Apparel manufacturers and other value chain parties will be familiar with many of the environmental content standards which have been emerging, including:

–       restrictions on harmful substances usage;

–       more responsible materials sourcing;

–       better durability;  and

–        reduction of packaging.

Once met, any further environmental duties will only occur at the other end of a textile’s linear path, at the point it enters a waste, or diverted waste stream such as reuse, without regard to its manufacturing origin.

Design-for-Environment Standards Throughout Textile Lifecycle?

As part of the coming legal requirements for a circular economy, Design-for-Environment (DfE) standards aim to fundamentally reposition the role of the manufacturer as a necessary collaborator in the broader task of resource recovery. For products with a history of regulated waste diversion, there has been some recognition, though less concrete action, regarding the deconstruction supply chain which awaits at the post consumer stage.

The Ellen MacArthur Foundation has assessed what DfE requirements will mean for the textile industry, which has been spared the vagaries of large scale, government-run recycling programs to date. In its recent landmark publication A New Textiles Economy – Designing Fashion’s Future, the Foundation anticipates that “cross value chain action” will be necessary, involving coordination among all product life-cycle participants, including erstwhile strangers – the manufacturer and the recycler.

What Will These Standards Include?

These collaboration efforts will no longer be voluntary, but rather specifically tasked with the overall achievement of textile industry DfE-mandated standards which the Foundation has articulated to include:

–              aligning design of clothing with recycling options;

–              convergence towards a reduced palette of materials;

–              requirements for new material innovation; and

–              cross-industry alignment on systems for labelling, tracking and tracing.

In other words, manufacturers will be obligated to meet two potentially competing sets of apparel product specifications to simultaneously satisfy the consumer and the recycler.

New Value Chain Alliances Provide Opportunities for Manufacturers

With these new circular economy requirements will come opportunities for manufacturers willing to innovate their production processes to meet the design standards. Producers with end-of-life requirements in other industries, such as electronics have already begun to form new alliances across their complete supply chain to best ensure they meet their sustainability goals as well as coming DfE legal obligations.

Further, as brand owners group themselves based upon consistent sustainability goals and the need for economies of scale to collectively recover their textiles, innovative manufacturers able to meet DfE obligations may find themselves well placed to expand their relationships to brands previously viewed as direct competitors.


For further information, please contact Jonathan Cocker:

[email protected]



Jonathan D. Cocker heads Baker McKenzie’s Environmental Practice Group in Canada and is an active member of the firm's Global Consumer Goods & Retail and Energy, Mining and Infrastructure groups. Mr. Cocker provides advice and representation to multinational companies on a variety of environmental and product compliance matters, including extended producer responsibilities, dangerous goods transportation, GHS, regulated wastes, consumer product and food safety, and contaminated lands matters. He assisted in the founding of one of North America’s first Circular Economy Producer Responsibility Organizations and provides advice and representation to a number of domestic and international industry groups in respect of resource recovery obligations. Mr. Cocker was recently appointed the first Sustainability Officer of the International Bar Association Mr. Cocker is a frequent speaker and writer on environmental issues and has authored numerous publications including recent publications in the Environment and Climate Change Law Review, Detritus – the Official Journal of the International Waste Working Group, Chemical Watch, Circular Economy: Global Perspectives published by Springer, and in the upcoming Yale University Journal of Industrial Ecology’s special issue on Material Efficiency for Climate Change Mitigation. Mr. Cocker maintains a blog focused upon international resource recovery issues at