Voluntary Sustainability Initiatives in the Apparel Industry: the Trend towards ‘Beyond Certification’ Approaches to Sustainability

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Voluntary Sustainability Initiatives in the Apparel Industry:

The Trend towards ‘Beyond Certification’ Approaches to Sustainability

Master thesis Political Science, Political Economy

Research Project: Corporate Responsibility and Authority in Global Governance

June 2018

Will Sharp [11717440]

Supervisor: Luc Fransen

Second Reader: Philip Schleifer

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Acknowledgments

I would first like to thank my thesis supervisor Dr Luc Fransen for all his assistance with this project, from his engaging and informative seminars to his valuable guidance and support in our individual supervision sessions. I would also like to express my gratitude to Karin Ekberg, Sibbe Krol, Sinead Murphy, Baptiste Carriere-Pradal and Christian Dreszig for giving up their valuable time to provide interesting and informative answers to my questions. Finally, I would like to thank the second reader Philip Schleifer, for both taking the time to read this research and for delivering the seminars that sparked my passion for the topic of CSR and sustainability.

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1. Introduction

Over the last decade, environmental sustainability in the apparel industry has risen on the agenda from a relatively niche theme to one of the industry’s most important challenges, as more and more people begin to realise the devastating impact it has on the environment. In line with this realisation, numerous voluntary sustainability initiatives (VSIs) have been developed over the last decade in order to address the industry’s considerable impact on the environment throughout its value chain. Given that numerous other industries seeking to deal with environmental sustainability issues have sought to do so through the development of voluntary standards, we might expect these to feature prominently in the industry’s efforts to tackle its unsustainability. This is especially the case for the apparel industry, which is often cited as one of the pioneering industries to develop standards-based voluntary initiatives from the late 1980s (Egels-Zanden, 2011: 259), prominent examples including the Fair Labor Association (FLA), Workers’ Rights Consortium (WRC) and Worldwide Responsible Apparel Production.

However, this does not appear to be the case, with the vast majority of VSIs develope d over the last decade taking a number of non-standards-based approaches, such as the sharing of best practices, capacity-building and target-setting, for example, as well as harmonisation and building transparency, with an emphasis on ‘continuous improvement’. Moreover, a notable feature of these new initiatives is the lack of rigid enforcement mechanisms, such as third-party auditing, public disclosure and explicit sanctions.

This paper is therefore an exploratory study in an effort to answer the research question:

Why are new voluntary sustainability initiatives in the apparel industry primarily taking non-standards-based approaches to addressing environmental issues over the last decade?

In doing so, it will sequentially address the following sub-questions:

A) In what ways has there been a trend towards taking non-standards-based approaches to sustainability in the apparel industry?

B) Why have voluntary standards not been a major feature of the industry’s approach to dealing with the apparel industry’s environmental impact?

C) What are the advantages and disadvantages of these new approaches for addressing the apparel industry’s environmental impact?

This seeks to contribute to the ongoing debate regarding the effectiveness of VSIs’ standards-based approaches to making industries more sustainable and whether we should instead be advocating approaches that go ‘beyond certification’, by drawing attention to and analysing the significant shift in the apparel industry towards the latter approach. This is an important subject of study: as the global

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environmental crisis deepens, it is essential that we understand how the most environmentally damaging industries are acting to address this imperative transnational issue and promote sustainability. The apparel industry is especially important in this regard due to its particularly enormous environmental impact and ever-expanding size. Therefore the recent dominance of non-standards-based VSIs in the apparel industry is of significant interest, and a better understanding of why this change in approach is occurring and what its promises and pitfalls are is important for advancing sustainability both in the industry and more generally. Indeed, it may provide useful insights or inspiration for the development of new VSIs in other industries, or for existing stand-setting organisations which are forever changing and adapting (Fransen, 2018a).

The findings of this research reveal that existing standards have been deemed an ineffective means of improving the sustainability of the industry, given the pervasiveness of cheating by factories undermining their effectiveness, while also distracting attention and resources from making more impactful sustainability improvements. These issues are intensified by ‘audit fatigue’ in the industry and the complex and opaque nature of the apparel supply chain, which also makes it difficult for brands and retailers to effectively implement and enforce them beyond their immediate suppliers. This explains why so few standards have been introduced over the last decade, and why those seeking to address sustainability in the industry collaboratively by founding new VSIs have taken alternative approaches, especially involving ‘continuous improvement’, given that many of the problems of standards stem from their pass-or-fail approach. This is particularly evident in the three case studies presented, which show how their various functions often address these problems directly, while enabling brands to make more impactful sustainability improvements.

The paper will proceed with by developing a conceptual framework of VSIs and their various approaches to sustainability, including an attempt to distil a typology of non-standards-based approaches both deductively and inductively, before developing a theoretical framework by highlighting the main critiques of standards-based approaches. It will then introduce and reflect upon the research methods and case selection, before providing a brief summary of the apparel industry’s structure and environmental impacts, as well as the particular characteristics of the industry that exacerbate these problems. The main empirical section will begin by establishing the premise of this research in more depth by demonstrating the various ways in which the trend over the last decade towards non-standards-based approaches among VSIs is evident. It will then present the main weaknesses which sustainability professionals have found with environmental standards in the apparel industry, before examining three case studies of non-standards-based VSIs in order to develop a better understanding of their various approaches, while evaluating their advantages and disadvantages.

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2. Theoretical and Conceptual Framework

This chapter will begin by explaining the rise of ‘private governance’ of sustainability issues through the development of VSIs, before introducing the standards-based approach, elaborating on its main characteristics, mechanisms and variations in addressing sustainability issues, while defining important concepts for the subsequent analysis in the process. It will then seek to distil a typology of other functions VSIs might take, as well as their enforcement mechanisms, both deductively from existing literature and inductively through my examination of VSIs in the apparel industry. Finally, it will highlight the main critiques of standards-based approaches in the literature in order to develop a theoretical background for the following empirical analysis

2.1 Voluntary Sustainability Initiatives (VSIs)

Many of the world’s most pressing environmental problems are inherently transnational in nature, often arising from activities involved in transnational processes such as the globalization of production and supply, while also producing impacts that transcend borders also, such as greenhouse gas emissions and non-point source pollution. Consequently, the ability of the jurisdictionally and fiscally-constrained nation-state, the traditional source of authority and regulation over private actors, to effectively respond to these challenges is limited (Abbott & Snidal, 2009: 44; Dauverge & Lister, 2013). This is exacerbated by the high cost and practical difficulty of enforcing regulations, the complexity of modern production processes and supply chains, and the difficulty of fostering international cooperation and consensus to address these issues (Prakash & Potoski, 2011).

