Gesamtverband der deutschen Textil- und Modeindustrie e. V.

Germany’s medium-sized energy-intensive industry is facing a historically unprecedented crisis, leading not only to the outward movement of production, but also to plant closures and job losses. Energy-intensive small and medium-sized enterprises are committed to the European Union’s climate goals and want to follow this path by 2050.

Filed in German · English published by the European Commission

The CBAM (Carbon Border Adjustment Mechanism) is a completely new measure that has not yet been tested and is incomplete in its design. In its current form, it risks jeopardising the competitiveness of European industry and not providing effective protection against carbon leakage. A substantial improvement of the mechanism is urgently needed to achieve its objectives.

Filed in German · English published by the European Commission

The Confederation of the German Textile and Fashion Industry (t+m) welcomes the European Commissions commitment to reducing administrative burdens within environmental legislation. As a key industrial sector for Europes circular transition, the textile and fashion industry requires a coherent, practical, and economically viable regulatory framework to successfully deliver circularity in practice.

The proposed DPP registry introduces an additional centralized registration requirement alongside existing regulatory frameworks and registries, such as those within the context of Extended Producer Responsibility (EPR).

The EU’s main goal in the area of energy and climate policy is climate neutrality by 2050. The only instrument needed to achieve this objective is the EU Emissions Trading System (EU ETS), as it securely achieves a clearly defined climate target while being efficient.

Filed in German · English published by the European Commission

textil+mode (t+m), representing the German textile and fashion industry, welcomes the opportunity to contribute to the evaluation of the Biocidal Products Regulation (BPR). While supporting the BPRs objectives, we highlight key challenges for textile downstream users regarding predictability and transparency of regulatory processes, availability of approved active substances for critical applications (including…

textil+mode supports the objective of protecting children from CMR 1A/1B substances in childcare products. Our comments therefore do not concern the objective of the proposal, but its practical implementation. As set out in the attached statement, the proposed restriction should be revised to ensure that it can be implemented by companies and enforced by authorities.

Textil+Mode (t+m), representing the German textile and fashion industry, welcomes the opportunity to comment on the proposed amendment to Regulation (EU) 2019/1021 on long-chain perfluorocarboxylic acids (C9C21 PFCAs), their salts and related compounds. We identify key issues regarding regulatory coherence, scope alignment with the Stockholm Convention and enforceability.