EQM Report

The Feasibility of a Voluntary

Ethical Quality Mark for the

Australian Textile, Clothing

and Footwear Industries

Ethical Clothing Australia

27 June 2011

Report Preparation

Authors: John Gertsakis Cameron Neil

Senior Sustainability Associate Senior Associate

WSP Environment & Energy Net Balance

Project Manager: Cameron Neil

Senior Associate

Net Balance

Project Director: John Gertsakis

Senior Sustainability Associate

WSP Environment & Energy

Status: Final Report


Report on the Feasibility of a Voluntary Ethical Quality Mark for the Australian Textile,

Clothing and Footwear Industries

27 June 2011

NB Ref: MMPJ10ECA142

Table of Contents

Report Preparation ......................................................................................................... 2

Executive Summary ........................................................................................................ 4

Introduction ................................................................................................................... 6

Methodology .................................................................................................................. 8

Research & Analysis ....................................................................................................... 9

1. Review of Ethical & Environmental Sustainability Compliance Programs .......... 9

2. Australian TCF Industries Stakeholder Consultations ...................................... 16

3. Justification of a Voluntary EQM Option ........................................................ 29

Roadmap Toward an Australian Voluntary EQM for TCF Production ........................... 33

Conclusions .................................................................................................................. 39

References .................................................................................................................... 41

Appendix A: Credibility Principles for Sustainable Production Compliance Programs .. 43

Appendix B: Selected Existing Certifications & Compliance Programs for Assessing Ethical

& Environmentally Sustainable Production in the TCF Industries ................................. 44

Appendix C: EQM Feasibility Study – Online Stakeholder Survey Questions ................ 50

Appendix D: Stakeholder Consultation Summary Data & Selected EQM Survey Finding

Tables 58

Interview Responses .................................................................................................. 58

Workshop Results ...................................................................................................... 61

Online Survey Data .................................................................................................... 64

Appendix E: Global Industry Sustainable Supply Chain Initiatives ................................ 71

NB Reference: MMPJ10ECA142 4

Executive Summary

The feasibility and appropriateness of establishing a voluntary Ethical Quality Mark for the

Australian Textile, Clothing and Footwear industries was assessed over the last six months. The

creation of a voluntary Ethical Quality Mark (EQM) was proposed in 2008 in a review of Textile,

Clothing and Footwear (TCF) industries commissioned by the Australian Government.

The TCF Industries Innovation Council commissioned Ethical Clothing Australia to undertake a

feasibility study and report on the appropriateness of a voluntary EQM, given there are existing

ethical and environmentally sustainable production compliance programs applicable to the TCF

industries. Two sustainability consulting firms with expertise in this area, WSP Environment &

Energy and Net Balance, were engaged to conduct the research and produce the report.

The feasibility of a voluntary EQM was assessed using two major streams of enquiry:

1. A review of existing ethical and environmental sustainability compliance programs

applicable to the TCF industries, as well as relevant global and local industry trends; and

2. Consultation with stakeholders from the Australian TCF industries through interviews,

workshops and an online survey.

Three potential options for a voluntary EQM for Australian TCF products were agreed prior to the

commencement of the study, and were tested during the stakeholder consultations and against

international eco-labelling and sustainable production practices. These options are:

Option 1 – Expansion of the current Ethical Clothing Australia (ECA) label to include

environmental/sustainability accreditation as an optional adjunct to the current labour

rights accreditation for the local TCF industries

Option 2 – Transformation of the current ECA label so that the primary focus of the new

label is on environmental/sustainability accreditation while still accrediting members for

upholding labour rights for the local TCF industries; and

Option 3 – Development of environmental/sustainability accreditation for the local TCF

industries that is separate from ECA.

Each option was assessed with a view to identifying the most desirable, effective and efficient

option to adopt and implement. Justification for the preferred voluntary EQM option is offered,

and a roadmap for moving the current system towards the most feasible voluntary EQM model is

provided.

The feasibility assessment recommends Option 1 as the preferred method for implementing a

voluntary EQM for the Australian TCF industries, in particular for the fashion and clothing sectors,

and potentially footwear.


Stakeholders in the Australian TCF industries see the potential value and role of a voluntary EQM in

helping to drive more sustainable production and assisting this sector in a competitive global

marketplace. There is particular support for an EQM in some product classes (e.g. clothing and

fashion) and from some stakeholder groups. Implementation of EQM Option 1 will need to address

specific supply chain and production issues (e.g. toxics, waste, carbon, water, and labour rights),

scope of the EQM, as well as how it would address ‘local’ versus ‘off-shore’ manufacturing (and

therefore associated auditing and performance verification processes). The preference for Option 1

reflects the value in integrating labour rights, product safety and environmental performance

across the supply chain, while retaining the current ECA label as a starting point. The broader EQM

ambitions of Option 1 could be implemented in a staged or modular manner.

While Option 1 is the preferred of 3 options for a voluntary EQM, there are dissenting opinions

from some stakeholders. Many stakeholders are non-aligned and sitting on the fence, needing

more information about scope, geographical coverage, and a much clearer business case. While

some believed it could hold potential, there was also a minority view that did not see sufficient

value across all TCF industries. Despite some stakeholders being neutral about the need for a

voluntary EQM, they did acknowledge that it may be more relevant in some TCF product categories

than in others.

There is however broad support for a range of activities (including a voluntary EQM) that can shift

the TCF industries towards a more engaged, informed and proactive mode of operation that

embodies improved and measurable levels of product safety, environmental performance and

labour rights protection.

Methods for funding the implementation of the preferred Option were specifically canvassed with

stakeholders as part of the online survey. While no particular method (e.g. royalties versus annual

application fee) emerged as a clear preference, there was an overt view that the cost of being

certified should be kept minimal and focused on cost-recovery. The importance of government

support to ensure independence and transparency also was considered important by stakeholders.

Depending on its agreed design and scope, a new voluntary EQM under Option 1 has the potential

to connect and harmonise with several existing certification schemes that are relevant to the TCF

industries. These schemes are typically product specific (e.g. carpet, upholstery textiles), or

process-oriented (e.g. organic, toxics). There are several existing schemes and standards from

Australia and overseas that could be referenced directly and incorporated into a voluntary EQM for

the Australian TCF industries.

It is also important to recognise that some product categories (and companies) within the TCF

industries are significantly advanced on certain aspects of environmental performance, product

safety and/or ethical considerations. For example, driven by demands of the Green Building

Council, the Carpet Institute of Australia has developed a comprehensive and widely adopted

industry facing environmental classification system.


Introduction

The purpose of this project was to assess the feasibility and appropriateness of establishing a

voluntary Ethical Quality Mark (EQM) for the Australian Textile, Clothing and Footwear (TCF)

industries.

The Australian Government’s response was to task the TCF Industries Innovation Council with

examining the feasibility and appropriateness of a voluntary EQM, given there are existing ethical

and environmentally sustainable production compliance programs applicable to the TCF industries.

A concern of Government was that any EQM take in to account the Homeworkers Code of Practice

(and the associated Ethical Clothing Australia label) and various State and Territory compliance

arrangements, and that its design and operation would “complement rather than add complexity to

the arrangements currently in place”.

The TCF Industries Innovation Council commissioned Ethical Clothing Australia (ECA) to produce a

feasibility study. ECA engaged WSP Environment & Energy and Net Balance, two sustainability

consulting firms with expertise in the area, to conduct the research and produce the report.

The research considered a voluntary EQM that:

• covers all issues of concern in TCF production (human health and safety, worker’s rights

and labour conditions, and environmental impacts)

• addresses more than just manufacturing, but also supply chains for fibres and materials,

and aspires to address product stewardship and post-sale use impacts

• is a tool for consumers to inform their choice of TCF products

• provides a competitive advantage in the market to companies and products that qualify for

the certification and use of the Mark

• is complimentary to existing schemes, in particular the Ethical Clothing Australia system;

and

• will reduce rather than increase complexity of existing arrangements.

This report provides an assessment for ECA by WSP Environment & Energy and Net Balance, of the

feasibility of establishing an Australian voluntary EQM for the TCF industries.

The opinion reached on the feasibility or otherwise is based on two streams of enquiry:

1. a review of existing ethical and environmental sustainability compliance programs

applicable to the TCF industries, as well as relevant global and local industry trends; and

2. consultation with stakeholders from the Australian TCF industries through interviews,

workshops and an online survey.


The report first provides more information on the methodology used to assess the EQM feasibility.

It then presents key findings from the review of existing compliance programs and ethical and

environmentally sustainable production trends relevant to the TCF industries. An analysis and

discussion of stakeholder opinions expressed through the consultations follows. The report then

discusses the feasibility of a voluntary EQM for the Australian TCF industries based on these

findings and the justification for choosing a particular EQM model. Frameworks for a way forward

towards an industry grounded in ethical and environmentally sustainable production are then

presented. The report concludes with some final thoughts and recommendations.


Methodology

Applied research methods including desktop research and literature reviews were used to

understand the ‘landscape’ of ecolabelling and sustainable production in the local and global

textile, clothing and footwear industries. This applied chiefly to the review and assessment of

existing certifications, standards and marks.

Mainstream methods of social inquiry were used for the stakeholder engagement aspects of the

study. This included online survey techniques, small-group workshops and face-to-face interviews.

Interaction and discussion was enabled and facilitated by the study team as a key workshop

objective.

The online survey was developed and deployed among stakeholders. A self-administered survey

approach was deemed appropriate and inclusive. Online stakeholder consultation was also adopted

to maximise efficiencies in relation to time, geography and overall project resources.

The workshops were based on an ‘appreciative inquiry’ approach with the aim of creating an

inclusive environment for discussion and debate. Grouping multiple and diverse stakeholders was

considered an important catalyst for issues identification and solution generation. The format

allowed for group-wide discussion as well as smaller break-out sessions.

The interviews were focused on direct and detailed discussions and exploration with individuals,

and provided the opportunity to further deconstruct views, opinions and preferences. Interviews

were conducted as face to face discussions or via telephone.

In summary, the key elements of the feasibility study included:

1. a review of existing systems and tools, as well as industry trends (December 2010)

2. consultation via survey, interviews, and workshops (March/April/May 2011)

3. an analysis of consultation findings (May 2011)

4. an updated review and industry trends (May 2011)

5. an assessment of feasibility and proposition of frameworks for progress (May 2011)


Research & Analysis

1. Review of Ethical & Environmental Sustainability Compliance Programs

This review considered a range of standards, certifications and other compliance programs and

initiatives which may be directly or indirectly relevant to the development of a voluntary EQM for

the TCF industries. It builds on the work completed in June 2010 by the Secretariat to the TCF

Industries Innovation Council on “A Voluntary Ethical Quality Mark for the Australian Textile,

Clothing and Footwear Industries: An Examination of Possible Design Components.” The review was

conducted in 2 stages, firstly in December 2010 and then updated in May 2011 to reflect new

activity and trends.

Compliance Programs Applicable to the TCF Industries

The certifications and programs considered in this review were from a number of sources including

the report in June 2010 by the Secretariat of the TCF Industries Innovation Council, web searches

for environmental and ethical/social accreditations and programs relevant to the TCF industries,

existing knowledge of programs by Ethical Clothing Australia, Net Balance and WSP Environment &

Energy, and via the Ecolabel Index (website: http://www.ecolabelindex.com).

Not all compliance initiatives were judged to be in scope. For example, the Ecolabel Index lists 78

initiatives applicable to textiles alone. They are more for buildings and building products, some of

which are applicable to the textiles industry (i.e. carpets, upholstery, industrial textiles). Many of

the programs are highly specific in terms of country of application or use, only relevant to some

parts of the supply chain or limited product application, etc.

The compliance programs reviewed in depth have a number of dimensions relevant to

consideration of the feasibility of a voluntary EQM for the TCF industries in Australia, and how such

an EQM would be best structured and achieved.