Consequently, sustainability governance has increasingly entered the realm of ‘private governance’, which refers to “the role of private actors, both profit and non-profit, in the establishment and maintenance of issue-specific transnational rule systems” (Pattberg, 2005: 592). Thus corporations and civil society take it upon themselves to exploit their immense power and transnational character to address sustainability issues (Dauverge & Lister, 2013; Kalfagianni & Pattberg, 2013). This may be achieved through unilateral action, referring to actions taken by a single firm to improve its own sustainability performance (Paton, 2000), or in bilateral 'private-social' partnerships, when an NGO assists a firm in this process (Delmas & Young, 2011). However, transnational sustainability problems are often most effectively addressed through collective action, especially where wider collaboration makes this process easier or creates other shared benefits, while also accomplishing sustainable impacts on a larger scale. The result has been a proliferation of VSIs across a variety of sectors; these are normative institutions involving multiple firms which seek to induce “participating firms to adopt environmental stewardship practices that are over and above legal requirements” (Potoski & Prakash, 2013: 273).

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2.2 Standards and Certification

One of the principal approaches many VSIs take is the development standards, certification and labelling systems (henceforth referred to as the ‘standards-based approach’). Indeed, over the last three decades, the number of such standards has proliferated considerably: according to the Ecolabel Index, there are currently at least 463 labels in the world relating to environmental performance (Ecolabel Index, n.d.). According to Mike Barry, Director of Sustainable Business at Marks & Spencer (M&S), "certification has been the traditional approach to managing complex supply chains", while the International Institute for Sustainable Development (IISD) describes voluntary sustainability standards as "the quintessential example of the green economy in action" (Potts et al., 2014: 323). In fact, so dominant has the standards-based approach to sustainability been, that many scholars simply use the term 'voluntary environmental initiative' or ‘voluntary program’ synonymously with environmental standards (for example, Christmann et al., 2002; Potoski & Prakash, 2005a, 2005b; Delmas & Young, 2011).

Voluntary standards are a defined set of environmental or social criteria which participating companies or products adhere to on a voluntary basis (RESOLVE, 2012: 6). They rely on a market-based approach to promote sustainable production and practices. Participating firms’ or products’ compliance with the standard is then assessed via an assurance system, typically consisting of recurring audits to determine whether or not they meet the standards’ criteria and can become ‘certified’ through a ‘pass-or-fail’ approach. This certification communicates their adherence to this criteria to their customers, be they other businesses (for B2B certification) or consumers via a label (for end-products).

This promotes sustainability firstly by translating the content of a standard into reality (RESOLVE, 2014: 6). In addition, through certification and labelling, they increase transparency by signalling the firms’ otherwise invisible sustainability credentials to their customers, enabling both businesses and consumers to more easily identify more sustainable products and companies (Komives & Jackson, 2014: 5). Certified companies are in turn rewarded with increased demand for their products, and can also be rewarded by their stakeholders, for example through increased investment, therefore providing a significant incentive to become certified (Marx, 2010; Potoski & Prakash, 2005a). This has additional benefits in terms of risk management: a certified firm may be less likely to be ‘named and shamed’ by NGO activists and receive negative publicity, and may also lead to better relations with regulators and government bodies considering imposing regulation on the sector (Bartley, 2007). As Potoski and Prakash argue, this only works because of a standard’s positive ‘brand reputation’, a collective benefit which cannot be replicated by taking the same actions unilaterally and which can only be accessed by participating. Nevertheless, the creation and maintenance of this ‘brand reputation’ relies on the perceived effectiveness of that standard in addressing sustainability (Potoski & Prakash, 2005a)

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Nevertheless, standards come in many different forms. For example, they may be ‘practice-based’, requiring companies to implement particular production practices, for example, or ‘performance-based’, in which companies must meet quantitative targets (Delmas & Young, 2009: 145). Moreover, they might apply ‘horizontally’ to just one stage of production, which is the easiest to implement or enforce, as with many commodities and agri-foods, as well as labour rights in the apparel or electronics industries. Alternatively, they might be applied ‘vertically’ across multiple stages, requiring more audits and a traceability system, also known as a ‘chain of custody’, which are more difficult and expensive to implement (Komives & Jackson, 2014: 9).

Perhaps the most important aspect of voluntary standards, however, is how compliance is assured, especially as their integrity and effectiveness rely on being able to accurately communicate the performance of its participants. This ranges from first-party auditing, or ‘self-assessment’, to third-party auditing, in which an independent organization audits the firm. The general consensus is that the latter is far more reliable and stringent as an enforcement method than the former, although it tends to be more considerably more expensive and may lead to a conflict of interest (Abbott & Snidal, 2009; Marx, 2010; Esbenshade, 2012: 545-8). However, in long and complex supply chains, standards might seek to simplify this process at the expense of stringency, for example by combing self-assessments with the prospect of a random third party audit, as with the EU Eco-Label; or by only testing the end-product itself, as with the OEKO-TEX® Standard 100 (Made-By, n.d.). More stringent methods include the strict monitoring of all inputs, ensuring that each is sustainably sourced, as with the Bluesign Standard (Bluesign, 2013). Another approach involves using a ‘chain of custody’ in order to ensure that products certified earlier in the supply chain retain their sustainability credentials throughout all subsequent processes (Komives & Jackson, 2014: 9)

2.3 Alternative Approaches of VSIs

While VSIs have primarily been studied for their rule-setting and 'regulatory' capacities (Fransen, 2018a), there are numerous other approaches they can take in order to promote and ensure sustainable objectives. These have been examined in more detail in the literature on partnerships (Martens, 2007; Bitzer et al., 2007) and transnational governance, especially that pertaining to climate change (Bäckstrand, 2008; Andonova et al., 2009; Hoffmann, 2011; Bulkeley et al., 2012). Various typologies have been suggested by scholars, some of which will be outlined below. However, attempting to distil a definitive typology from the literature is a thorny and perhaps futile task, especially given the multitude of different terms that have been used to describe similar functions, and given the specificity of many of these functions to the particular industry or issue-area in question. Nevertheless, a brief literature review is still a worthwhile exercise, as it provides a useful initial framework in which to work deductively to categorise the VSIs in the apparel industry. This categorisation, however, will also be

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achieved inductively, given the specificity of these initiatives to the apparel industry and its particular problem structure, so as to ensure that any ‘new’, previously neglected or overlooked functions are included.

