EURATEX

EURATEX welcomes the opportunity to contribute to the Commission consultation on revising the Public Procurement Directives. We strongly support the priorities of simplifying procedures, facilitating SMEs participation in tenders, strengthening green, social, and innovation criteria, and introducing European preferences for strategic sectors, which incentivise EU-based, reliable value chains from fibre to finished…

EURATEX acknowledges the progress made by EU public procurement directives but highlights persistent challenges, particularly for SMEs and specialized industries like textiles. Simpler and more flexible rules for SMEs Achievements: ESPD and digitalization have reduced administrative burdens. Challenges: Complex procedures and rigid selection criteria still hinder SMEs.

EURATEX, representing the European textile and clothing industry, welcomes the initiative to establish a voluntary 28th regime corporate framework. We support its aim to allow companies, including innovative ones, to operate across the Single Market under a single, harmonised set of rules.

EURATEX appreciates the opportunity to provide feedback on the Waste Framework Directive revision proposal. EURATEX welcomes the proposal for a targeted revision of the WFD and the EU regulatory efforts to solve the textile waste problem, both to reduce waste and to enable textile waste recycling.

EURATEX actively supports the European Commission’s political commitment towards circular economy and the revision of the Waste Framework Directive (WFD) and welcomes the objectives of the initiative to improve the waste management and the harmonisation of separate waste collection rules across EU. To extend the lifespan of textiles, an appropriate collection system must first be established.

EURATEX, the European Apparel and Textile Confederation representing the interest of the European textiles and clothing industry, understands the importance of establishing transparent and accountable value chains. However, key factors must be met for the the Directive to be workable. EURATEX critically stresses the following recommendations: - Harmonisation is key to ensure an EU-wide level playing field.

EURATEX welcomes the objectives of the Green Claims proposal to provide a level playing field for businesses, tackle green washing and help consumers to make informed decisions regarding the environmental impacts of products placed on the EU market.

EURATEX supports the efforts of the European Commission to improve the sustainability of products that circulate in the European internal market through the Ecodesign Requirements for Sustainable Products Regulation proposal. However, there are critical points that require attention and revision for the regulation to be workable in the textiles industry.

The European textile and clothing industry is committed in supporting the EUs climate neutrality objective for 2050. The goal of the Carbon Border Adjustment Mechanism (CBAM) is crucial in ensuring that the EUs climate policies are not undermined by carbon leakage, and that industries globally are held to similar environmental standards.

Feedback to the Commission consultation on the CLP revision 30 March 2023 As the Classification, Labelling and Packaging (CLP) Regulation is one of the cornerstones of the EU chemicals legislation along with the REACH Regulation, it is imperative that the revision will improve the current CLP while not creating unnecessary regulatory burden or rules which in practice would not be implementable or hamper the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EURATEX, the European Apparel and Textile Confederation representing the interest of the European textiles and clothing industry, perceives the Industrial Emissions Directive proposal for review as greatly concerning.

Recognition of qualifications and skills of third-country nationals is increasingly relevant to the textile and apparel industry because demographic change, persistent shortages and the pace of industrial transformation are tightening labour markets in several regions and occupations. Skills portability policy that excludes third-country nationals risks missing an important dimension of labour market functioning.

Skills portability in the European textile and apparel industry is constrained less by the willingness of workers and employers to engage cross-border, and more by the practical difficulty of making skills and qualifications legible, comparable and trusted across national systems. A credible approach to skills transparency and digitalisation should therefore start from the realities of the ecosystem.

The European Apparel and Textile Confederation (EURATEX) welcomes the European Commissions initiative to simplify administrative burdens in environmental legislation. The textile and apparel sector is committed to the transition towards a circular and sustainable economy, but companies are increasingly confronted with overlapping regulatory obligations, fragmented national implementation, and duplicative reporting…

Please find the position of EURATEX in the document attached. Summary: The textile and apparel industry recognizes that the protection of the climate is one of the most important challenges and tasks of mankind in our times.

EURATEX, the European Textile and Apparel Confederation representing the European textile and apparel industry, welcomes the opportunity to provide feedback on the Roadmap of the revision of the REACH Regulation. We support the aim of the Commission to improve the current text of REACH and pursue the objectives of protecting human health and the environment and promoting innovation for companies.

EURATEX welcomes the Commission proposal establishing the Digital Product Passport (DPP) Registry under the ESPR framework, at the same time, several clarifications are needed to ensure proportionality, legal certainty and operational feasibility for the European textile and apparel ecosystem, which is largely composed of SMEs.

EURATEX considerations on EC call for evidence “Measures aiming to reduce the presence in the environment of unintentionally released microplastics from tyres, textiles and plastic pellets” 18 January 2022 SUMMARY • • • • • EURATEX’s work has enabled real progress to tackle MP releases and built considerable knowledge, having engaged since 2017 EURATEX strategy to tackle microplastics is to find suitable solutions…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European textile and apparel industry welcomes the European Commissions intention to develop an Advanced Materials Act and supports its objective of accelerating innovation, manufacturing capacity and uptake of advanced materials in Europe.

EURATEX, the European Apparel and Textile Confederation, represents the interests of the European textile and clothing industry along the entire value chain from fibre producers and textile manufacturers to apparel companies and technical textile producers.

EURATEX, the European Apparel and Textile Industry Confederation, supports the objective of facilitating intra-EU shipments of separately collected textile waste for recovery. The proposed entry reflects collection practice and may reduce unnecessary administrative barriers, however: a. legal certainty is required regarding the continuing B3030 condition that textile waste must be prepared to a specification.

The European Apparel and Textile Confederation (EURATEX) welcomes the opportunity to provide feedback to the Commission's One Substance, One Assessment legislative package. Please find EURATEX's input in the attached document, which highlights our concerns around security of information, notification of studies, and tasks for the European Chemicals Agency (ECHA).

EURATEX, representing the European textile and clothing industry (over 200,000 companies and 1.3 million workers), supports a strong EU Market Surveillance Regulation (EU) 2019/1020 to ensure consumer protection, fair competition and trust in EU legislation. Our sector is highly globalised and increasingly exposed to unfair competition from non-compliant products entering the EU market.

ECHA founding Regulation Feedback to Commission’s Call for Evidence 10 October 2022 The European Apparel and Textile Confederation (EURATEX) welcomes the Commission’s public consultation to revise the governance of the European Chemicals Agency (ECHA) as outlined in the Chemicals Strategy for Sustainability (CSS).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EURATEX, the European Apparel and Textile Confederation, appreciates the opportunity to provide feedback to the draft Implementing Act (IA) on the details and format for the disclosure of information on discarded unsold consumer products. Building on our previous input to the development of the draft legislation, we would like to provide additional remarks in the enclosed file.

The European textile and apparel industry welcomes the initiative to simplify the Defence Procurement Directive. Strengthening Europes defence readiness requires procurement rules that secure resilient and autonomous supply chains for SMEs. Please find attached EURATEXs position paper in this call. Textiles are strategic enablers of Europes defence capabilities.

EURATEX, representing the apparel and textile industry in Europe, welcomes the opportunity to comment on the draft act amending Annex I to Regulation (EU) 2019/1021 on Persistent organic pollutants and would like to highlight that the POP Regulation for C9C21 PFCAs contains two points that clearly deviate from the Stockholm Convention and could be detrimental to our industry.

EURATEX welcomes the European Commission’s initiative to establish the Programme for Agile and Rapid Defence Innovation (AGILE). A dedicated instrument aimed at accelerating the development and uptake of mission-driven, high-impact technologies can make an important contribution to Europe’s defence readiness.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)