Existing schemes differ on the following dimensions:

• How they seek to intervene in production systems to achieve more ethical1 and

environmentally sustainable production: Many schemes take a product certification approach,

and label products based on their compliance along their supply chain with ethical and/or

environmental standards. Other programs are based on life cycle assessment of (almost

exclusively) environmental impacts. Some interventions are business support and engagement

processes that guide companies to continuously improve performance over time (including

Codes of Conduct). Finally, there are initiatives that provide reporting or measurement tools to

businesses. Each approach plays a role and has its own strengths and weaknesses.

• Whether they emphasise consumer facing or industry facing activities: Compliance programs

often employ consumer-facing labels as ‘pull factors’ for businesses to change their behaviour.

These are predominantly product certification, and to a lesser extent life cycle analysis,

approaches. Compliance with standards enables a company to sell products to consumers that

have agreed ethical and/or environmental features. Typical drivers are competitive advantage

in the marketplace. Alternatively there are schemes that focus on industry engagement and

participation, and seek to raise the standard across business performance, industries or

industry groups as a whole. Often such programs offer important information for business-to-

business transactions or inform annual reports to stakeholders. They also often inform choice

editing2 by retailers and other market intermediaries.

• Their ambition to cover all supply chain production issues: As many interventions have

emerged from responses to single issues in supply chains or production performance, it is

typical for compliance programs to be less inclusive rather than more inclusive when it comes

to their scope. Schemes typically focus on ethical or environmental issues, not both. However,

there are some exceptions and it is certainly the trend for approaches to work towards being

inclusive of both aspects. In most cases, interventions are ethical, with a little bit of

environmental, or vice versa. Truly comprehensive programs that cover all production issues

are aspirational at present.

1 References to ethical in the context of compliance programs encompass initiatives that address social production aspects, primarily

worker’s rights and labour conditions

2 Choice editing refers to voluntary removal by industry, including retailers, of unsustainable or less sustainable products from their

customer offer and providing in their place sustainable alternatives. The choice is removed from the customer to buy unsustainable

products.


• Whether they are explicitly focused on TCF industries or provide broader coverage of global

consumer goods or other sectors: While there are some programs that are specific to

companies operating in the textile, clothing and footwear industries, there are a myriad of

programs with applicability to TCF production systems that target a broader scope of business

sectors. For example, there are environmental management system certifications that are

generic to all forms of manufacturing, versus highly specific environmental requirements for

carpet production.

• How much of the supply chain from raw materials to finished consumer goods and beyond

they cover: There are often many steps in the supply chains for TCF products. Similar to the

coverage of production issues already discussed, it is the exception rather than the rule for

single compliance programs to provide full supply chain coverage from raw materials through

to finished consumer products. When environmental or social impacts of post-sale use by

consumers is considered, it is only company reporting schemes, such as the Global Reporting

Initiative, that provide a framework for complete supply chain coverage.

• How credible they are: While there are many compliance programs relevant to the TCF

industries, and many added every week, not all are equally credible. Credibility can be difficult

to define, and it is also highly dynamic as expectations and available options change.

Perceptions of credibility are typically tied to how convincing claims made by businesses using a

label or scheme are trusted or believed by stakeholders and customers. Compliance to

programs with multi-stakeholder governance or government support, public standards and

third party verification of claims is typically viewed as more credible in the marketplace. A

longer discussion of credibility principles, and why they are important, is included as Appendix

A.

The compliance programs reviewed are displayed in Table 1, indicating the features of each

program related to these above dimensions. Note that further details for each compliance program

considered can be found in Appendix B of this report, including mapping them to credibility

principles and applicable TCF supply chain coverage areas (the last two dimensions discussed

above).


Table 1. Compliance Programs Reviewed

Compliance Program Program

Origin

Intervention

Approach

Emphasis on

Consumer or

Industry

Facing

TCF Industry Focus

Ethical Production Compliance Programs & Certifications

Ethical Clothing Australia AU Company

accreditation Consumer TCF manufacturing

SA8000 Global Factory certification Industry

General

manufacturing social

compliance

Fair Wear Foundation Netherlands Code of Conduct Industry Apparel cut make trim

Fair Labor Association USA Code of Conduct Industry

Textile manufacture

and apparel cut make

trim

GoodWeave International UK Product certification Consumer Rug manufacturing

Business Social Compliance

Initiative Belgium

Business support &

engagement + Code

of Conduct

Industry General supply chain

Supplier Ethical Data Exchange

(SEDEX) UK Reporting tool Industry General supply chain

Better Work Programme /

Better Factory Program Global Tools & projects Industry General supply chain

Textile, Clothing, Footwear &

Associated Industries Award AU

Government

legislation Industry TCF manufacturing

ILO Conventions Global Government

framework Industry General supply chain

OECD Guidelines for

Multinational Enterprises Global Industry guidelines Industry General supply chain

ISO 26000 Global Industry guidelines Industry General supply chain

Ethical Trading Initiative UK

Business support &

engagement + Code

of Conduct

Industry General supply chain

Combined Ethical & Environmental Compliance Programs & Certifications

Global Organic Textile Standard

USA, Japan,

UK,

Germany

Product certification Consumer TCF supply chain

Fairtrade Mark Global Product certification Consumer Cotton production

Good Environmental Choice

Label Australia AU Product certification Consumer General supply chain

Made-by NL Product certification Consumer TCF supply chain

BMP Cotton AU Product certification Consumer Cotton production

Global Reporting Initiative USA Reporting tool Industry General supply chain

Sustainable Apparel Coalition USA

Business

engagement + tools

and projects

Industry Apparel supply chains

UN Global Compact Global Industry guidelines Industry General supply chains

Nordic Initiative Clean and

Ethical Nordics

Business support &

engagement + tools

and projects

Both

consumer and

Industry

Apparel supply chains

DFID Responsible & Garment

Sector Challenge Fund (RAGS) UK

Government funding

program Industry Apparel cut make trim


Compliance Program Program

Origin

Intervention

Approach

Emphasis on

Consumer or

Industry

Facing

TCF Industry Focus

Worldwide Responsible

Accredited Production USA Product certification Consumer

General

manufacturing

(apparel cut make trim

focused)

Environmental Compliance Programs & Certifications

Oeko-Tex 100, 1000, and 100+

standards

Austria,

Germany,

SUI

Product certification Consumer

Textile manufacture

and apparel cut make

trim

ISO 14001 Global Business process

certification Industry General supply chain

Certified Organic (various

organic certifiers) Global Product certification Consumer General supply chain

Eco-Index USA Assessment tool Industry Apparel supply chain

EU Eco-label EU Product certification Consumer General supply chain

Forest Stewardship Council Global Product certification Consumer General supply chain

The Australian Carpet

Classification Scheme -

Environmental Certification

Scheme

AU Product certification Industry Textile manufacture

and carpet production

Better Cotton Initiative Global Production

principles Industry Cotton production

The Design Accord USA Business

engagement Industry TCF design

Australian Packaging Covenant AU Life cycle

management system Industry General packaging

Environmental Choice New

Zealand NZ Product certification Consumer General supply chain

Blue Angel Germany Product certification Consumer General supply chain

MBDC Cradle to Cradle

Certification USA Product certification Consumer General supply chain

Ecospecifier Green Tag

Certification AU Product certification Consumer General supply chain

Carbon Reduction Label UK Product certification Consumer General supply chain

Australasian Furnishings

Research & Development

Institute (AFRDI Standard 146 -

Leather)

AU Product certification Consumer Leather production

Green Leader Program AU Business

accreditation Consumer General supply chain

DEFRA’s Sustainable Clothing

Action Plan UK

Government

program Industry Apparel supply chain

Bluesign SUI Business tools Industry Textile supply chain

Leather Working Group UK Business tools and

protocol Industry Leather production


As Table 1 clearly shows, there are many schemes and initiatives to navigate, understand and

connect with for a voluntary Ethical Quality Mark for the Australian TCF industries that seeks to be

‘complimentary to existing arrangements’. The introduction in recent years of the ECA mark

addressed a gap in the tapestry of schemes relating to ethical Australian manufacturing of textile,

clothing and footwear, and communicating this to Australian consumers. Beyond the ECA program,

there are well established schemes for different aspects of environmental pollution and

performance that can be applied to local or overseas manufacturing and also to retail and other

operational settings. There are also existing approaches for ethical manufacture overseas, and a

growing number of programs covering ethical and environmental aspects of raw material

production whether within Australia or abroad. Initiatives to address product stewardship and

consumer use/end-of-life are under-developed at this stage.

Ecolabel Trends in Textiles & Apparel: The Sustainability Consortium’s Review

A similar review of ecolabels was recently completed by the Corporate Sustainability Initiative at

Duke University for the Sustainability Consortium (Golden, 2010). While the review was much

broader in scope than the TCF industries, it did specifically look at ecolabelling trends in clothing

and textiles. The review says “the textile industry illustrates the importance of not only

environmental considerations in the labelling process. The most successful textile certifications also

examine health and safety issues along with workers’ rights.” (Golden 2010, p7). This is informative

for considerations of whether a voluntary EQM for the TCF industries in Australia should seek to

cover ethical considerations only or include environmental issues as well, and whether it should

seek to do them under one label.

Further observations from the Duke University study include:

• Ecolabels in the textile and apparel sector mostly address human health and safety (e.g.

Oeko-Tex), environmental pollution (of all kinds, e.g. GOTS), and worker’s rights.

• Leading ecolabels – and labels that are quickly becoming leaders – share an aim to cover

the entire textile and apparel supply chain from raw material to finished product (Duke

University suggests this is important to ‘cut out the need for a number of smaller labels’

and thereby reduce consumer label fatigue).

• Ecolabels covering the full supply chain facilitate the creation of ‘supplier networks’ (i.e.

inter-connections between raw material, textile creation and final product manufacturing –

or Cut-Make-Trim (CMT) businesses) that make it easier for upstream companies to engage

and purchase ethically and/or environmentally sustainable produced goods.


A quote from the authors of the Duke University study is very relevant to this feasibility

assessment:

“… one thing about ecolabels in the textile and apparel sector is very clear. There are

already definitive “winners” in this industry’s ecolabel space. Comprehensive labels that

cover each of the three issues that are most important in this industry have been developed,

and are enjoying high levels of adoption. While it may be worthwhile for an individual

company to require Oeko-Tex, GOTS … certification for any textiles/apparel it carries,

developing a different set of standards or company-specific codes of conduct for

textile/apparel suppliers may raise the effort and cost without driving any real improvement

in field or market success.” (Golden, 2010, p43).

Alternative Approaches to Achieving Sustainable Production

The Sustainability Consortium, who commissioned the above ecolabel review, is a good example of

an increasingly adopted intervention approach to address moving towards greater ethical and

environmentally sustainable production in global supply chains: the multi-stakeholder,

collaborative, industry-engaged platform (for more on the Sustainability Consortium, see Appendix

E).

Other collaborative and performance-oriented multi-stakeholder programs of this type – all with

high relevance to the TCF industries – include the Global Social Compliance Program (see Appendix

E), the Business Social Compliance Program and the Ethical Trading Initiative (both are in the table

of compliance programs in Appendix B). Most recently – in fact over the course of this project – the

Sustainable Apparel Coalition has launched, adopting this approach amongst some of the biggest

apparel and footwear businesses in the world, with the goal of reducing the social and

environmental impact of apparel and footwear production and consumption.

The Sustainable Apparel Coalition is engaging with the (also new) Eco-Index, an emerging, life cycle

based environmental assessment tool for (initially) outdoor apparel (see more on the Eco-Index in

Appendix B). Taken together, all of these schemes have the potential to transform how the ethical

and environmental performance of TCF industries is understood, measured, and communicated

over the coming decade.