Bulkeley et al., for example, in their macro-analysis of sixty transnational governance initiatives addressing climate change, identify capacity building, agenda-setting, information sharing, direct action, provision of funding, as a “relatively discrete set of functions” carried out by VSIs, while also disaggregating the regulatory features of standards into target-setting, forms of monitoring and auditing, and the setting of specific rules (Bulkeley et al., 2012: 595, 604). A similar range of functions has been identified in the literature on public-private partnerships, including: norm coordination and diffusion, collective learning, capacity building, direct societal representation, and the development of new products, markets, or services (Bitzer et al., 2007; Andonova et al., 2009: 62), while Martens (2007: 21) identifies a similar range in his assessment of multi-stakeholder partnerships, adding advocacy, financing, technical cooperation, and coordination of state and non-state activities.

However, it should be noted that these functions are not wholly discrete, and that the boundaries between them can be blurred and difficult to separate in practice. This is complicated further by the fact that such initiatives very rarely engage in a single function, but usually carry out several in conjunction with each other, or may evolve and develop new functions over time (Bulkeley et al., 2012: 596). That is not to say the distinctions are not useful: as Andonova et al. (2009: 66) argue, by developing such typologies of functions, we can identify the “primary steering functions undertaken as identified by the [initiative] itself”, while these are often supported by “auxiliary” functions.

2.3.1 Information sharing: Agenda-Setting, Advocacy, Sharing of Best Practices, and

Transparency Building

A very broad activity frequently mentioned in the literature, information sharing has a variety of meanings depending on a range of distinct purposes it is used for. While some scholars (Andonova et al., 2009; Bulkeley et al., 2012) use this concept without demarcating between such purposes, it would be useful to break it down into several sub-categories based on its distinct purpose, as these would have more analytical value than using it as blanket term.

Firstly, an initiative may share information with an external audience. This activity has attracted significant attention from scholars of transnational governance, and is performed for the purposes of highlighting issues in order to “persuade, pressurize, and gain leverage over much more powerful organizations”, as well as bringing new ideas, norms and discourses into policy debates (Keck & Sikkink, 1999: 89-90). While this type of activity has traditionally been carried out by NGOs, social movements and advocacy networks in particular, it is also fairly ubiquitous among almost all VSIs, who

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need to produce information and highlight issues to an external audience in order to justify their purpose and amplify the importance of their cause, and thus attract members, funding and support. Therefore where information sharing is carried out for this basic purpose, it will not be considered a distinct ‘function’ of an initiative. However, when researching the functions of the VSIs operating in the apparel industry, it became evident that several initiatives engaged in ‘agenda-setting’ as an explicit purpose of the organisation. For example, the Global Fashion Agenda describes its main task as “setting a common agenda for focused industry efforts on sustainability in fashion” (GFA, 2018). Therefore where information is used to influence a wider audience as an explicit purpose of the organisation, it will be considered as an ‘agenda-setting’ function. Moreover, where information, in the form of knowledge and expertise, is used to inform or influence government policy, as has been exhibited by the SAC (Carriere-Pradal, interview), the ZDHC (Macintosh, 2017) and Race to the Top (Krol, 2018), this will be considered as ‘Policy Engagement’.

More important for VSIs, perhaps, is information sharing internally among its members. Again, this can also be a ubiquitous feature of most sustainability initiatives, as the organisation seeks to shape the subjectivity of its members and internalise new norms among them (Bulkeley et al., 2012: 605). However, this may be done in a more deliberate manner for more functional purposes, notably the sharing of best practices and expertise and the sharing of data, which involves data generated either by the initiative’s own experts for dissemination, or is collected from member organisations.

The first purpose involves the sharing of best practices and expertise. Sharing best practices involves the discovery or development of a demonstrably more sustainable practice, such as a new manufacturing process or use of a different material, often with efficiency or competitive advantage benefits as well. This is then shared among members, and therefore seeks to bring about sustainable improvements more directly. Industry associations, for example, have been known to develop and disseminate best practices among its members (Krut, 1996; Nash & Ehrenfeld, 1997). This is also a feature of ‘practice-based’ standards, although the fact that this is a formal requirement for certification, as opposed to being an optional form of assistance, make this a conceptually different phenomena. As many of the apparel VSIs reveal, this activity is usually accompanied by guidance or consultancy services, i.e. the sharing of expertise, in order to assist companies in identifying solutions to their problems and provide guidance in implementing them. For example, the European Clothing Action Plan (ECAP), offers “Access to learning and sharing of best practise with a network of other brands” as well as “Professional guidance through a structured, step by step programme” and “Subsidised access to resources, tools and consultancy support” (Made-By, 2017).

The second main type of internal information sharing is sharing data on the quality and sustainability performance of brands, suppliers and materials. This is especially important for building transparency in complex, geographically dispersed supply chains, in which it can be difficult for well-intentioned sourcing departments to ensure sustainable inputs and processes are being used, especially for tier-two

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suppliers and beyond. A number of apparel VSIs engage in this task, for example by building online platforms displaying the sustainability performance of a large number of suppliers around the globe (Carriere-Pradal, interview). This type of information sharing will therefore be conceptualized as ‘building transparency’.

2.3.2 Capacity-building

Capacity-building is a relatively broad function, defined by Brown and Moore (2001: 16) as efforts to “empower and build capacity of clients for self-help”, often through the “leveraging of a set of material and non-material resources that may include technologies, know-how, management skill, contacts, or financial resources” (Andonova et al., 2009: 65). The aim is therefore to have a longer-term, direct impact, with the NGO or initiative hoping to play only a temporary role. Capacity-building therefore encompasses numerous activities, such as provision of training, technical assistance and professional advice, direct provision of physical capital, or assistance in accessing capital to make long term sustainable investments. The latter in particular has been emphasised by sustainability experts as a crucial activity, especially in relation to poorer producers who often lack the capital or technology to produce in a sustainable manner or reach economies of scale (Potts et al., 2014: 326; ITC, 2015). Therefore the function ‘financial assistance’ mentioned in the existing literature will be included within this concept, especially where it relates to capacity-building investments.

2.3.3 Harmonisation

Another function exhibited by several apparel VSIs is engagement in ‘harmonisation’, by which an initiative seeks to simplify or overcome the problem of duplication of standards and unilateral approaches to measuring and assessing sustainability. This may be through the development of tools providing the industry with a common approach to measuring sustainability, as with the SAC’s Higg Index, for example, or by acting as a platform for “facilitating co-ordination and greater alignment” between existing initiatives, as with Cotton 2040 (2017). The importance of this function will become clear when the problems of duplication are discussed later in Section 2.4.3.

