Step four
Key to this approach would be to fill in critical information gaps, according to the NRDC. This could take the form of two types of research: the chemical composition of commonly used formulations and the alternative formulations that are available.
Greer points out that many mills use formulations without knowledge of their chemical composition or buy ‘off brand’ products without realising they are poor substitutes. “Brands must step up to the plate here (either alone or in collaboration) and test the products used at their mills. They should ask their mills to send samples of the products and formulations they use and send those samples to a laboratory for a scan of the Greenpeace chemical categories.” Collaboration across brands would clearly be useful here, with perhaps the creation of a third-party repository and a single list of banned products, but only “if and only if companies can coordinate quickly enough to ensure that they meet their reduction deadlines.”
NRDC believes that research to identify alternatives is also crucial for the change in the industry by 2020. Again, collaboration across brands would clearly be more efficient for the industry, but only “if it is possible to get this up and running expeditiously.”
With results in hand, “retailers/brands should then provide an explicit list of the formulations that contain banned substances to the mills, with dates for their phase-outs, as well as a list of preferred chemicals and formulations. This will provide a clear path forward for factories to transition away from problem uses.”
Step 5
The final step in the NRDC plan would be for brands to create clear sourcing policies with teeth that deliver business consequences to environmental non-compliance.
“The only way to make the Greenpeace commitments real is for the sourcing team to contractually require them, with consequences – suspension or termination of business – for bad behavior, says Greer. “In fact, it is the sourcing team that needs to own the Greenpeace commitments, not the CSR shop. Any phase-out plan owned and operated solely through the CSR shop is a fake and will not deliver results. This approach is very different from the ‘we’re-all-in-this-sustainability-journey-together’ mentality that many companies have brought to their CSR work to date and will require changes in hierarchies, ownership, and management for many of you.”
Industry challenge
The NRDC acknowledges that the implementation of the Greenpeace commitments is a challenge for the global textile industry. “Most brands know their Tier One garment factories but not the Tier Two fabric mills, which is where the chemicals of concern are used and released. Traceability of products through the supply chain is an on-going challenge which to date has been focused largely on small, special product lines (such as organic cotton) and not the bulk of wet processing production. Until now, chemical concerns have been limited to chemicals on the residue of clothing [Restricted Substances Lists from AAFA.pdf] and not on the chemicals used and released in manufacturing. And, let’s be honest with ourselves: only a very small handful of retailers and brands have ever even once assessed overall wastewater compliance at their fabric mills, let alone overseen or enforced a program limiting specific chemicals used and released at these sites.”