Another collaborative approach of note is The Design Accord (Appendix B). A voluntary,

participation based intervention, The Design Accord seeks to tackle the design phase in the TCF

(and other) industries, which has significant impacts on downstream sustainable consumption and

production. This global coalition attracts signatories, delivers training programs, and shares

knowledge across the design community globally. Design is a vital part of the sustainability agenda

but currently lacks any major compliance initiatives or programs. The Design Accord offers a

solution in this space.


Finally, the industry collaboration model has been adopted across Nordic countries to help achieve

a “clean and ethical” fashion industry. Fashion industry groups came together to form Nordic

Initiative, Clean & Ethical (NICE) in 2008. NICE has set out a ten-year plan to transform the fashion

sector in collaboration with government and non-government organisations. It also offers tools for

businesses and consumers, and conducts awareness and education campaigns towards this end. It

is notable that the ambitions of NICE are highly convergent with those underpinning the

proposition of a voluntary EQM for the Australian TCF industries.

2. Australian TCF Industries Stakeholder Consultations

Stakeholder Context

The TCF industries in Australia are diverse and comprise a range of different product categories

ranging from apparel and fashion, through to footwear, floor coverings, leather, commercial fabrics

and non-woven technical textiles. Each of these categories or sectors has its own set of issues and

priorities, including different drivers for improved environmental performance, product safety and

ethical behaviour.

It is also important to highlight that stakeholder groups within the TCF industries hold diverse and

sometimes competing views with regard to EQM-related issues. A multi-stakeholder approach was

a high priority requirement from the TCF Industries Innovation Council. The need for a multi-

stakeholder consultation approach was also deemed appropriate, given the diverse product

categories.

In addition to manufacturing, import, export and retail interests, the diversity of stakeholders

extends beyond product categories. The TCF industries also reflect several other sectors that play a

specific role in relation to:

• education and training

• workforce representation and union activity

• government policy, programs and regulation

• research and development

• environment, consumer and fair trade advocacy

• media, marketing and communications.

It should be recognised that some stakeholders within the TCF industries have well-developed

programs and initiatives focused on environment, product safety and ethical requirements. Some

of these activities will be further discussed in relation to the findings below.


The Stakeholder Engagement Process

Ensuring widespread consultation and engagement was an important element of seeking views,

opinions and ideas from across the TCF industries. Three specific methods were used:

i) Interviews: Focused on key stakeholders; interactive discussions; face-to-face or

phone; key decision makers and associations.

ii) Workshops: Multiple stakeholders and diverse interests i.e. manufacturers, designers,

associations, educators, designers, activists; enabled face to face group

discussion and debate; allowed stakeholders to ask questions of the study

team directly; conducted two workshops (Melbourne and Sydney).

iii) Online survey: Inclusive and accessible to interested stakeholders; web-based and

uncomplicated to complete; straightforward to promote nationally.

The interviews provided an additional perspective from stakeholders deeply involved with the TCF

industries, with strong views on what any EQM priorities might look like. The Melbourne workshop

enjoyed a larger number of stakeholders (compared to Sydney) and benefited directly from a

longer lead-time promoting the workshop date and location. The online survey proved particularly

successful with higher than expected participation from the TCF industries.

Who Responded & Participated?

A wide range of stakeholders participated in the study across the three streams of inquiry with

representation from business, unions, design, education and non-government groups.

Interviews – nine decision makers and association representatives, including several members of

the TCF Industries Innovation Council and industry associations such as the Council of Textile and

Fashion Industries of Australia, the Carpet Institute of Australia and the Footwear Manufacturers

Association of Australia. The majority of Innovation Council members were interviewed, however

not all members were available or in a position to respond. Some associations deferred to their

completion of the online survey as the primary source of their views and position.

Workshops – 22 participants from Melbourne and Sydney attended the workshops, including

individuals and organisations which reflect the types of business, groups and sectors listed below in

the context of the online survey.

Online survey – 111 respondents from diverse sectors and interests involved directly and indirectly

in the TCF industries. This included companies involved in the production and/or supply of fashion

and apparel, footwear, commercial upholstery textiles, carpet, leather and technical and non-

woven textiles. Not all questions were mandatory which resulted in some respondents skipping

specific questions. A base of approximately 90 respondents completed the majority of questions.


It is important to note that while industry associations reflect a relatively small percentage of

survey respondents, they typically represent much large numbers of their respective sector or

product category by way of being a collective voice for their member companies.

Union officials (and members) and designers were also well represented in the survey. The

remaining survey respondents were equally spread across stakeholders from:

• educational institutions including teachers, lectures, researchers and students

• environment and consumer oriented organisations (NGOs)

• consultants and think-tanks (environment, TCF and business related); and

• media, marketing and communications.

Interview Results

Several key decisions makers and association representatives were interviewed to gain further

insights as to the feasibility for a voluntary EQM. This included discussions (either face to face or by

phone) with:

• several members of the TCF Industries Innovation Council

• TCF Union of Australia

• Council of Textile and Fashion Industries of Australia

• Carpet Institute of Australia

• Footwear manufacturers Association of Australia

• Australian Association of Leather Industries.

Some associations deferred to their completion of the online survey as the source of their views

and position.

Preferred EQM Option

Of the three options proposed, Option 1 emerged as a preferred model chiefly because it could

expand on existing labour rights focused activities in the fashion and clothing sectors and

potentially footwear. This ability to ‘upgrade’ or integrate labour rights, product safety and

environmental performance, was seen as valuable in how Option 1 could be developed. Another

important finding emerging from the interviews was the view that Option 1 was flexible enough to

reference and integrate existing certification schemes and standards from overseas and Australia.

Effective use of, and harmonisation with, these existing initiatives was considered a positive feature

in pursuing Option 1.


Justification for an EQM Option

A key issue that emerged through the interviews was the need for simplicity, efficiency and

effectiveness in the design and implementation of a voluntary EQM, and that this could in part be

achieved through building on the existing ECA accreditation program. Starting from scratch was not

considered viable or desirable when there is already some industry currency through the ECA label.

In other words, several respondents acknowledged the benefits of using and expanding existing

resources, knowledge and multi-stakeholder mechanisms in a new EQM. Specific other existing

schemes cited as worthy of integrating into a new voluntary EQM, and/or learning from, include

the Oeko-Tex, Australian Certified Organic, Good Environmental Choice Australia, and the ACCS

Environmental Certification Scheme for Carpets.

Implementation of an EQM Option

There was agreement among several stakeholders that a joint or multi-stakeholder approach to

managing the design and implementation of a voluntary EQM is appropriate and necessary. This

would not only help ensure appropriate expertise and engagement, it would also contribute

towards transparency and achieving integrity in compliance. The existing ECA accreditation

approach was cited as an obvious example of how a multistakeholder approach helps with effective

implementation and industry outreach, and that this existing ‘infrastructure’ should not be

overlooked in creating a new voluntary EQM.

Limitations & Concerns

The majority of respondents acknowledged that diversity within the TCF industries provided a

challenge to designing, administering and funding a ‘one-size-fits-all’ EQM solution. A single

voluntary EQM that can be equally effective across all product categories within the TCF industries,

and across consumer types, was seen as difficult to realistically achieve.

A particularly strong view from several respondents believed that a ‘level playing field’ was vital. It

was considered essential to avoid creating an EQM that might result in competitive disadvantage

for local manufacturers compared to importers.

Several ‘industry’ respondents did not believe that a new voluntary EQM would help improve the

performance of Australian TCF companies, nor did they believe that household consumer demand

is a major driver. While some believed it could hold potential, there was also a minority view that

did not see sufficient value across all TCF industries. Some respondents remained neutral about the

need for a voluntary EQM, however they acknowledged that it may be more relevant in some

product sectors than others.

For a more detailed summary of interview findings refer to Appendix D.


Workshop Findings

The workshops were facilitated to create an inclusive environment for discussion and debate and

were based on an ‘appreciative inquiry’ approach i.e. a workshop structure that seeks to positively

engage all participants to address issues of change, growth and improvement. The workshops

posed four questions as a means of investigating the feasibility of a voluntary EQM:

i) What is happening today to create more ethical and environmentally sustainable TCF products

and services that excite you, both here in Australia and around the world?

ii) How can we get more of these exciting actions to create more ethical and environmentally

sustainable products and services in Australia?

iii) Looking at the actions identified under question ii), how desirable and feasible is each option?

iv) How would you design an EQM so that it is desirable and feasible, and could contribute to

creating thriving and viable TCF industries?

The workshops were held in Melbourne and Sydney with 22 participants from a variety of sectors

and interests, including local manufacturers (outdoor and corporate clothing, non-woven and

technical textiles), TFIA, TCFUA, fashion labels and designers, educators and post-graduate

researchers, Fair Trade advocates and government. Grouping these diverse stakeholders in the

workshops was considered an important catalyst for issues identification and solution generation.

This format allowed for group-wide discussion as well as smaller break-out sessions, all of which

generated a variety of views, ideas and options. The key findings are summarized below.


The workshops enabled a free-ranging discussion of how ethics, product safety and environmental

performance could be addressed across the TCF industries, and numerous ideas and suggestions

(e.g. regulations, funding, tariffs) were put forward even though many fell outside the scope of the

study. There was however a recurring view that the existing ECA program provides a base from

which to expand certification and labelling to move beyond labour rights requirements.

Option 1 was seen as a logical starting point as ECA accreditation was relatively well known and

understood in the clothing and fashion sectors. The inherent ability to expand Option 1 to deal with

additional certification criteria was also seen as positive and more realistic than designing a new

model from the ground up. There was a clear view emerging from the workshops that developing

an option which undermined existing ECA efforts would not be desirable or supported by key

stakeholders involved in the TCF industries.



A consistent and recurring finding from the workshops, which underscores the justification of

Option 1, is a view that it provides an established foundation for ongoing expansion to address

additional key certification criteria i.e. product safety and environmental performance. It was also

felt that Option 1 could enable a phased and modular solution to EQM type solutions, and that this

measured or staged approach could increase the chances of longer-term success.

The need and desire to effectively use existing global and/or local certification schemes was also

often raised during the workshops, and is compatible with the basic structure or scope of Option 1.

Ensuring that a new voluntary EQM addressed multiple certification criteria over time was another

key point raised, and the success of such a label would be dependent on showing how its design

and implementation would deal with ethical performance, as well as product safety and

environmental performance. Again, a modular or phased approach possible through Option 1

supports its further development. There was also agreement that ECA accreditation was ‘setting

new standards’ on labour rights with resulting positive outcomes, and that this basic framework

could be extended or adapted to other certification aspects.

The need for increased transparency and credibility that could be realised through an expanded

voluntary EQM was another common workshop theme and seen as increasingly important for

consumer and environment NGOs.

Implementation of an EQM Option

A noteworthy theme emerging from the workshops was the value of ‘modularity’ and how this

could support a more realistic and incremental EQM implementation approach. This view was

flavoured by the need to be realistic and focused about scope, and developing an EQM that was

both desirable and feasible to key stakeholders in terms of sector or product category, and

customer type (e.g. business-to-business and business-to-consumer). In short, the need for

targeting specific customer groups should inform the design and implementation of a voluntary

EQM.

Learning from existing, successful certification schemes relevant to the TCF industries was raised

during the workshops as important and of practical relevance with regard to implementation and

delivery. More specifically, any scheme should learn from the methods and processes adopted by

the Green Building Council of Australia and their Green Star rating tool, and how this influences or

drives the certification of product and company performance concerning product safety and

environmental.


Many workshop participants raised the issue of consumer interest, demand and awareness for

‘greener’, safer and more ethical products, from reputable manufacturers and retailers. Growing

receptiveness from Gen Y was one example of why EQM type solutions hold merit and may succeed

in the marketplace. This issue was also connected to workshop discussion around the increased

visibility of social and environmental impacts as communicated via blogging, documentaries,

activism and general media interest on such topics.