2.3.4. Enforcement

While the way in which standards-based VSIs govern the behaviour of their participants relies on a relatively straightforward approach, in which participants seek to meet certain criteria before being assessed via a pass or fail approach, this is not as simple with alternative approaches. This is because

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many of them rely on ‘continuous improvement’ approaches, which do not have specific criteria participants must meet by which they can be assessed. Enforcement mechanisms are important, however, in order to ensure that initiatives are not exploited as vehicles for ‘green-washing’ and free-riding on the collective benefits of participating. Indeed, rational-choice theory suggests that without explicit sanctions, firms acting rationally are likely to engage in opportunistic, free-riding behavior (Grief, 1997). Moreover, as Lenox and Nash emphasise, without “mechanisms for measuring and enforcing compliance with program objectives”, sustainability initiatives are vulnerable to “adverse selection”, whereby more polluting firms will seek to join them as they have the greatest incentive to free-ride on others’ efforts to create the collective benefits discussed in Section 2.2, thus undermining the credibility and effectiveness of the initiative as a whole (Lenox & Nash, 2003: 344).

Therefore features of the programs’ institutional design are important. This may include features of standards, such as auditing, with first-party and third-party audits constituting ‘softer’ and ‘harder’ enforcement mechanisms respectively. In addition, Potoski and Prakash (2005b: 747-48) argue that other features, such as the public disclosure of audit information, which enables consumers and civil society to punish slackers, and sanctioning by program sponsors (for example, through expulsion from the program), also improve the effectiveness of enforcing compliance. Public disclosure in particular, defined as the delivery of information to a wider public about the degree of sustainability of production, and therefore increasing transparency, has attracted significant scholarly praise as an enforcement mechanism (Fransen, 2018b), some suggesting that there is a positive relationship between the quality of disclosure practices and the effectiveness of VSIs (Auld & Gulbrandsen, 2010; Auld & Re nckens, 2017). Finally, the requirement of making financial contributions could deter potential free-riders from joining, while incentivising members to make better use of their membership by participating more earnestly in order to reap greater benefits.

However, it should be noted that harder forms of enforcement mechanisms can potentially deter firms from joining. This may be due to the cost of enforcement, for example by paying for a third-party auditor, (as will be discussed in the following sub-section) or through the risks posed to a company’s reputation if it fails to perform in relation to other members. Thus VSIs with more stringent enforcement mechanisms are less likely to attract firms, resulting in a trade-off between industry coverage and stringency (Kalfagianni & Pattberg, 2013).

However, scholars also point to another, non-institutionalised mechanism at work, what Schleifer refers to as a "norm-based mechanism" (2016: 44), whereby “sociological pressures (normative, mimetic, and coercive)” from other members or stakeholders shape their behaviour (Potoski & Prakash, 2005b: 748). For example, transnational governance scholars Bulkeley et al. draw attention to “more discursive and normalising practices whereby the exchange of knowledge, ideas, and beliefs is also a critical means through which transnational governance has effect” (2012: 595-96), while Schleifer explains that by bringing members together and seeking to solve problems collectively through interaction and

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deliberation, members build "communities of practice" and create "shared norms" (Schleifer, 2016: 44). This is derived from March and Olsen’s “logic of appropriateness” (1996) in new institutionalist theory, which emphasizes that decision-making is not purely based on utility-maximising cost-benefit calculations, but are also heavily influenced by social norms, which dictate the ‘appropriateness’ of a course of action. Similarly, management scholars, such as Oliver (1991) and Greening and Gray (1994) have shown how enduring norms and organizational cultures have had a significant effect on how firms behave, especially in relation to their stakeholders. Consequently, as Bernstein and Cashore argue, this "logic of appropriateness" governs firms’ behaviour in voluntary initiatives in tandem to formal rules and enforcement mechanisms (2007: 349).

2.3.5. Conclusion

Through a combination of deduction from existing literature and induction from an examination of the population of VSIs in the apparel industry, we can distil a typology of functions these non-standards-based VSIs perform. These functions can be divided according to their role in bringing about sustainability into those that seek to bring about sustainability improvements more directly, those that seek to facilitate this process, and ‘other’ functions which do this more indirectly:

Direct improvements : Best practice & expertise sharing, capacity-building, target-setting Facilitating functions : Harmonisation, building transparency, policy engagement

Other: Agenda-setting, innovation support

In addition, we see how these VSIs can seek to encourage their members to engage in ‘continuous improvement’ via both ‘hard’ and ‘soft’ institutionalised forms of enforcement:

Hard enforcement: 3rd_{party auditing, sanctions (fines, expulsion)}

Soft enforcement: 1st_{party auditing, public disclosure, financial contributions}

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2.4 Critiques of Standards

Having introduced and defined the various concepts involved in standards-based and non-standards-based approaches to sustainability, explaining the both logic of how they seek to increase the sustainability of an industry and how they seek to govern their participants, we will now consider the ongoing debate in both academia and in the professional field about the effectiveness of standards as vehicles of achieving industry transformation, and whether we should seeking to go ‘beyond certification’.

After over two decades in action, scholars and sustainability professionals are now able to assess the effectiveness of standardisation and certification as a means of addressing sustainability and social issues. The persistence of so many social and environmental problems, despite the proliferation of standards, has led a number of scholars to conclude that they have been unable to address these issues substantially (Ponte et al., 2011: 300). While those focused on protecting ‘common’ natural resources, such as fisheries and forestries, have enjoyed a greater degree of success (King & Lenox, 2000; Sharma et al., 2010), the majority of those in other industries have failed to deliver. The apparel industry is a prime example: despite its vast array of standards and codes of conduct regarding labour practices, many scholars argue that they have failed to effectively address this issue, at best producing limited or inconsistent improvements (Locke et al., 2009; Esbenshade, 2012: 545-8).

This view is gaining increasing traction in the sustainability field among professionals and policy -makers also (Gjaltema, 2017; Fransen, 2018b). For example, Scott Poynton, a prominent sustainability professional in the forestry industry, argues that “certification schemes cannot and never will be able to deal with the growing number and diverse array of hugely difficult and extremely complex issues the world faces” (2015: 25). Even the late Jason Potts of the International Institute for Sustainable Development (IISD), described by his colleagues as a “visionary and leader in championing inclusive sustainability standards” (IISD, 2018), admitted in his lengthy meta-analysis of standards in numerous sectors that while they might be able to “offer an important contribution to the green economy… [they] cannot be assumed to deliver sustainable development outcomes.” (Potts et al., 2014: 9).

