The TXT BREF defines Best Available Techniques, and the emission levels or energy use associated with them for textile production in the EU.
Most clothing consumed in the EU is imported, therefore the TXT BREF has no direct impact on its production. However, the EU is a major manufacturer and exporter of other types of textiles: home textiles (e.g. curtains or sofa covers), covers for car seats, carpets, medical and many other specialised technical textiles.
The TXT BREF deals with all dyeing and surface-treating process steps (easy ironing, flame retardancy, water repellency etc.), but not with the production of the fibres (whether vegetable, animal or mineral – the latter are the object of the WGC BREF.
Although the TXT BREF is European in scope, its impact isbroader, as European BATs are often used as benchmarks in international processes and guidelines. At the current draft stage, the TXT BREF is still not up to date or it is less ambitious than standards in other countries, or less ambitious than broadly accepted industry standards. This situation is obviously not satisfactory.
Process and status
The BREF adopted under the IPPC Directive was finalised in 2003. Its revision was started in 2018 and a first draft was published in December 2019, on which EEB extensively commented. The final adoption is planned for 2022, which means that its prescriptions become binding at the latest in 2026.
The textile industry uses a high amount of energy and generates a high amount of waste water; it is estimated that worldwide, the textile industry generates 8% of GHG and 20% of industrial wastewater, and cotton production uses large amounts of pesticides, water and fertilisers.
The textile industry is also indirectly responsible for another environmental time bomb: microfibres released from synthetic textiles (in production, use, and waste stages) are released to surface water, further destabilising already heavily stressed ecosystems.
It is estimated that 1 kg of textiles requires almost half a kilogram of chemicals on average: a large part of these chemicals ends up in the effluent of the processing plants. The impact on the environment can be eliminated or strongly reduced by:
- Reducing the amount of chemicals used (e.g. by getting a higher percentage of a dye to stay on the fabric)
- Substituting hazardous chemicals
- Using better abatement techniques (e.g. water treatment facilities).
It is about hazardous chemicals, but not only: one of the highest volume chemicals used in the textile industry is starch. This is not a hazardous chemical, but if it is released into a river without treatment, algae will thrive and most other aquatic life will die. Substitution of hazardous chemicals is mandated by the IED.
Emissions to air and energy consumption are also important: for many processes, the textile industry uses stenters (long ovens in which surface treatments may be cured and solvents driven out) powered mostly by natural gas. Stenters are the source of the usual air pollutants from combustion (such as NOx), but also of the other chemicals used in the process.
The BATs and BAT-AELs
The BREF contains hundreds of pages of descriptions of processes, chemicals, materials and efficiencies. However, the most impactful part of the BREF is its part 5, which sets the binding BAT and the BAT-AEL emission levels.
At the current draft (D1) stage, this section lacks both ambition and transparency:
- Footnotes add derogations without either a proper justification or a safety net (see e.g. EEB comment #174)
- Many BAT-AEL ranges are very broad, providing little incentive for continual improvement (see e.g. EEB comment #186)
- BAT-AELs are derived based on data collected by questionnaires. In some cases, the questionnaires contained technical errors (see e.g. EEB comment #66). In other cases, the collected data are obviously of substandard quality (see e.g. EEB comment #156), but those data points are not removed from the dataset!
- The BREF text does not reveal why a certain BAT-AEL was set to e.g. 100, rather than 80 or 120 (see e.g. EEB comment #163). Documents with the ambition to be evidence-based and transparent should go further than this.
- Some positive aspects are a dedicated BAT-C section on the substitution of chemicals of concern and chemicals management, and the definition of a toxicity parameter for effluents, however need to be tightened on several aspects.
Jean-Luc Wietor, Senior Policy Officer for Industrial Production: Jeanfirstname.lastname@example.org