in the production, distribution, use and disposal of
textiles might have on health, including occupational health, biodiversity and the
environment, including waterways, groundwater and water quality. This would
contribute to underlining the need to reduce negative effects on human health and
the environment stemming from the use of chemicals of concern throughout the
entire lifecycle of textiles.
The importance of product safety for consumers should be emphasised. This
includes avoiding substances of concern in products, as well as ensuring that
consumers have easy access to information on the chemical content throughout
the product lifecycle.
3. Less waste – more and higher quality recycling. Establishing a
market for recycling and secondary raw materials
The Danish Government supports the focus on extended producer responsibility
schemes in promoting a more sustainable textile and treatment of textile waste in
accordance with the waste hierarchy. The requirement in Directive (EU) 2018/851
3
for separate collection of textile waste from 1st of January 2025 in EU member
states, will already be implemented in Denmark by January 2022, as part of the
Government's strategy for a green waste sector and Circular Economy from June
2020. This will create a push for new business models and technology
development in recycling. Furthermore, this will contribute to the transition to a
circular economy and EU's goal of a climate neutrality.
The Danish Government supports the proposal to make the textile ecosystem fit
for the circular economy for instance by improving textile waste collection and
recycling in the member states. The Danish Government encourages the
Commission to focus on less textile waste throughout the whole value chain, reuse,
repair, refurbishment and recycling possibilities, in regards to design, business
models and especially technological development.
The Danish Government supports using targets to improve reuse and recycling
efforts, as well as promoting green public procurement. The planned engagement
of a broad range of stakeholders in forming the objectives is of great importance in
order to develop and implement the solutions successfully.
The Danish Government stresses the importance of developing technological
solutions for textile recycling. This can increase the options for textile recycling
and be a way to address the expected increase of textile waste following the entry
into force of the requirement of collecting textile waste in 2025. Solutions for
higher traceability (including of chemicals of concern) in regards to textile waste,
especially exports hereof, should be part of the new textile strategy.
4. Use of business models and public procurement promote circular
economy
The Danish Government stresses the importance of exploiting the potential in
circular business models in the aim of reaching a sustainable textile industry.
Circular business models can help companies to extract significantly more value
from textile products by prolonging the lifetime of products. The higher value
extraction can imply a good business case besides the environmental and climate
related benefits of the lower need for raw materials. Therefore, the Danish
Government supports the proposal of actions to underpin business models that
e.g. sell textile products as services, buy back and resale of used products, second
hand stores, renting of products, and stores for repair and refurbishment of
textiles. In this regard, it is important to note that data and digitalisation can
enable the circular business models - also in the textile industry. Data on the
condition and damage of textile products after use or intelligent price setting on
second hand- or rental of textile products are examples of how data and
digitalisation can enable circular business.
Moreover, it is important to gain further insights and improve the available data
on the consumer’s use of textiles and clothes during its lifetime to promote
sustainable usage and contribute to the development of sustainable business
models.
The Danish government supports proposing minimum mandatory Green Public
Procurement (GPP) criteria and targets, including for textiles. The Commission
4
should ensure a better and more systematic monitoring of member states’ use of
GPP criteria, common definitions and the different tools. The Danish government
suggests that PEF or ecolabel criteria should be used to provide the basic
environmental profile for a product or service.
5. Combating micro plastics, biodiversity loss and climate change
The Danish Government supports the Commission's focus on tackling the climate
crisis and limiting the release of micro plastics. Additionally, the global
biodiversity and habitats of animals and insects should be considered as a central
topic in relation to the production of textiles. Agriculture, resources extraction,
micro plastics, climate change and the release of chemicals play a central part in
shrinking local habitats, but also globally. We encourage the Commission to
present concrete actions to address these issues.
The Danish Government welcomes the cost-benefit analysis of policy measures
reducing unintentional release of micro plastics but would suggest an extension of
the analysis to include an ecological profile (e.g. by using PEF) and taking into
account the user pattern. Natural fibres (e.g. cotton, wool etc.) and synthetic fibres
(e.g. PET, polyamide etc.) typically have different applications not necessarily
interchangeable one-to-one, and the Danish Government would thus urge the
Commission to take into consideration the specific challenges related to release of
micro plastic from synthetic fibres.
The Danish Government suggests that the strategy highlight the potential
contribution towards achieving climate neutrality in the EU by 2050.
Please do not hesitate to contact the Danish Ministry of Environment for further
explanation of the above points.
We look forward to participating actively in the implementation of the
Commission’s work towards an EU textile strategy.


Dear Mr. Virginijus Sinkevičius, Commissioner for the Environment, Oceans and
Fisheries
On behalf of the Danish Government, I thank the EU Commission for the
opportunity to comment on the Commission's roadmap for an EU strategy for
textiles.
The Danish Government strongly supports the Commission’s decision to launch a
common European strategy for textiles, as well as achieving a green transition. A
more sustainable textile industry requires a common and coordinated effort.
The Danish Government advocates for an ambitious textile strategy that
contributes positively to environmental, climate and health outcomes, whilst
considering the current covid-19 crisis.
The Danish Government supports the outlined scope of the textile strategy, as
presented in the roadmap. Thus, we would encourage the Commission to consider
additional content in the final strategy within five prioritised areas, which we
consider to be in line with the roadmap. The Danish Governments' feedback to the
roadmap is addressed in further detail in the attached document.
We look forward to continue to participate actively in developing the final EU
textile strategy.
Please do not hesitate to contact the Ministry of Environment of Denmark if you
have any questions to Danish experience.
Kind regards,
Lea Wermelin
Minister of the Environment
Denmark
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