2.4.1 The Problematic Auditing Process

Critics argue that the enforcement process of standards is inherently flawed, and that this is a major obstacle to their effectiveness. Locke et al., for example, argue that the “information on which this entire system rests is by its very nature incomplete, biased, and often inaccurate and thus cannot serve as the basis for well-informed and reasoned decisions” (2009: 329). For example, scholars point out that auditors can rarely be classified as truly “independent”, as the nature of their relationship mean conflicts

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of interest inevitably arise (Locke et al., 2007). With regard to internal audits, both the brands and their suppliers have incentives to suppress violations, leading to issues of moral hazard. Meanwhile even with external, third party auditors, they still have an economic relationship with the company, and thus might refrain from revealing violations in order to retain future business (Esbenshade, 2004; Poynton, 2015; Greenpeace, 2015).

Even if one trusts the relationship between auditor and firm, the skills and expertise required to effectively audit multiple aspects of production, usually involving highly complex issues, are very high. Consequently, qualified auditors are in short supply, rendering them very expensive for firms to employ. This is compounded by more practical challenges, such as travel costs (especially for remote locations) and insufficient local knowledge. Seeking to save costs, they may therefore employ underqualified auditors, thus compromising the validity of the results (Locke et al., 2009: 322, 326; Poynton, 2015: 28).

The literature also emphasises the overly bureaucratic nature of the audit process, which undermines its effectiveness. Most audits are characterised by long checklists, capable of revealing only relatively superficial violations, without identifying the source of the problem. Moreover, managers can learn how to achieve compliance through the bare minimum, perhaps only improving processes leading up to and during the audit, or through tailoring their records in order to comply with these checklists (Locke et al., 2009: 328). Scholars also argue that “more aggressive, rule-based, legalistic enforcement practices sometimes discourage rather than encourage responsible behaviour among corporations” (Bardach & Kagan, 1982; Locke et al., 2009: 327).

As a result of this lack of independence, insufficient auditor skills, and over-bureaucratisation of the audit process, one can argue that the integrity of audit results, on which the effectiveness of standards rely, can therefore be called into question, thus undermining standards’ ability to achieve sustainability.

2.4.2 Failure to achieve industry transformation

In addition to these flaws in the assurance process itself, scholars and professionals have also highlighted numerous other flaws in the standards system in general, which severely undermines its role as a vehicle of industry sustainability.

Critics also argue that standards fail to bring about real industry transformation and stifle innovation (Verburg, 2015). With their emphasis on strict rules and box-ticking, Poynton argues that they lack the flexibility to allow companies to “find their own way”, think outside the box and find innovative new ways to achieve sustainability. Given that many firms seek certification for the sake of reputation or risk management considerations, they lack the incentive to really transform their systems or seek new approaches, only doing so sufficiently to meet the standard, even if they could go further (Poynton, 2015: 26-27). Moreover, Locke et al. (2009: 326-27) emphasise that while the audit process might

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highlight areas for improvement, they do not always help identify the root causes of these problems, and therefore penalised firms may not always know how to address these issues.

Moreover, certification usually increases costs for firms wishing to be certified, either because more sustainable processes and practices are themselves more costly to run (at least in the short-run), or because the firm has to invest time and resources in the bureaucracy that the process entails, and sometimes bear the burden of paying the auditor themselves (Potoski & Prakash, 2005a). This deters many suppliers from aspiring for certification, especially for small producers or if their margins are already tight, while buyers may also be deterred by the subsequent higher price for certified goods to offset these costs (Potts et al., 2014: 323). Consequently, only those who can afford it, i.e. the “lowest hanging fruit”, embrace it (Potts et al., 2014: 92), therefore only a relatively small market share, around 10 percent for most sectors, of companies do so (Poynton, 2015: 30-31). This low uptake demonstrates the inability of standards, despite several decades in operation, to bring about industry-wide transformation. Meanwhile the small-scale suppliers who wish to be certified almost always have to receive financial assistance in order to do so (Martin, 2013: 18; Potts et al., 2014). Critics highlight that such investments of resources in certification carries a significant opportunity cost, arguing that this time and money could be used more effectively to achieve sustainability, such as investments in capacity-building or addressing the root causes of the sustainability problems (Locke et al., 2009; Poynton, 2015; Innovation Forum, 2015).

2.4.3 Duplication and Audit Fatigue

This is exacerbated by another deficiency of standards: the problem of duplication, raised as a significant issue in a recent symposium on sustainability and standards (Gjaltema, 2017). In many cases, multiple standards or codes of conduct may exist in the same sector for the same issue (Jenkins, 2001; Locke et al., 2007; Derkx & Glasbergen, 2014). As a result, individual suppliers serving multiple buyers will often be asked to meet different standards by different buyers, resulting in confusion, inefficiency and “audit fatigue” due to multiple audits in a short time-span, and “compliance limbo”, as they are caught between complying with different and contradictory requirements (Locke et al., 2007: 6). This inefficiency leads to a significant waste in time and resources as factory managers have to prepare for multiple audits, which not only could have been used for more useful sustainability purposes, but also generates antagonism towards sustainability initiatives within the factory. This confusion may also be extended to consumers, who may not be able to recognize or discern the differences between multiple labels (ITC, 2017).

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3. Methodology

This paper represents an exploratory case study of a relatively recent trend in the field of VSIs towards alternative approaches to standards that seek to go ‘beyond compliance’. It will therefore primarily take an inductive approach, beginning with observations from which various explanatory possibilities are considered and theory is developed. However, where possible, findings will be tested deductively against existing theory, such as the criticisms of standards, for example.

3.1 Case Selection 1

The apparel industry was chosen because it exhibits this trend noticeably; while similar developments might be occurring in other industries, focusing on this exaggerated phenomena in a single industry will allow a deeper investigation into the phenomenon, allowing one to develop a more substantial understanding of it, from which theory can be generated and tested in other industries. However, as an extreme case, this lowers the probability that it is representative of the wider population of other industries (Gerring & Seawright, 2007). Furthermore, while every industry has unique characteristics, thus limiting the overall generalisability of these findings, the apparel industry has a number of characteristics that are common to other industries, such as: long, complex and far-flung supply chains, in which most of the worst environmental impacts occur; a buyer-led, ‘hourglass-shaped’ value chain structure; and sensitivity to consumer demands, to name a few. Therefore while the findings might not be wholly generalisable, they could nevertheless provide clues and lessons for other industries.

