An open letter has been published and endorsed by 20 members of the International Consumer Protection and Enforcement Network (ICPEN). It emphasises to the fashion and textile sector the importance of adhering to consumer protection law when making environmental claims. 

The consumer protection authorities – including the Competition and Consumer Protection Commission (CCPC) in Ireland – outlined in the letter a number of principles for retailers to follow. 

The ostensible aim of the open letter is to help raise standards and compliance across the fashion industry, while ensuring consumers are well-placed to make informed choices about their purchases. 

What measures does the ICPEN open letter call for? 

The membership organisation of consumer protection law enforcement authorities stated that while there may be variations in the laws of different jurisdictions, “this letter emphasises that the same basic principles apply to businesses across many different countries.” 

Such principles include: 

• Making sure only truthful, clear, and accurate environmental claims are made 
• Only putting forward claims when sufficient evidence already exists to substantiate them 
• Avoiding the use of vague or general claims, such as “green”, “eco-friendly”, or “sustainable” 
• Swerving clear of unsubstantiated claims about future aspirations, instead concentrating on specific measures already taken or underway to achieve future goals. 

Fashion brands told not to overstate their progress on environmental matters 

To give an example of one area of focus for the open letter, the 20 consumer protection authorities cautioned firms against overstating the significance of “green” measures they have implemented. 

The document asks businesses to make sure they market any improvements in a “proportionate” way, not giving them “undue emphasis” in marketing. 

For instance, the open letter says that while it can be considered a positive improvement to reduce the amount of water used in the manufacture of jeans, the reality is that it is crucial not to overemphasise such a reduction. 

This stance is justified because, the document reasons, such a decrease may constitute only “a small fraction of the overall emissions and negative environmental impact of the production of the jeans”. 

The letter states, too, that retailers should not make claims based on data that is not sufficiently specific to the given product. An example of this would be claiming that a particular clothing item automatically has a lower impact on the environment due to it having been made from organic cotton rather than conventional cotton. 

Warning is provided in the letter, too, against the use of self-made labelling schemes and the misuse of third-party certifications. The document goes on to say that labels “should give an accurate impression of the environmental performance of the product.” 

Last year, the UK Competition and Markets Authority (CMA) published guidance to help fashion businesses avoid “greenwashing” in their environmental claims. 

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