There was a strong and clear view from the workshops that any voluntary EQM needs to target the

majority of clothing and fashion if there is to be any measurable social and environmental benefit.

While the relevance of an EQM across all TCF product categories was recognised, the strongest

views were expressed in relation to ensuring effective applicability of an EQM on clothing and

fashion. This view is consistent with related comments on the challenges of achieving a level

playing field by eliminating free-riders who might gain a competitive advantage through non-

participation in an EQM certification program.

A concern from some business stakeholders was raised about limited market demand or other

compelling drivers for business to spend on any form of ethical or environmental certification. In

other words, they were not convinced of the possible return on investment of adopting an EQM.

The need for education and re-education of all stakeholders was also seen as very important in

securing commitment and future action on ethical and environmental improvements across the

TCF industries. Great awareness and understanding of the issues and impacts was considered as a

prerequisite to business engagement and buy-in.

For a more detailed summary of workshop findings refer to the Appendix D.

Online Survey Results

An online survey (the survey) was deployed among stakeholders to help maximise participation and

provide an inclusive approach. The use of a conventional, web-based format enabled the study

team to access stakeholders regardless of their geographical location or time constraints.

Over 30 questions were posed and aimed to explore and investigate levels of general awareness,

attitudes, opinions and preferences in relation to a variety of topics and themes directly and

indirectly related to an EQM. A combination of multiple-choice, closed and open-ended questions

generated a significant body of results that have been used to further evaluate and test the

feasibility of a preferred voluntary EQM option. The online survey questions are listed in Appendix

C.


A total of 111 respondents from diverse sectors and interests involved in the TCF industries

participated in the survey. The combined representation of business (manufacturers, brand

owners, retailers and importers) represented the largest single grouping (34.9 %). Union officials

and members represented 19.6 % of all responses. Manufacturers formed 15.2 % of all survey

responses. While industry associations reflect a relatively small percentage of survey respondents,

they typically represent much large numbers of their respective sector or product category by way

of being a collective voice for their members.

Which sector best describes your role? Response percent Response count

Manufacturing 15.3 % 17

Brand owner 6.3 % 7

Retailer 8.1 % 9

Importer 5.4 % 6

Designer 10.8 % 12

Union 19.8 % 22

Education and research 9.9 % 11

Industry and professional association 5.4 % 6

Government 0 % 0

Environment or consumer organisations 4.5 % 5

Other 14.4 % 16

In relation to sub-sectors or product categories, the majority of survey respondents considered

themselves as most directly involved with fashion and apparel (52.7 %), as per the table below.

Which product category are you primarily

involved with?

Response percent Response count

Fashion and apparel 52.2 % 58

Footwear 6.3 % 7

Commercial textiles 5.4 % 6

Technical textiles and non woven 1.8 % 2

Leather 3.6 % 4

Carpet and other floor coverings 4.5 % 5

Other 26.1 % 29



Of the three options proposed, the largest single group of survey respondents favoured Option 1 as

being the most attractive to stakeholders. Option 1, or an expanded or modular upgrade of the

existing ECA accreditation program, was considered to be the most attractive to companies with

33.3 % of respondents selecting Option 1. The same Option was also considered as the most

attractive to consumers (36 %), as per the tables below. While the majority of respondents

completed the ‘Options’ questions, some chose to skip this section of the survey.

Which of the three options outlined is most

likely to be attractive to TCF companies?


Option 1 33.3 % 37

Option 2 11.7 % 13

Option 3 9.9 % 11

None of the options 3.6 % 3

Other (please describe) 8.1 % 10

Which of the three options outlined is most

likely to be attractive to consumers?


Option 1 36 % 40

Option 2 10.8 % 12

Option 3 9 % 10


Other (please describe) 9 % 10

Of the three options outlined which has the

highest risk of failure or low-level adoption

by TCF companies?


Option 1 16.2 % 18

Option 2 27 % 30

Option 3 14.4 % 16



It is important to note that a relatively high number of respondents felt that Option 2 has the

highest risk of failure or lowest level of adoption by TCF companies.

A considerable number of respondents (39.6 %) believed that existing labour rights initiatives in the

TCF industries were ‘effective and meeting stakeholders’ needs’, compared to only 16.2 % feeling

the opposite. This tends to highlight the success and performance of the ECA accreditation program

and is consistent with the single largest group of respondents favouring an EQM as described under

Option 1.


The relationship between a new voluntary EQM and existing labour rights activities was also raised

by some respondents, with a strong preference to see the ECA accreditation program as a

prerequisite to securing additional certification or accreditation to environmental and product

safety standards. This further supports the intent of Option 1 as a sequenced approach that can

help ensure that working conditions are addressed from the outset and not omitted from the

overall scope of an integrated EQM approach.


At a general level there is a strong feeling of ‘industry interest, concern and responsibility’ among

respondents. A total of 78 % of respondents either agree or strongly agree that environmental

issues are of great concern to the TCF industries.

The issue of ‘hazardous and/or toxic substances used in the manufacture of TCF products’ was

considered the most significant environmental issue among a large group of respondents at 48.6 %.

Concern about ‘energy consumption and associated carbon emissions/global warming’ was also

seen as significant with 46.8 % of respondents nominating it as a major environmental issue. Given

the nature of fashion and typically short life cycles for many clothing items, it is not surprising that

42.3 % of respondents also considered ‘solid waste resulting from end-of-life TCF products’ as a

significant issue.

More specifically, as a combined percentage (47.7 %), a relatively large group of respondents either

strongly agree (36.9 %) or agree (10.8 %) that a new Environmental Label is much needed for the

TCF industries. These figures indicate that there is more support among respondents than there is

opposition to a voluntary EQM, as per the table below.

A new voluntary Environmental Label for

the TCF industries is much needed in

Australia


Strongly agree 36.9 % 41

Agree 10.8 % 12

Undecided 19.8 % 22

Disagree 9.9 % 11

Strongly disagree 2.7 % 3

The single largest group of respondents (36 %) believed that the expansion of the current ECA label

to include environmental/sustainability accreditation as an optional adjunct to the current labour

rights accreditation for local TCF industries would be most attractive to consumers. The least

popular option among respondents (9 %) was Option 3 which proposed to start a new label

separate to the ECA. Option 2 attracted the support of 10.8 %.


In terms of desirability among TCF companies, the breakdown was similar to that of consumer

attractiveness. An expanded and modular upgrade of the ECA accreditation program was

considered to be the most attractive to companies with 33.3 % of respondents selecting Option 1,

compared to only 11.7% support for Option 2 and 9.9% for Option 3.

A diverse range of factors and potentially positive outcomes underpinned the justification of a new

voluntary EQM by respondents. A strong and recurring justification related to an EQM’s

contribution to achieving a sustainable future and creating employment. Some survey respondents

also believed that an EQM would directly assist with increasing consumer awareness, which in turn

would drive industry to deliver improved TCF products. Additional justifications emerging from the

survey include:

• the potential for a label to provide brand differentiation in the market place, including export

opportunities

• the role of innovation in helping to stimulate competitive spirit between manufacturers

underpinned by a common standard or baseline of product performance

• environmental benefits e.g. less waste, safer products, reduced toxic substances

• the creation of a more direct connection between consumers, the products they purchase, and

the associated environmental impacts; and

• the possibility of raising consumer awareness about Australian-made ethical and/or

environmental products, depending on who was eligible for the EQM.

Several survey respondents noted that in the absence of regulations or mandated labelling

requirements imposed on TCF products, a voluntary EQM remained a worthwhile starting point

that could develop and expand over time.

Implementation of an EQM option

The largest group of survey respondents (50.4 %) believed that a combination of organisations was

best placed to ensure ‘independence and credibility’. The dominant combination among

respondents was ‘unions + industry + associations + environment and consumer NGOs’. This

combination was closely followed by a variation, which included government and research

organisations.

Which stakeholder/s bring the most

independence and credibility to the design

of a voluntary TCF based environmental

label?


Australian Government 6.3 % 7

Educational/academic organisations 1.8 % 2

Environment and consumer NGOs 4.5 % 5

Industry and professional associations 9 % 10

Research organisations 1.8 % 2

State and Territory Governments 0.0 % 0

Unions 3.6 % 4

A combination of the above 50.4 % 56


Respondents were divided on the issue of who should be eligible to receive a voluntary label. The

biggest grouping of respondents (34.2 %) either strongly agree or agree that any new label should

be available to any manufacturer, importer, brand owner or retailer supplying products to the

Australian market.

A new voluntary Environmental Label

should be available to any manufacturer,

importer, brand owner or retailer supplying

the Australian market?



Agree 15.3 % 17

Undecided 5.4 % 6

Disagree 5.4 % 6

Strongly disagree 27 % 30

With 63 % of respondents believing that local and overseas manufacturers should be subject to the

same labour rights requirements, it could be concluded that a level ‘playing-field’ without any

exemptions is a priority issue for the majority of survey respondents, and that this is a high priority

implementation requirement.

An important aspect of achieving an integrated approach between and across certification schemes

is to ensure that the design and implementation of an EQM under Option 1 is governed by relevant

expertise, interests and sectors. This highlights the value and benefits associated of adopting a

multi-stakeholder model not dissimilar to how the current ECA accreditation operates.

The survey results also emphasised a range of significant factors in the design of a successful

voluntary EQM including: independence, transparency, robust data, credibility, effectiveness,

industry commitment, collaboration, monitoring, clear communication, clear metrics, and public

recognition.


respondents as part of the survey. While no particular method (e.g. royalties versus annual

application fee) emerged as a clear preference, there was an overt view that the cost of being

certified should be kept minimal, especially given concerns about the rising costs of doing business.

The importance of government support to ensure independence and transparency also was

considered important by stakeholders.

From a learnings and precedent perspective, survey respondents cited several labels and

certification schemes that could inform the future development and implementation of a voluntary

EQM. These include – the Energy Star Rating Scheme, Australian Certified Organic, Sustainable

Apparel Coalition, ACCS Environmental Certification Scheme for Carpets, Fairtrade Label, Good

Environmental Choice, Woolmark label, Made in Australia, the Heart Tick and Forest Stewardship

Council certification.



A large number of respondents noted that the performance and benefits of an EQM could be

enhanced or improved if it was regulated in some way i.e. not voluntary. Similarly, a clear definition

around the scope and parameters of any new voluntary EQM would be required to help to focus

the success of such a scheme.

More work needs to be done on the question of eligibility and to whom an EQM under Option 1

could be applied. Survey respondents were divided on this issue. The biggest grouping of

respondents (34.2 %) either strongly agreed or agreed that any new Environmental Label should be

available to all companies supplying TCF products to the Australian market.

For a more detailed summary of the online survey results refer to the Appendix D.

Summary of Key Findings from the Interviews, Workshops and Online Survey

The results from, and analysis of, the stakeholder consultations have provided a comprehensive

body of information to help determine the feasibility of a new voluntary EQM for the TCF industries

in Australia. When the results are considered as a collective set of findings it becomes apparent

that there is support for a voluntary EQM regardless of any limitations, caveats and concerns.

The interviews with individual decisions makers indicated support for Option 1 because it was well

placed to expand on existing labour rights activities in the fashion and clothing categories, and

potentially footwear. Option 1 was also considered flexible enough to reference and integrate

existing schemes and standards from overseas and Australia. Simplicity, efficiency and effectiveness

in the design and implementation of any new EQM were seen as important. A joint or multi-

stakeholder approach to the implementation was also considered a priority by most respondents,

as was the need for a level playing field to ensure that local manufacturers did not suffer any

competitive disadvantage.