3.2 Elements of Study

This study takes VSIs, both standards-based and not, as its unit of analysis, while primarily seeking to observe why they take the approaches they do. The population of standards is discussed in Chapter 5, while the non-standards-based VSIs consists of VSIs operating in the apparel industry that meet the following criteria: (1) they explicitly address environmental issues, although often they might address social issues also; (2) they involve the collaboration between more than two companies or NGOs and is open to more members, and therefore excludes unilateral initiatives and bilateral partnerships; (3) they seek to govern their participating members, trying to steer their actions or behaviour towards specific ends. Lacking systematic records or a database of such initiatives, this population had to be constructed by the researcher through extensive web searches and snowballing, before being cross-checked and verified with interviewees. The population identified is presented in Table 5.2, in Chapter 5.

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However, one must acknowledge that there is no way of knowing that this population is complete and perfectly representative, some initiatives perhaps being overlooked. Given that none of the interviewees were familiar with all of the initiatives presented to them, while simultaneously emphasising that “there are so many” (Krol, interview; Carriere-Pradal, interview), we cannot know for sure that more initiatives exist. Indeed, only those with a web presence in English would have been revealed, which reduces the likelihood of detecting those developed by actors in the Global South, for example. Moreover, older initiatives (from over a decade ago) which could now be defunct would be less likely to be revealed through these searches. Nevertheless, by cross-checking those found with the interviewees we can be reasonably sure that the most important VSIs have all been identified, and that the population presented represents a wide range and diversity of VSIs active in the apparel industry, even if it is not a perfectly representative sample.

3.3 Data Collection

In seeking to answer the research question and sub-questions, this paper relies on primary data gathered from both qualitative semi-structured interviews and online resources. The researcher carried out five interviews from April to early June 2018 with relevant individuals working for these VSIs: one from a standards-based initiative (Bluesign) and four from non-standards-based VSIs (see Appendix). As professionals directly involved in making the industry more sustainable, they are well-placed to comment on the trend under investigation, while also being able to provide a deeper understanding of how their initiatives work. The use of semi-structured interviews allows room for probing, follow-up questions and the adjustment of the question sequence, which is especially conducive to developing a deeper understanding of the initiatives’ unique characteristics and rationales for their approaches, while also being more appropriate for an exploratory study. While the researcher also sought to carry out interviews with relevant individuals from brands and retailers in order to understand this trend from the corporate perspective and widen the scope for cross-referencing, none were willing to be interviewed due to the abundance of interview requests they receive from students. Unable to hear their perspective directly, the researcher sought to access it indirectly through the use of online resources, such as company websites and interviews with publications, and by asking interviewees what they thought brands’ perspective was.

There are several drawbacks of this approach which must be considered. Firstly, the semi-structured nature of the interviews reduce the reliability of the research in terms of replicability. Furthermore , interviewees’ personal biases towards their VSI’s particular approach over others’ may distort the data collected from interviews, which may compromise its validity. Moreover, less senior or experienced individuals are more likely to have incomplete knowledge of why their initiative took the approach it did, as well as of the wider trends in the industry. In order to combat this, the paper will seek to cross-reference their statements with other interviewees and sources as much as possible. In addition, the fact

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that three of the interviewees were based in other countries meant that their interviews had to be conducted via telephone, which reduces the ability establish rapport with the interviewee and take in contextual and nonverbal data, while also giving rise to occasional communication problems, which at times impaired the researcher’s ability to probe and subsequently analyse the data

Moreover, while one would ideally be able to study all or a majority of the programs and relevant actors, especially given the small population, in order to gain a more comprehensive understanding of the phenomena, this unfortunately is not possible. On the one hand, the abundance of data generated from interviews places limits on the number of interviews that can be effectively analysed within certain time constraints. On the other hand, many of these initiatives are run by a minimal amount of staff with heavy workloads in order to save on costs, meaning that the majority of those contacted declined being interviewed due to lack of time, This therefore threatens the external validity of the results, as one cannot be sure if the responses of these interviewees are representative of other actors in their category. In addition to interviews, this paper makes extensive use of secondary online resources, including: the websites of each VSI, companies and other related organisations; articles from online outlets, especially major apparel- or sustainability-focused publications such as Eco-Textile News and Triple Pundit respectively; and industry reports. In addition to being used for cross-referencing purposes, they are especially useful for providing information about the VSIs themselves in the absence of interviews, and are therefore heavily used in the construction of the tables and their subsequent analysis in Chapter 5, while also providing information on trends and discourse in the industry more generally. Moreover, some contain interviews and opinions from key individuals in both the VSIs and brands and retailers, therefore providing an alternative, albeit inferior, route to understanding their rationales in the absence of an interview. While most can be deemed to be reliable in terms of the factual information they present, one must be wary that they may not provide a complete picture and cannot be probed, therefore making interviews a more useful source of information. Additionally, the unsystematic nature of using online resources reduces the reliability of the findings in terms of replicability.

3.4 Case Selection 2 (Sub-Question C)

The cases used to answer the third sub-question in Chapter 7 were selected through purposive sampling. This was in order to ensure that all three ‘direct’ and both ‘facilitating’ approaches to sustainability were covered, and to ensure that a range of characteristics are represented. This was achieved despite problems with accessing interviewees from certain VSIs. For example, the SAC was selected due to the fact it is the largest VSI in the industry while featuring innovative approaches to sustainability such as its value-chain index; Race to the Top represents a smaller, NGO-led, on-the-ground capacity-building approach; while SCAP involves a medium-sized initiative with a target-setting approach. These case studies allow a deeper investigation into three of the main approaches taken by non-standards-based VSIs, shedding light onto mechanisms by which they seek to bring about industry transformation,

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govern the behaviour of their members as well as their respective advantages and disadvantages. However, this case selection approach has significant limitations: for example, the uniqueness of each VSI limits the findings’ generalisability, both to other VSIs in the apparel industry and more generally for other industries as well.

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4. Background: The Apparel Industry

The apparel industry, comprising the manufacturing and selling of textiles, garments and footwear,is one of the world’s largest consumer industries, being valued at $1.5 trillion and producing around 62 million tons of apparel products in 2016. It is also growing rapidly, having doubled in size between 2000 and 2014, and, with global population growth and the expected entry of around 3 billion people to the world’s “middle class”, it is expected to grow by a further 30 percent by 2030 (GFA, 2017).

