Include Social Aspects on Textile Labels: We respond to the new Textile Labelling Regulation

Update: For the EU consultation for the Labelling Regulation on 15 April, find FTAOs submission here.

Brussels, 28 September 2023 – The European Union is revising its rules on product labelling: what information should be included on garments and textiles. At present, this is limited to information on fabrics and care instructions. To improve working conditions for all workers in the supply chain, it is important to provide more information on the social side of the garment sector. Today, the Fair Trade Advocacy Office (FTAO) presents this position to the European Commission through a call for evidence. 

Until the 30th of September the European Commission opened a call for proposals. This legislative process is used to receive feedback on specific policies which will be used to update the policy, in this case the Textile Labelling Regulation. The FTAO argues that social information should be given on three different levels: country level, company level and information from the production sites. These three will be explained in more detail below. 

Human rights violations take place in the garment sector at a great scale: low wages, unpaid overtime, unsafe factories and (sexual) harassment, to name a few. One of the contributing factors to this is a lack of transparency. Consumers that want to make an informed choice and buy sustainable products have difficulty finding the right information. Workers that want to address problems don’t know who the buyer is and cannot reach them. Garment- and textile – labelling could help tackle this problem when used in the right way.  

How information should be presented  

It is important that the information is understandable and accessible to different stakeholders in garment supply chains, to consumers and for journalists to fact check information. Where possible, information should be provided on the label, detailed information could be provided through a QR code or other digital means. Information should be given for all tiers of the production process: from the raw material stage (cotton farms or other fibres), through the spinning-, weaving- and finally cut-make-trim (CMT) stage. 

Country specific information 

The country of origin can give some insights, as long as it is accompanied by specific information. This could be information on the minimum wage in a country and how this relates to a living wage. Ratified ILO- and UN conventions can also be informative, for example on migrant workers or supporting freedom of association. This does not mean that these problems will never arise, it is however an indication that there is an international system in place to address issues when they arise. How a country scores on the list on the ranking of trade union busting can also provide useful information. 

Company information: purchasing practices and complaints 

The purchasing practices of a company should be made clear as they can have a big influence on working conditions. Last-minute changes in delivery times or design could have significant repercussions for a factory: financially, if additional investments arise in the event of design changes, but also in terms of possible longer working hours, if delivery times are pushed forward. (Forced) unpaid overtime is not uncommon in these situations to compensate for the losses. A company should therefore pay a price that makes sustainable production and decent working conditions possible. To verify if this is the case, transparency is needed on the purchasing practices and contracts between the company and their supplier. If a company has a complaints mechanism, it should be clear what complaints they have received and how they responded to these cases. 

Working conditions and audits 

For the different stages of the production process, information should be provided on the average working hours, overtime (if present), health & safety conditions, committees that are active, real democratic trade unions present at the factory, collective bargaining agreements settled and information on types of employment contracts. Temporary contracts are common in the garment sector. This creates job insecurity for workers and influences other human rights. Some workers might not receive a new contract when they become pregnant or if they join a trade union. Farming raw materials such as cotton is often a seasonal job, making job security even lower. If these working conditions are verified by an auditing company, this information should be made public as well, in such a way that does not put workers or smallholder producers at risk.   

Aligning with other EU policies 

As a minimum we call for the Regulation to be in line with forthcoming Due Diligence legislation such as the CSRD and CSDDD (for example by including a link to the CSRD reporting on the company on/through the label). However, these directives have limits in terms of size of companies covered and type of information that are legally obliged to provide. In itself the Due Diligence legislation will not provide sufficient information for all pieces of garment for consumers to make an informed decision. Therefore, the information listed above should be added on/through the label.  

For any questions around our work on the Textile sector or Due Diligence legislation, please contact May Hylander at hylander@fairtrade-advocacy.org.