The issues, themes and ideas emerging from the workshops suggest that while many innovative

ideas and possibilities exist, that the essential structure of Option 1 was considered to be a logical

starting point, especially for fashion and clothing. The ability to expand Option 1 to deal with

additional certification criteria was also seen as positive and more realistic than designing a new

model from the ground up. There was also general agreement that ECA accreditation was ‘setting

new standards’ on labour rights with resulting positive outcomes, and that this basic framework

could be extended or adapted to other certification aspects. The need to be focused and realistic

about a new EQM was also clear, as was the acknowledgement of re-educating key stakeholders

and increasing consumer interest and awareness.


In the first instance, the online survey results highlight a strong degree of interest in the issue

merely through the high number of respondents. Furthermore, the breakdown of results shows

that those involved with fashion and apparel are especially engaged and eager to see positive

outcomes. Of the three options proposed, the single largest group of survey respondents favoured

Option 1 as being the most attractive to stakeholders – both companies and consumers. A strong

and recurring justification related to an EQM’s contribution to achieving a sustainable future and

creating employment. The majority of survey respondents (50.4 %) believed that a combination of

organisations was best placed to ensure ‘independence and credibility’. The dominant combination

among respondents was ‘unions + industry + associations + environment and consumer NGOs’.

Concerns and queries across all three streams of inquiry relate to the need for clarity around scope,

eligibility, source of production, avoiding competitive disadvantage and the importance of learning

from, and integrating with existing local and global certifications. While some believed it could hold

potential, there was also a minority view that did not see sufficient value across all TCF industries.

Some stakeholders remained neutral about the need for a voluntary EQM, however they

acknowledged that it might be more relevant in some TCF product categories than in others.

In summary, there are dominant and common areas of agreement emerging from all three streams

of consultation. Most importantly and within the context of assessing the feasibility of the

proposed options, there is general agreement that Option 1 is the preferred approach.

3. Justification of a Voluntary EQM Option

Referring back to the context for this report, the Australian Government asked the TCF Industries

Innovation Council to examine the feasibility and appropriateness of a voluntary EQM given there

are existing ethical and environmentally sustainable production compliance programs applicable to

the TCF industries. Factors considered during the conduct of the study included a voluntary EQM

that:

• covers all issues of concern in TCF production (human health and safety, worker’s rights

and labour conditions, and environmental impacts)

• addresses more than just manufacturing, but also supply chains for fibres and materials,

and aspires to address product stewardship and post-sale use impacts

• is a tool for consumers to inform their choice of TCF products

• provides a competitive advantage in the market to companies and products that qualify for

the certification and use of the Mark

• is complimentary to existing schemes, in particular the Ethical Clothing Australia system;

and

• will reduce rather than increase complexity of existing arrangements.


The voluntary EQM options tested by this study were:

Option 1: Expansion of the current Ethical Clothing Australia label to include


rights accreditation for the local textile, clothing and footwear industries.

Option 2: Transformation of the current Ethical Clothing Australia label so that the primary

focus of the new label is an environmental/sustainability accreditation while still accrediting

members for upholding labour rights for the local textile, clothing and footwear industries.

Option 3: Development of an environmental/sustainability accreditation for the local

textile, clothing and footwear industries that is separate from Ethical Clothing Australia.

The voluntary EQM Option 1 has emerged as the most supported and likely to succeed of these

options. The intervention approach implied under EQM Option 1 is a product certification model,

compared to Codes of Conduct or industry-performance enhancement approaches. An explicit

focus on TCF industries is also implied rather than a general sustainability compliance tool.

Credibility is assumed, of course, but not a given, and will need to be considered in any final design.

Further questions regarding the justification for Option 1 and its feasibility as a voluntary EQM for

the Australian TCF industries are posed below. The answers draw on the streams of enquiry

discussed in this Research & Analysis section, including the review of global and local compliance

programs and sustainable production trends, stakeholder interviews, workshops and the online

survey.

1. Do Stakeholders in the Australian TCF Industries See the Value, Demand for, and Interest in

Creating a New Voluntary EQM?

Stakeholders in the Australian TCF industries see the potential value and role of a voluntary EQM

that builds on existing labour rights initiatives. There is strong support for an EQM in some product

classes (e.g. clothing, fashion, technical textiles) and from some stakeholder groups (e.g. trade

union and some industry associations).

The results emerging from the stakeholder consultations show broad support for a voluntary EQM

that can shift the TCF industries towards a more engaged, informed and proactive mode of

operation that embodies improved and measurable levels of product safety, environmental

performance and labour rights protection. While some believed it could hold potential, there was

also a minority view that did not see sufficient value across all TCF industries. Some stakeholders

remained neutral about the need and justification for a voluntary EQM, however they

acknowledged that it may be more relevant in some TCF product categories than in others.


The majority of survey respondents (50.4 %) believed that a combination of organisations was best

placed to ensure ‘independence and credibility’. The dominant combination among respondents

was ‘unions + industry + associations + environment and consumer NGOs’.

Stakeholders also see the value of learning from existing, successful certification schemes relevant

to the TCF industries. More specifically, any scheme should learn from the methods and processes

adopted by the Green Building Council of Australia and their Green Star rating tool, and how this

influences or drives the certification of product and company performance concerning product

safety and environmental factors. For example the Carpet Institute of Australia has developed a

comprehensive and widely adopted environmental classification system, partly driven by Green

Star. Similarly, several Australian commercial upholstery suppliers have successfully adopted a

range of international and local environmental certification schemes such as Good Environmental

Choice Australia, EcoSpecifier GreenTag and Oeko-Tex.

2. Which of the Three Options Proposed by the TCF Industries Innovation Council has the Most

Support & What Does That Tell Us?

Based on the results of stakeholder consultation, and the three options presented to stakeholders,

Option 1 has the most support at this point in time:

Expansion of the current Ethical Clothing Australia (ECA) labour rights related label to

include environmental/sustainability accreditation as an optional adjunct to the current

labour rights accreditation for the local textile, clothing and footwear industries.

While the overall thrust of the findings was supportive of Option 1, the online survey results further

reinforced stakeholder preferences for this Option i.e. the largest single group of respondents

favoured Option 1 as being the most attractive to stakeholders. Option 1, or an expanded or

modular upgrade of the existing ECA accreditation program, was considered to be the most

attractive to companies with 33.3 % of respondents selecting Option 1, compared to only 11.7 %

support for Option 2 and 9.9 % for Option 3. The same Option was also considered as the most

attractive to consumers.

The preference for Option 1 also suggests that stakeholders see value in integrating labour rights,

product safety and environmental performance, in a staged or modular manner within the context

of retaining ECA involvement.


3. How Does a New Voluntary EQM Compare to Existing Initiatives (Local & Global), & What Does

That Tell Us?

Depending on its design and scope, a new voluntary EQM has the potential to connect and/or

harmonise with several existing certification schemes that are relevant to the TCF industries. These

schemes are typically product specific (e.g. carpet, upholstery textiles), or process-oriented (e.g.

organic, toxics). In Australia these include:

• Good Environmental Choice Australia

• EcoSpecifier Green Tag

• Australian Carpet Classification Scheme (Environmental Classification Scheme)

• Australian Certified Organic (amongst other organic certifiers).

A range of overseas schemes and standards also has applicability within an Australian context. An

obvious and widely used standard dealing with restricted and harmful substances is the Swiss-

based Oeko-Tex standard.

Other international initiatives also have relevance and are discussed in the next chapter. In short,

there are several existing schemes and/or standards from Australia and overseas that could be

referenced directly into a comprehensive voluntary EQM for the Australian TCF industries.

4. Is a Voluntary EQM for the TCF Industries Feasible for Australia?

The analysis of the stakeholder consultation results, as well as the literature review of certification

schemes, recommends Option 1 as the most feasible approach for a voluntary EQM at this time.

In particular, there are opportunities to work towards a phased approach that targets TCF

product(s) where demand and awareness is currently strong. The results support this conclusion.

The feasibility is likely to increase if the scope and focus of the EQM are narrowed to a specific

product category or sector(s) where there is clear demand from stakeholders, be they

manufacturers, suppliers, brand-owners or consumers, as is the case with clothing and fashion.

The feasibility of a voluntary EQM within the context of Option 1 can also be increased through

additional work to establish a compelling business case that includes some form of cost-benefit

analysis for a specific product category or sector. It is also important to note that some

stakeholders are neutral and sitting on the fence, needing additional information about scope and a

much stronger business case.

In summary, a voluntary EQM in accordance with Option 1 is the most feasible of the three options

proposed. By focusing the design, scope, eligibility and market relevance of Option 1, the feasibility

can be further increased. Mindful of this measured approach, the following Roadmap seeks to

address and accommodate how a phased approach to implementing a voluntary EQM could be

implemented.


Roadmap Toward an Australian Voluntary EQM for TCF Production

The most desirable and feasible of the three voluntary EQM design options put to Australian

stakeholders was:

Option 1: Expansion of the current Ethical Clothing Australia label to include


rights accreditation for the local textile, clothing and footwear industries

A roadmap from current arrangements towards Option 1 for fashion, clothing and potentially

footwear will need to take the following aspects in to account:

• Domestic versus full global supply chain scope: The stakeholder consultation revealed general

agreement that an EQM covering domestic activities only is more feasible, but likely not

credible to end users (i.e. retailers, consumers). Additionally, a domestic application would

exclude most TCF products in the Australian market. Adopting a full global supply chain scope

creates opportunities for any scheme to be accessed by Australian brands producing overseas,

as well as international companies selling in to the Australian market – though there are strong

opposing opinions on the latter aspect. It is also noted that the Sustainability Consortium’s

ecolabel review concluded that global leading labels in the TCF industries aim to cover the

whole supply chain from raw materials to finished products, as they limit the need for a

number of smaller, supply chain step labels and consumer label confusion/fatigue.

• New versus existing initiatives: Complimentarity has been emphasised throughout this report

as a key requirement for the Australian Government in considering the feasibility of a voluntary

EQM. There are existing compliance programs covering most relevant supply chain issues and

areas that can be utilised. As the Duke University report stated, there is likely questionable

return on investment in creating new standards or labels compared to utilising schemes already

in operation. New models should complement the existing work of Ethical Clothing Australia

(which accredits to the Code).

• Financial feasibility: Preferred intervention approaches must consider where money has

already been invested, competition for funds, and value to stakeholders so that it can rapidly

transition to a self-sustaining enterprise beyond an initial start-up period. Government funding

support is an important and appropriate requirement to help increase success of any ongoing

development activities.


• A rapidly evolving global environment: There have been many innovations in recent years in

the TCF industries, and the significant global momentum suggests this will continue. Platforms

like the Sustainable Apparel Coalition, the Sustainability Consortium and the Global Social

Compliance Program are working on enhancing ethical and environmentally sustainable

production in TCF industries. Consequently, any model adopted in Australia needs to remain

flexible and open to global developments, and preferably develop direct relationships with such

organisations to facilitate knowledge, information and tool exchange.

With the above points in mind, as well as the findings from the review of current global compliance

programs and Australian TCF industries stakeholder views, a possible roadmap for implementing a

the preferred voluntary EQM model (i.e. Option 1) is outlined below. The roadmap focuses on

consumer-facing standards and certification, starting with ECA, and providing a competitive,

market-differentiation framework for businesses to pursue ethical and environmentally sustainable

fashion, clothing and possibly footwear production.

Key Features of the Roadmap:

Builds on existing ECA accreditation covering worker’s rights and labour conditions.

Starts with Ethical Clothing Australia system and expands both along the supply chain

(so it incorporates more stages) and to incorporate more production issues (i.e.

environmental and health and safety aspects).

Engages business by offering consumer-facing standards and certification that give

them a competitive advantage in the market through offering credible claims of

ethical and environmentally sustainable production.

Uses a passport framework to do this credibly using existing compliance programs.

Communicates to industry and consumers a vision, a direction, and credible choices

for ethical and environmentally sustainable production.