However, for decades, few realised the full extent of the impact of the apparel industry on the environment, with the spotlight falling heavily on their labour practices instead (Solidaridad, 2012: 12-13; Wicker, 2017; Ekberg, interview). Environmental sustainability was primarily confined to the realm of niche brands or product ranges. In the mid-2000s, organic cotton started to rise on the agenda, especially with commitments from Nike and Patagonia to only source such fibres (ITC, 2008). However, as awareness of the industry’s wider environmental impact increased, only over the last decade or so has it really become a salient and pressing issue in the industry (McKinsey, 2016; Ekberg, interview; Murphy, interview).

Before proceeding with the empirical findings and analysis, it is important first to specify the main stages of the apparel industry’s value chain and the types of environmental impact each stage has: these are presented in Table 4.1. This allows us to understand the main issues that need to be addressed and at which stages of the value chain they occur. This will be followed by a discussion of other important features of the apparel industry, including its power dynamics and prevailing business model.

4.1 Value Chain Structure and Environmental Impacts

The environmental impact of apparel is clearly enormous, especially in terms of water use, water pollution, energy use, air emissions, hazardous chemical use and waste production, as Table 4.1 reveals. For example, in total, the apparel industry used 76 trillion liters of water in 2016, according to the Global Fashion Agenda, which is forecast to increase by a further 50 percent by 2030 (GFA, 2017: 11), while approximately one fifth of the world's total freshwater pollution results from textile treatment and dying (Maxwell et al., 2015: 17). Moreover, according to Quantis’ World Apparel and Footwear Lifecycle Database, the industry is responsible for about 5 percent of all total global emissions, which roughly equates to the total emissions of the aviation industry or the entirety of Russia (SBT, 2017). Left unchecked, these impacts can have grave consequences for both local communities and local ecosystems, as well as the globe more generally.

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Table 4.1. Environmental impact of stages of the apparel value chain. Stage of Value Chain Main Environmental Impacts

Design Specifies:  Choice of textile material  What treatment processes needed  How material is cut/assembled

 80-90% of environmental impact of product is determined by the designer (Graedel et al., 1995)

 50% of garment’s environmental impact determined by material choice (GFA, 2018)

Fibre Production Natural fibres:

 Cotton (48% of all fibres)

 Wool, silk, flax, jute, hemp

 Cotton production requires 10,000-20,000 litres of water to manufacture produce 1 kilogram of cotton

 Many cotton-producing countries (China, India and Pakistan) already facing water scarcity problems  Cotton production leads to significant non -point source

pollution – accounts for 10% of agricultural chemicals

and 25% of all insecticides (Maxwell et al., 2015: 11, 13, 15) Synthetic fibres:  Polyester (45% of all fibres)  Viscose, nylon, acrylic

 Polyester production produced 706 billion kg of

greenhouse gases in 2015 (Kirchain et al., 2015: 17)

Production Processes

1. Yarn production 2. Fabric production 3. Pre-treatment 4. Dyeing and printing 5. Finishing treatments 6. Manufacturing

 Together, uses 5 trillion liters of water per year  Approx. 20,000 chemicals used throughout (Murray,

2016)

 10-20% of chemicals, dyes and bleach released as

untreated wastewater

 Approx. 20% of the world's total freshwater pollution results from textile treatment/dying

 Dying houses in India, Bangladesh and China have severely depleted and polluted local water supplies  Significant energy use and air pollution

 Needed to heat water and power machinery  E.g. Chinese dying/textile factories use around 15

million tonnes of coal per year (Chadha et al., 2014), producing approx 3 billion tons of soot (NRDC, 2016)

 Manufacturing – 15% of material is wasted (Maxwell et al., 2015: 17)

Marketing/Retail

Consumer Use  Washing  Post-purchase washing/drying at high temperatures accounts for around 60% of energy used in the life-cycle of a cotton T-shirt (Claudio, 2007: 453)

 Washing releases 500,000 tonnes of plastic microfibres into the world's waterways and oceans per year (Reuters, 2018)

Disposal  Landfill  Incineration  Reuse / Recycling

 73% of clothes sent to landfill or are incinerated (Morlet et al., 2017: 20)

 Average of 30kg of clothes per person every year in the US and the UK (Martin, 2013)

 In China, total amount of textiles wasted before/after consumer-use is approx. 26 million tonnes per year (Dean, 2015)

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We therefore see that the vast majority of these environmental impacts arise early on in the value chain: during the production of raw materials (both cotton and polyester) and the production processes, especially the dying and finishing processes. Brands and retailers, however, usually only perform the intangible, highest value-adding activities, notably design, branding, marketing and retail of the products, choosing to outsource the low-value-added, labour-intensive physical production of the products to a network of suppliers. Yet they often only know their tier-one manufacturers to whom they stipulate various garment specifications, but otherwise delegate to them the responsibility of purchasing the inputs and coordinating the majority of the production process (Gereffi & Frederick, 2010: 15). It is therefore more difficult for them to influence the behaviour of companies beyond their tier-one suppliers (PRI, 2017).

4.2 Importance of Brands and Retailers

Nevertheless, major brands and retailers in particular are usually viewed as the key to transforming the industry (Dauvergne & Lister, 2013). On the one hand, this is due to their immense power in terms of both revenues and market share, allowing them to exert their influence over a multitude of sma ller suppliers. Indeed, according to Gary Gereffi, one of the world's foremost scholars of global value chains, describes the apparel industry as "the quintessential example of a buyer-driven production chain marked by power asymmetries between the producers and global buyers of final apparel products" (Gereffi & Frederick, 2010: 11). Moreover, their consumer-facing position in the value chain makes them more visible than their supply chain partners and more sensitive to changes in consumer preferences, and are therefore more vulnerable to being targeted by activist NGOs and governments for transgressions in their supply chains (Bartley, 2007).

4.3 Fast Fashion Business Model

They are also responsible for the ascendency of ‘fast fashion’, a business model characterized by drastically shortened fashion cycles and mass consumption, especially in Europe, North America and Japan, that has dominated the mainstream fashion industry since the early 1990s. This is made possible by just-in-time sourcing, compressed lead-times and rapid inventory turnovers in order to ensure low costs and flexible supply chains (Turker & Atluntas, 2014). Moreover, rapid incorporation of consumer preferences into the design process using real time data ensured that apparel companies could compete not only on price, but also on constantly seeking to offer the “newest” trends (Christopher et al., 2004). As a result, the number of fashion cycles has increased to over fifty in a year, from just two under the “traditional” model, while consumers now keep garments for half as long in 2014 as they did in 2000, according to the World Resources Institute (WIR, 2017).

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This business model is highly unsustainable, given the degree to which it expands production unnecessary and generates significant waste: as McKinsey’s ‘State of Fashion’ report emphasises, the fast fashion model “magnifies fundamental problems for the fashion industry” (McKinsey, 2016: 33). Moreover, it often leads to situations in which lead firms demand that a supplier use more sustainable practices, while simultaneously putting them under significant pressure to produce goods at increasingly low prices with ever-shorter lead times, which often requires cutting certain corners in sustainable practices to achieve. Thus even if a supplier makes sustainable investments, if this impacts the price, quality or responsiveness, this can deter buyers, who may switch to a cheaper, more responsive supplier elsewhere (Locke et al., 2009: 328-29).

This chapter has highlighted a number of the most important issues that need to be addressed in order to make the apparel industry more sustainable, not only terms of the specific impacts and where they are caused, but also in how the structure, dynamics and business model of the industry exacerbates these impacts. Crucially, it explains the importance of major brands and retailers in this process. This will help us understand how various VSIs go about seeking to make the industry more sustainable.

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5. Illustrating the trend

Standards relating to environmental sustainability are not absent from the apparel industry: far from it. For example, the Ecolabel Index lists around 100 standards and labels that can be used by apparel companies in order to improve and demonstrate some aspect of their environmental performance at some stage in the value chain while both the Eco-Textile Labelling Guide 2014 and ITC’s Standards Map list around 60 sustainable textile labels and standards (Standards Map, n.d.; Ecotextile News, 2018). Such figures are misleading, however: of those listed, many are country-specific standards; are more socially-oriented with some environmental criteria; or are for specific products or materials, such as wool, leather or down. Moreover, these figures provide little information about the how much of a company’s environmental performance is covered, nor the extent of uptake of these standards in the industry, and how far they are still active and relevant since their foundation.

A better starting point is the list compiled by Made-By, an apparel-focused sustainability NGO and consultancy, which spotlights eleven of the most important environmental standards for apparel companies relating to the production processes (Made-By, n.d.. In addition, four main standards have been developed relating to cotton production specifically, as identified by both the Sustainable Cotton Ranking, a research group, and the 2014 IISD report reviewing standards operating in major commodity sectors: two multisector standards, Fairtrade and Organic, and two sector-specific initiatives, the Better Cotton Initiative (BCI) and Cotton made in Africa (CmiA), both of which were established in 2009 (Potts et al., 2014; SCR, 2017). These have been compiled and presented in Table 5.1., featuring their characteristics, what they address, their originators and their market uptake.1

Meanwhile the results of the research into non-standards-based VSIs in the apparel industry are presented in Table 5.2. In addition to presenting the population found in this research, the table focuses on three core aspects: their functions; which environmental issues they are seeking to address, and at what stages of the value chain; and the basis of the initiatives, in terms of convening actors, current membership and other important affiliations. The purpose of this section is to show that there has been a clear trend away from using standards as the main collective approach to addressing sustainability issues in the apparel industry, and towards using alternative approaches. This trend is evident along four axes: 1. chronology, in terms of when new initiatives have been founded; 2. originators of the initiatives, i.e. whether the impulse came from within or outside the industry; 3. market coverage of the initiatives; and 4. Sustainability coverage i.e. what proportion of the environmental impacts and stages of the value-chain are addressed.

1_{Of the cotton standards, only Better Cotton has been featured, given that the others all have a market share}

of less than 1 percent of cotton production (SCR, 2017: 6). Similarly, from Made-By’s list, the ISO 14000 standard has been omitted due to the fact that i t only certifies the presence of an EMS, while Blue Angel and Nord Swan have been omitted due to their limited geographic scope of mainly German and Scandinavian companies respectively.

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Table 5.1. The main environmental standards used by apparel companies: characteristics, issue areas, origins, market uptake

Name Ye ar Type Assurance Me chanism(s) (all third-party) Stringency Main Sustainability Issue(s) Main Life-Cycle Stage(s) C onvening Actor (non-apparel specific) Marke t Uptake (Made -By)

Marke t Figures O ther Information

O EKO -TEX® Standard 100

1992 Performance-based Consumer label

End-product testing Low Chemicals Production Processes OEKO-T EX® Association High 10,000 companies STe P by O EKO -TEX® 1995 Practice-based B2B certification Self-assessment Facility audits

Gradated All Fibre Production Production Processes

OEKO-T EX® Association

Low 32 factories (2015)

NATURTEXTIL iVN ce rtified BEST

2000 Content verification Practice-based B2B certification Consumer label

Facility audits High Chemicals Water Use & Pollution Waste Fibre Production Production Processes iVN (International Association of Natural T extile Industry)

Low Under 100 companies, mainly in Europe

Organic textiles only

Bluesign Standard 2000 Practice-based B2B certification Consumer label

Input -stream management Facility audits

High All (especially chemicals)

All Bluesign T echnologies High 58 brand partners 500+ manufacturers 140 chemical suppliers (40-50% of market) Global Organic Te xtile Standard (GO TS) 2005 Content verification Practice-based B2B certification Consumer label Facility audits Chain of custody (segregation) Medium Chemicals Water Pollution Fibre Production Production Processes

iVN High 4642 facilities (2017) Organic textiles only Global Recycle Standard (GRS) 2008 Content verification Practice-based B2B certification Consumer label Facility audits Chain of custody

Medium All Production Processes Control Union Certification

Medium Approx. 900 factories Only for products with recycled content Be tter C otton Standard 2009 Performance-based Commodity certification Self-assessment Farm audits Chain of custody (mass-balance system)

Low Water Use & Pollution Chemicals

Fibre Production Better Cotton Initiative (BCI) NA 12% of global cotton production (2016) C radle to Cradle Certified™ 2010 Practice-based Consumer label Design assessment Facility audits End-product testing

Gradated All (especially waste) Design Production Processes Cradle to Cradle Products Innovation Institute Low 33 apparel/textile-related products EU Eco-Labe l: Te xtiles and footwear 2014 Performance-based B2B certification Consumer label Self-assessment Facility audits

Medium Water Pollution Chemicals Air Pollution

All European Commission Medium Less than 50

companies

European products only

Voluntary Sustainability Initiatives in the Apparel Industry: the Trend towards ‘Beyond Certification’ Approaches to Sustainability