One possible route towards Option 1 is the creation of a recognition framework to provide TCF

businesses with a ‘tick’ in their ethical and environmentally sustainable production passport across

their supply chain activity (see Figure 1). A tick would be dependent on demonstrating achievement

using credible existing systems as the performance criteria.


As illustrated in Figure 1, there are 8 supply chain areas of ethical and/or environmental

performance which could form the passport portfolio. Credibility principles, as discussed earlier and

in Appendix A, would be used to determine what constitutes effective action in each supply chain

area.

Generic TCF Supply Chain Stages for Australian

Product Sales • Key ethical and environmental challenges for each

step in the supply chain (Human Health & Safety and

Greenhouse Gas Emissions are cross-cutting supply

chain issues)

• Major initiatives to ensure ethical/environmentally

sustainable production for each supply chain step Figure1. Graphic illustration of Roadmap.

Offshore Stages Local Stages

Life Cycle or Supply Chain Stages


In keeping with Option 1, such a passport system could begin with the Australian CMT

(manufacturing of clothing and potentially footwear) stage and the ECA label – requiring ECA

accreditation as the starting point, i.e. companies manufacturing in Australia demonstrating ethical

production. The passport could be then expanded over time, at a pace judged to be effective for

both industry and the passports’ management. Expansion across the supply chain stages and into

human health and safety and environmental pollution performance widens the scope for Australian

(and possibly global businesses) to participate, which:

• increases economic viability of the scheme (i.e. more companies as clients)

• provides coverage over more TCF products, which increases consumer awareness; and

• substantially increases social and environmental impact of the scheme.

This could be approached by making new supply chain areas or issues part of progress

requirements for maintaining initial ECA accreditation. To illustrate, once the passport framework is

in place, and decisions are made on where to build out to first, companies would need to

demonstrate adequate performance in other areas of their supply chain and/or on other

production issues to maintain their ECA accreditation. ECA may require accredited businesses to

demonstrate they have environmental management systems in place for their Australian CMT

operations, or that they are addressing human health and safety of their products by acquiring

Okeo-Tex certification.

Table 2 attempts to illustrate this further and provide some possible compliance program options

for expanding the ECA sequentially or modularly, consistent with Figure 1. The passport framework

starts with recognising the ECA accreditation and product label as a credible compliance program,

demonstrating ethical performance in the Australian CMT stage of a TCF product supply chain.

Table 2. Possible Compliance Program Combinations Under Route 1

Supply Chain Area Supply Chain Issue Compliance Program Combination

Starting Point

Australian CMT Worker’s rights ECA

Second Step – Build out on production issues within Australian CMT

Australian CMT Worker’s rights

Environmental management

ECA

ISO 14001

Australian CMT Worker’s rights

Environmental management

Human health and safety

ECA

ISO 14001

Oeko-Tex

Additional Future Step – Build out on worker’s rights and labour conditions across the supply chain

Australian CMT

Overseas textiles

Overseas fibres

Worker’s rights

Labour conditions & worker’s rights

Labour conditions and fair prices

ECA

SA8000

Fairtrade Certified Cotton

Other Steps/Possibilities

Australian CMT

Overseas/local textiles

Worker’s rights & human health & safety

Human health and safety

ECA

Oeko-Tex


In pursuit of Option 1, accreditation is geared towards product labelling. However, the model could

be applicable to the whole of a company’s operation, especially in some supply chain areas (i.e.

environmental performance in textile manufacture). The framework may require a minimum level

of compliance across the whole company before products are able to carry the labelling. However,

this may work against the attractiveness of the recognition framework. In time, the supply chain

area ‘ticks’ across the passport could be adapted to a ‘star rating’ system for TCF products.

The framework itself could be communicated, along with the principles for choosing credible

compliance schemes to demonstrate ethical and environmental performance along the supply

chain, to the sector well in advance of the formal EQM process adopting full supply chain area and

issue coverage. The stakeholder consultations indicate providing industry with such guidance on

choosing credible schemes and knowing what issues and supply chain areas to manage would be

very helpful. In the absence of such information, new schemes are being created, or less credible

systems adopted, often with little ethical or environmental benefit to production outcomes – and

at expense to businesses and increasing confusion for consumers. An additional advantage of using

this framework to communicate to industry is that it may create more businesses and production

systems eligible for accreditation against the EQM as it grows to be more encompassing.

Some possible benefits and weaknesses of this particular approach are described in Table 3.

Table 3. Benefits & Weaknesses of this Roadmap to EQM Option 1

Benefits & Opportunities Weaknesses & Challenges

It is complimentary to existing initiatives, i.e. Ethical

Clothing Australia, rather than in competition.

Will businesses see the value in paying for, or going

through the process of, additional recognition for

compliance they have already invested in elsewhere?

Businesses who have already invested in action get

recognition without having to go through additional

certification.

Businesses who have invested time and money in

compliance programs that are not deemed ‘credible’

may object, criticise, or stay away.

New compliance programs can be recognised against

the credibility principles as they are

developed/assessed.

Not all supply chains encompass all 8 areas, meaning

not all products could be scored on an 8 part rating

system, e.g. products made from Australian cotton in

Australia could only ever have 5 stars. This presents a

challenge for consumer communication but could be

overcome through using %, differentiating Australian

grown and made products, etc.

Businesses are able to be recognised for action in

some areas of their supply chain as encouragement

to go further, i.e. starts with where business is.

Is compliance in any one supply chain area more

important than in others? Does this differ across

product classes? Should they be differentially

weighted?

Recognition framework could be adopted by retailers

and/or institutional end users (i.e. government or

corporate procurement) to choice edit.

May not be as useful for consumer facing as

business-to-business transactions, given lack of

comparability across supply chain areas (though a

‘star rating’ system is known and may be easily

generalised from water and energy consumption to

TCF products).


Benefits & Opportunities Weaknesses & Challenges

Provides information to industry and consumers on

what supply chain issues need to be addressed, and

what constitutes credible action.

If it was determined to adapt such a model to a

consumer facing ‘star rating’ type system, then there

would need to be investment in establishing a visual

identity or brand which may compete with existing

schemes – and may take time to garner consumer

awareness, etc.

No avenues for businesses to engage – it is a

compliance program that they meet or they don’t

(push rather than pull approach).

To further assist with conceptualising and implementing the proposed model and mapping out how

it could be achieved, some thoughts on how it could operate are outlined below.

Operation

Under the model proposed above, the passport and recognition framework would likely sit within

the existing Ethical Clothing Australia organisation. The framework may err on the side of being an

organisational scheme rather than a consumer facing scheme in the early stages until a critical mass

is achieved and/or a consistent approach developed, keeping the ECA Label as the primary

consumer facing activity for a period of time. Strategic and business plans would be need to be

developed soon after establishment by the Steering/Executive Committee and Secretariat.

Governance

The program will need a representative Steering or Executive Committee to oversee its operation

and direction; involvement of industry, unions and government are likely essential for credibility.

The program will need a strong, independent and representative Compliance Committee to apply

(and determine) the credibility principles and assess new programs that could be used to ‘tick’

supply chain area actions. The Compliance Committee could also assess the applications for

recognition, though this would likely be delegated to the Secretariat as early as possible.

Funding

Conduct an outreach campaign to industry to introduce the program and attract applicants – this

may come from the Australian Government and/or other sources. Ongoing operational funding

could be derived from application fees from business to have their performance recognised against

the framework, i.e. fees per supply chain area. Attention would need to be given to an appropriate

level of fees to balance funding the operation of the program, maintaining accessibility for all types

of businesses, and recognising businesses have already paid to be compliant against other

tools/programs. Consumer and industry outreach and education activities may require additional

funding, to be pursued through partnerships, grants, participating business investment, etc.


Conclusions

The feasibility assessment recommends Option 1 as the preferred method for implementing a

voluntary EQM for the Australian TCF industries, in particular for the fashion and clothing sectors

and potentially footwear.

Stakeholders in the Australian TCF industries see the potential value and role of a voluntary EQM.

There is particular support for an EQM in some product classes (e.g. clothing and fashion) and from

some stakeholder groups.

Implementation of Option 1 will need to address specific subject matters (e.g. toxics, waste,

carbon, water, and labour rights), scope of the EQM, as well as how it would address ‘local’ versus

‘off-shore’ manufacturing (and therefore associated auditing and performance verification

processes).

The preference for Option 1 also reflects the value in integrating labour rights, product safety and

environmental performance, in a staged or modular manner, within the context of retaining the

current ECA label as a starting point. Any EQM must address the whole supply chain over time and

embody the principles of life cycle thinking and life cycle assessment.

While Option 1 is preferred, there are dissenting opinions from some stakeholders, particularly

outside the fashion and clothing sectors. Many stakeholders are neutral and sitting on the fence,

needing additional information about EQM scope, and a much clearer business case. While some

believed it could hold potential, there was also a minority view that did not see sufficient value

across all TCF industries.

Depending on its design, a new voluntary EQM under Option 1 has the potential to connect and

harmonise with several existing certification schemes that are relevant to the TCF industries. These

schemes are typically product specific (e.g. carpet, upholstery textiles), or process-oriented (e.g.

organic, toxics). Various overseas schemes and standards have applicability within an Australian

context e.g. ISO14001 and Oeko-Tex. These could be referenced directly and incorporated into a

voluntary EQM for the Australian TCF industries.

No particular method (e.g. royalties versus annual application fee) emerged as a clear preference

for funding the implementation of the preferred Option, however there was an overt view that the

cost of being certified should be kept minimal and focused on cost-recovery. The importance of

government support to ensure independence and transparency was considered important.

There is broad support for a range of activities (including an EQM) that can shift the TCF industries

towards a more engaged, informed and proactive mode of operation that embodies improved and

measurable levels of product safety, environmental performance and labour rights protection.


As part of any ongoing work on a new EQM, it is important to recognise that some product

categories (and companies) within the TCF industries are significantly advanced on certain aspects

of environmental performance, product safety and/or ethical considerations. For example, driven

by demands of the Green Building Council, the Carpet Institute of Australia has developed a

comprehensive and widely adopted industry facing environmental classification system.


References

Australian Government, 2010, Department of Innovation, Industry, Science and Research,

Competitive Industries Branch, Secretariat, TCF Industries Innovation Council, February 2010, A

Voluntary Ethical Quality Mark for the Australian Textile, Clothing and Footwear Industries?


Competitive Industries Branch, Secretariat, TCF Industries Innovation Council, June 2010, A

Voluntary Ethical Quality Mark for the Australian Textile, Clothing and Footwear Industries: An

Examination of Possible Design Components.


Competitive Industries Branch, Secretariat, TCF Industries Innovation Council, September 2010,

Product Stewardship and the TCF Industries.

Allwood, J, Laursen, S, Malvido de Rodriquez, C & Bocken, N, 2006, Well dressed? The present and

future sustainability of clothing and textiles in the United Kingdom, University of Cambridge

Institute for Manufacturing, Cambridge, viewed 17 May 2011,

http://www.ifm.eng.cam.ac.uk/sustainability/projects/mass/UK_textiles.pdf

Collins, M & Aumonier, S, 2002, Streamlined life cycle assessment of two Marks & Spencer plc

apparel products, Environmental Resource Management, London, viewed 17 May 2011,

http://aestivaltd.web.officelive.com/Documents/MandS%20LCA%20Final%20Report.pdf.

UK Department for Environment, Food and Rural Affairs, 2011, Sustainable Clothing Action Plan,

London, viewed 17th

May 2011, http://www.defra.gov.uk/publications/2011/03/30/pb13206-

clothing-action-plan/.

UK Department for Environment, Food and Rural Affairs, 2011, Sustainable Clothing Roadmap:

Progress Report 2011, viewed 17 May 2011,

http://archive.defra.gov.uk/environment/business/products/roadmaps/documents/clothing-

actionplan110317.pdf

Diviney, E & Lillywhite, S, 2009, Travelling textiles: A sustainability roadmap of natural fibre

garments, viewed 17 May 2011,

http://thehub.ethics.org.au/uploads/files/BSL_Travelling_Textiles_%20Garment_PRM_Report.pdf.

Diviney, E & Lillywhite, S, 2007, Ethical Threads: Corporate social responsibility in the Australian

garment industry, Brotherhood of St Laurence, Melbourne, viewed 17 May 2011,

http://www.bsl.org.au/pdfs/DivineyLillywhite_ethical_threads.pdf.

Diviney, E & Lillywhite, S, 2009, Corporate responsibility and stakeholder governance: Relevance to

the Australian garment sector, in Fair Trade, Corporate Accountability and Beyond: Experiments in

Globalising Justice.


Draper, S, Murray, V & Weissbrod, I, 2007, Fashioning sustainability: a review of the sustainability

impacts of the clothing industry, Forum for the Future, London, viewed 17 May 2011,

http://www.forumforthefuture.org.uk/files/Fashionsustain.pdf.

Ecolabel Index, 2011, viewed 17 May 2011, http://www.ecolabelindex.com.

Fletcher, K, 2008, Sustainable fashion and textile design journeys, Earthscan, London.

Golden, J (Ed), 2010, An Overview of Ecolabels and Sustainability Certifications in the Global

Marketplace (interim report), Corporate Sustainability Initiative, Nicholas Institute for

Environmental Policy Solutions, Duke University, Durham, viewed 17 May 2011,

http://www.sustainabilityconsortium.org/wp-

content/themes/sustainability/assets/pdf/Ecolabels_Report.pdf.

International Finance Corporation (IFC), 2007, Environmental health and safety guidelines, IFC,

viewed 17 May 2011,

http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines.

Hiscox, MJ & Smyth, NFB, 2005, Is there Consumer Demand for Improved Labor Standards?

Evidence from Field Experiments in Social Product Labeling, Harvard University.

Jadav, A & Ajmera, N, 2009, Cost effectiveness in textile processing, Fibre 2 Fibre, viewed 17 May

2011, http://www.fibre2fashion.com/industry-article/4/316/cost-effectiveness-in-textile-

processing1.asp.

Madsen, J, Hartlin, B, Perumalpillai, S, Selby, S & Aumonier, S, 2007, Mapping the evidence on

sustainable development impacts that occur in life cycles of clothing: a report to the Department for

Environment, Food and Rural Affairs, Environmental Resources Management Ltd, DEFRA, London,

viewed 17 May 2011,

http://randd.defra.gov.uk/Document.aspx?Document=EV02028_7073_FRP.pdf.

Moussa M, 2009, Environmental impacts of textile industries, section 3 of Process analysis of textile

manufacturing, UNESCO – IHE, Delft, Netherlands.

WRAP, 2011, Sustainable Clothing Roadmap and Action Plan, viewed 17 May 2011,

http://www.wrap.org.uk/business/sustainable_clothing.html.


Appendix A: Credibility Principles for Sustainable Production Compliance

Programs

Credibility principles were explored in part one of the Research & Analysis section, and are also part

of the assessment of existing compliance programs in Appendix B. The use of credibility principles

also underpins the proposed roadmap.

The three core ‘principles’ proposed here, are:

i. It is a multi-stakeholder driven and owned program, or is established and run through

credible Government processes

ii. It has public standards for compliance

iii. Verification is undertaken by parties independent from the company being certified,

preferably with a credible, transparent system (e.g. ISO 65)

Other considerations might include whether the compliance program is meaningful, consistent and

clear in its application, has no conflicts of interest within the major parties to the program, and

whether it is open to public consultation on standard development.

It is important to determine a set of ‘credibility principles’ so as to agree what compliance

programs provide credible, valid information along the TCF supply chain – given just how many

sustainability claims and tools are now on offer.

The ISEAL Alliance, the peak body for credible voluntary social and environmental standards

systems is in the process of producing what it is calling ‘High Level Credibility Principles’ for

sustainability claims. Once produced, this could be utilised by those pursuing the implementation

of an EQM in whatever form.

The science based life cycle assessment tools being developed and applied by the Sustainable

Apparel Coalition (i.e. extending the EcoIndex) and the Sustainability Consortium can also inform

the criteria implemented here in Australia.

It is recommended that credibility criteria used in the roadmap model in this report match global

consensus on the best tools available to ensure Australian developments are:

• multi-stakeholder owned and run

• ‘good practice’

• have global credibility

• facilitate global market access; and

• make it easier for Australian companies – given their smaller demand pull relative to other

European or North American operators – to access compliant supply chains.


Appendix B: Selected Existing Certifications & Compliance Programs for Assessing Ethical & Environmentally

Sustainable Production in the TCF Industries

Credibility Supply Chain Area

Certification/Program Multi-

stakeholder

or Gov’t

Public

Standards

3rd

Party

Cert

OS

Fibres

OS

Textiles

OS CMT Au

Fibres

AU

Textiles

Au CMT AU

Retail

AU Use

Ethical Production Compliance Programs and Certifications


www.ethicalclothingaustralia.org.au X X X X X

SA8000 www.sa-intl.org X X X X X X X

Fair Wear Foundation fairwear.org X ? X X

Fair Labor Association www.fairlabor.org X X X X X

GoodWeave International www.goodweave.net X X X X X

Better Work Programme / Better Factory Program

www.betterwork.org X X X

Textile, Clothing, Footwear & Associated Industries

Award X X X X X

Combined Ethical & Environmental Compliance Programs & Certifications

Global Organic Textile Standard www.global-

standard.org ? ? X X X X X X X

Fairtrade Mark www.fairtrade.net X X X X

Good Environmental Choice Label Australia

www.geca.org.au X X ? X X

Made-by www.made-by.nl X ? ? X X X

BMP Cotton www.bmpcotton.com.au ? ? ? X X

Worldwide Responsible Accredited Production

www.wrapcompliance.org ? ? X X X X X


Credibility Supply Chain Area

Certification/Program Multi-

stakeholder

or Gov’t

Public

Standards

3rd

Party

Cert

OS

Fibres

OS

Textiles

OS CMT Au

Fibres

AU

Textiles

Au CMT AU

Retail

AU Use

Environmental Compliance Programs & Certifications

Oeko-Tex 100, 1000, and 100+ standards www.oeko-

tex.com ? X X X X X X

ISO 14001 www.iso14000-iso14001-environmental-

management.com/iso14000.htm X X X X X X X X ?

Certified Organic (various organic certifiers) e.g.

www.australianorganic.com.au, www.nasaa.com.au

Also ECO-CERT, BIO, JAS, etc.

X X X X X X X X X

EU Eco-label www.eco-label.com X ? X X X X X X X X

Forest Stewardship Council www.fsc.org X X X X X

The Australian Carpet Classification Scheme -

Environmental Certification Scheme

www.carpetinstitute.com.au

? ? X X X X X

Better Cotton Initiative www.bettercotton.org X X

Australian Packaging Covenant

www.packagingcovenant.org.au X X

Environmental Choice New Zealand www.enviro-

choice.org.nz X ? ? ? X ? X

Blue Angel www.blauer-engel.de X X X X X

MBDC Cradle to Cradle Certification www.mbdc.com X X X X X X X

Ecospecifier Green Tag Certification

www.ecospecifier.org X X X X X X

Carbon Reduction Label www.carbon-label.com X X X

Green Leader Program www.greenleader.ca ? X

Bluesign www.bluesign.com X X X X X X X X

Leather Working Group

www.leatherworkinggroup.com X X X X X X X


Other Relevant Compliance Codes, Programs, Initiatives Details Relevance

ISO 26000

www.iso.org/iso/iso_catalogue/management_standards/social_responsibility.htm

Guidance on social responsibility. Gives guidance to organisations on 7 subjects:

Organisational governance, Human rights, Labour

standards, The environment, Fair operating practices,

Consumer issues and Community involvement and

development.

OECD Guidelines for Multinational Enterprises

http://www.oecd.org/department/0,3355,en_2649_34889_1_1_1_1_1,00.html

Covers all major areas of business ethics,

including corporate steps to obey the law,

observe internationally-recognised standards

and respond to other societal expectations.

Guidelines include Employment and industrial relations,

Human rights, Environment, Information disclosure,

Combating bribery, Consumer interests, Science and

technology, Competition and Taxation.

Global Reporting Initiative www.globalreporting.org Reporting framework - organisational

operations, environmental, economic and

social criteria.

GRI guidelines est. 2000. Sector Supplement still at pilot

stage. In addition to the GRI guidelines, the sector

supplement mentions: Code of conduct content and

coverage, compliance audit process, supply chain

policies, non-compliance with labour standards; Use of

materials, environmentally-preferable materials; Energy

consumed from renewable sources; Employment

standards, wages and hours, diversity and equal

opportunity, adherence to ILO conventions,

labour/management relations, health and safety;

Community investment and Public policy.

Ethical Trading Initiative www.ethicaltrade.org A ground-breaking alliance of companies,

trade unions and voluntary organisations,

working in partnership to improve the lives of

workers across the globe who make or grow

consumer goods.

ETI brings corporate, trade union and voluntary sector

members together in a unique alliance that enables us

to collectively tackle many thorny issues that cannot be

addressed by individual companies working alone.

Implementation of the ETI Base Code address ethical

production in supply chains.

Australasian Furnishings Research & Development Institute (AFRDI Standard 146 -

Leather)

www.furntech.org.au/index.php/commercial-furniture/lether.html

The AFRDI Standard 146 - Leather

Descriptions Furniture Industry was prepared

and released in April 2006 in order to provide

the Australian and New Zealand commercial

and residential furniture industry with a set

of description and performance guidelines

for leather, and with particular focus on

making this information readily available to

the consumer.

Standards for furniture manufacturers to use with

leather specifically the authenticity of leather and

chemical use.



Supplier Ethical Data Exchange (SEDEX) www.sedex.org.uk Database of ethical performance Provides valuation of what companies are doing

Sustainable Apparel Coalition www.apparelcoalition.org The Sustainable Apparel Coalition is an

industry-wide group of leading apparel and

footwear brands, retailers, manufacturers,

non-governmental organizations, academic

experts and the U.S. Environmental

Protection Agency working to reduce the

environmental and social impacts of apparel

and footwear products around the world.

The Sustainable Apparel Coalition’s first major project is

the development of a common, industry-wide tool for

measuring the environmental and social performance of

apparel products and the supply chains that produce

them. Founding members of the Sustainable Apparel

Coalition are based in North America, Asia, Europe and

the U.K.

Eco-Index www.ecoindexbeta.org The Eco Index is a ground-breaking

environmental assessment tool designed to

advance sustainability practices within the

outdoor industry. It provides companies

throughout the supply chain a way to

benchmark and measure their environmental

footprint, allowing them to identify areas for

improvement and make informed sourcing

and product life cycle decisions.

This index is being taken and expanded – potentially – to

other apparel, in collaboration with the Sustainable

Apparel Coalition.

ILO Conventions www.ilo.org The ILO is the international organization

responsible for drawing up and overseeing

international labour standards. It is the only

'tripartite' United Nations agency that brings

together representatives of governments,

employers and workers to jointly shape

policies and programmes promoting Decent

Work for all. This unique arrangement gives

the ILO an edge in incorporating 'real world'

knowledge about employment and work.

The main aims of the ILO are to promote rights at work,

encourage decent employment opportunities, enhance

social protection and strengthen dialogue on work-

related issues.

Very active in labour rights in TCF supply chains,

especially garment manufacture. Works with

governments and other international NGOs and

multilateral bodies.

Nordic Initiative Clean and Ethical www.nicefashion.org Pan-Nordic initiative to achieve a clean and

ethical fashion sector

10 year plan, consumer tools, business tools – lots of

similarities to what could be done in Australia.

Business Social Compliance Initiative http://bsci-eu.org Business-driven initiative for companies

committed to improving working conditions

in the global supply chain. Unites 700+

companies around a development-oriented

system applicable to all sectors and sourcing

countries.

Applicable to TCF industries sourcing from outside

Australia. Provides a Code of Conduct and step-by-step

progress towards achieving an ethical supply chain.

Australian Made www.australianmade.com.au A program to identify products made in

Australia

Product labelling available to TCF products

manufactured in Australia



The Design Accord www.designersaccord.org The Designers Accord is a global coalition of

designers, educators, and business leaders,

working together to create positive

environmental and social impact.

The Designers Accord was founded with the goal of

changing the way the creative community does

business. Designers, educators, and business leaders

adopted a “Kyoto Treaty” of design (later renamed the

Designers Accord) that specified a particular ethos and

behaviour around sustainable design.

* 761 Design Firm Adopters

* 39 Educational Institution Adopters

* 40 Corporate Adopters

* 100 Countries

* 6 Continents

* All design disciplines

DEFRA’s Sustainable Clothing Action Plan www.defra.gov.uk A UK government program to reduce the

social and environmental impacts of the

clothing industry

Addresses environmental impacts including energy use

and generation of GHG emissions from washing and

drying of clothes; energy use; resource depletion and

generation of GHG emissions from processing fossil fuels

into synthetic fibres; significant water use; toxicity from

fertiliser, pesticide and herbicide use; energy use and

GHG emissions associated with fertiliser generation and

irrigation systems from fibre crops, e.g. cotton, water

use; toxicity; hazardous waste and effluent associated

with production stage; pre-treatment chemicals, dyes

and finishes and waste. It also addresses social impacts

such as working conditions, child labour, trade inequities

and animal welfare, limited market access and

information for farmers and workers leading to

inequitable trading conditions.

DFID Responsible & Garment Sector Challenge Fund (RAGS) www.dfid.gov.uk A funding initiative from the UK government The Responsible and Accountable Garment Sector

(RAGS) Challenge Fund supports projects aimed at

improving conditions of vulnerable workers in the ready-

made garment (RMG) production sector. The fund aims

to benefit workers in low- and lower-middle-income

countries in Asia and Sub-Saharan Africa that supply the

UK market



Restricted Substances Lists for textiles, apparel, and footwear including

http://www.apparelandfootwear.org/Resources/restrictedsubstances.asp &

http://www.afirm-group.com/faq.htm

Various codes and supplier requirements by

textile, apparel and footwear brands on

substances being used in their supply chains

There are a growing number of Restricted Substances

Lists applicable to textiles, apparel and footwear

imposed by companies such as Adidas and Nike on their

suppliers. These Lists aim to eliminate substances

harmful to those involved in the supply chain and

customers.

UN Global Compact www.unglobalcompact.org Principles that businesses sign up to. Human rights, labour, environment and anti-corruption


Appendix C: EQM Feasibility Study – Online Stakeholder Survey Questions

General Information

1. Please fill out your details below:

Name:

Organisation:

Position:

Email:

Phone:

Website:

2. * Which sector best describes your role?

� Manufacturing

� Brand owner

� Retailer

� Importer

� Designer

� Union

� Education and research

� Industry and professional association

� Government

� Environment or consumer organisation

� Other (please specify):

3. * Which product category are you primarily involved with?

� Fashion and apparel

� Footwear

� Commercial textiles

� Technical textiles and non-woven

� Leather

� Carpet and other floor-coverings

� Other

CONTEXT

4. * Environmental issues are of great concern to the TCF industries:

� Strongly agree

� Agree

� Undecided

� Disagree

� Strongly disagree


5. * What do you believe to be the three most significant environmental issues resulting from the

textile, clothing and footwear (TCF) industries?

� Land degradation associated with the production of natural fibres

� Emissions to air, water and soil from the production of synthetic fibres

� Emissions to air, water and soil from manufacturing TCF products

� Energy consumption and associated carbon emissions/global warming

� Consumption of non-renewable resources

� Hazardous and/or toxic substances used in the manufacture of TCF products

� Solid waste arising from end-of-life TCF products

� Water consumption during fibre production and product

� Water, energy and detergent consumption during the use phase of TCF products

� Other (please describe):

6. * The environmental performance of the TCF industries in Australia is best described as:

� Creating products which demonstrate best of class environmental features

� Meeting regulatory requirements but not much more

� Pragmatic about improving its environmental commitment and performance

� Having made a strong start but has much more to do

� Diverse with some companies as world leaders, and others as laggards

� Reactive to the market and adopting new initiatives if commercially viable

� Showing few if any measurable environmental improvements and benefits

� Embarrassed about its environmental achievements to date

� Other (please describe):

7. * What do you believe is the most effective way to minimise environmental impacts associated with

the Australian TCF industries?

8. * Do you believe existing Government and Industry initiatives on product safety in the TCF industries

are effective and meeting stakeholders’ needs?

� Yes

� No

� Undecided

� Not aware of initiatives

Please comment on the reason(s) behind your response:


9. * Do you believe existing initiatives in Australia on labour rights in the TCF industries are effective

and meeting stakeholders’ needs?

� Yes

� No

� Undecided


Please comment on the reason(s) behind your response:…………………………

10. * Do you believe overseas manufacturers and brands should be held to the same labour rights

standards and requirements as local manufacturers i.e. those producing products in Australia?

� Yes

� No

� Undecided



WHAT SHOULD BE DONE

11. * Which of the following initiatives do you believe are best placed to improve the environmental

performance of TCF products in Australia?

� Voluntary Environmental labels

� Environmental regulations

� Government support to industry

� Voluntary industry-driven programs

� Training and professional development

� Nothing new should be done i.e. business as usual

� Other (please describe

12. * A new voluntary Environmental Label for the TCF industries is much needed in Australia:

� Strongly agree

� Agree

� Undecided

� Disagree


Please comment on the reason(s) behind your response: …………………………

13. * What do you believe are positive and/or negative outcomes associated with a voluntary

Environmental Label for the TCF industries in Australia?

Positive outcomes:…………………………

Negative outcomes:…………………………


14. * Can you provide an example of similar environmental labels for other products/sectors in

Australia? Describe why you believe they have been successful or unsuccessful, highlighting any

specific challenges:

WHY IT SHOULD BE DONE

15. * Consumer demand is the key driver for developing a new Environmental Label in Australia:

� Strongly agree

� Agree

� Undecided

� Disagree



16. * The need to address labour rights issues AND environmental issues is a priority for TCF companies

in Australia:

� Strongly agree

� Agree

� Undecided

� Disagree



17. * An effectively promoted voluntary Environmental Label will play a key role in helping consumers

make environmentally informed purchasing decisions:

� Strongly agree

� Agree

� Undecided

� Disagree



18. * A new voluntary Environmental Label would play a major role in improving the environmental

performance of TCF products in the Australian market:

� Strongly agree

� Agree

� Undecided

� Disagree




WHO SHOULD DO IT

19. * Which stakeholder/s brings the most independence and credibility to the design of a voluntary TCF

based Environmental Label?

� Australian Government

� Educational/academic organisations

� Environment and consumer NGOs

� Industry and professional associations

� Research organisations

� State and Territory Governments

� Unions

� A combination of the above (please list which combination:…………………………

20. * Which stakeholder/s brings the most independence and credibility to the administration of a

voluntary Environmental Label?

� Australian Government

� Educational/academic organisations

� Environment and consumer NGOs

� Industry and professional associations

� Research organisations

� State and Territory Governments

� Unions

� A combination of the above (please list which combination):…………………………

21. * Which stakeholders have the most to gain or lose from a new voluntary Environmental Label?

Most to gain:…………………………

Most to lose:…………………………

HOW SHOULD IT BE DONE

22. * What do you believe is the most significant factor in designing a successful voluntary Environmental

Label for the TCF industries in Australia?

23. * What do you believe is the single most significant factor in administering a successful voluntary


24. * What do you believe are the key barriers to the successful design and adoption of a new voluntary



25. * Accreditation to a new voluntary Environmental Label is the most effective way to make the TCF

industries more sustainable:

� Strongly agree

� Agree

� Undecided

� Disagree



26. * An adequately resourced Environmental Label program is best achieved through a:

� Royalties-based approach i.e. a charge per unit or product sold

� One-off certification fee renewed every three years

� An annual application fee

� Undecided

� Other


BUSINESS, CONSUMERS AND TIMING

27. * Companies in the TCF industries are likely to be very enthusiastic about the potential for a new

voluntary Environmental Label:

� Strongly agree

� Agree

� Undecided

� Disagree



28. * A new voluntary Environmental Label should only be available to TCF companies manufacturing in

Australia:

� Strongly agree

� Agree

� Undecided

� Disagree




29. * A new voluntary Environmental Label should be available to any manufacturer, importer, brand

owner or retailer supplying the Australian market:

� Strongly agree

� Agree

� Undecided

� Disagree



30. * A new voluntary Environmental Label could be successfully designed and launched inside:

� 1 year

� 2 years

� 3 years

� Other (please describe):…………………………

31. * What do you believe are the major opportunities and benefits of a new Environmental Label for

the TCF industries in Australia?

FUTURE OPTIONS FOR A TCF ENVIRONMENTAL LABEL IN AUSTRALIA

The following questions are optional and require some knowledge of the existing Ethical Clothing Australia

labour rights-related accreditation program.

Please read the following options carefully, and use them to provide responses to the questions below.

Option 1. Expansion of the current Ethical Clothing Australia (ECA) labour rights related label to include

environmental/sustainability accreditation as an optional adjunct to the current labour rights accreditation

for the local textile, clothing and footwear industries.

Option 2. Transformation of the current Ethical Clothing Australia label so that the primary focus of the new

label is an environmental/sustainability accreditation while still accrediting members for upholding labour

rights for the local textile, clothing and footwear industries.

Option 3. Development of an environment/sustainability accreditation for the local textile, clothing and

footwear industries that is separate from Ethical Clothing Australia.

32. Which of the three options outlined above is most likely to be attractive to consumers?

� Option 1

� Option 2

� Option 3

� None of the options



33. Which of the three options outlined above is most likely to be attractive to TCF companies?

� Option 1

� Option 2

� Option 3



34. Of the three options outlined above which has the highest risk of failure or low-level adoption by

TCF companies?

� Option 1

� Option 2

� Option 3


� Other (please describe) …………………………

35. Of the three options outlined above which has the highest chance of widespread adoption by TCF

companies?

� Option 1

� Option 2

� Option 3



OTHER ISSUES

36. Are there any other issues, views, ideas, suggestions or concerns you wish to raise? If yes, please

elaborate below.


Appendix D: Stakeholder Consultation Summary Data & Selected EQM Survey

Finding Tables

Appendix D documents summary data from the stakeholder consultation interviews and workshops, as well

as selected data tables from the online survey.

Interview Responses

Several respondents talked about the need for simplicity in whatever is done without ‘dumbing down’ the

process or outcomes. At the same time it was noted that ‘starting from scratch’ was not desirable or viable

given that resources and time are limited i.e. avoid re-inventing the wheel if related, similar or compatible

initiatives already exist, provided they were ‘rigorous and robust’.

There appeared to be moderate support for a voluntary EQM among most but not all respondents. Support

was often given with caveats and conditions. While some believed it could hold potential, there was also a

minority view that did not see sufficient value across all TCF industries. Some respondents remained

neutral about the need and justification for a voluntary EQM, however they acknowledged that it may be

more relevant in some TCF product categories than in others.

Avoiding confusion in the industry was also considered important in any future work i.e. having too many

options might not deliver consistent or measurable outcomes and improvements. Too many options might

also result in some business choosing the cheapest, easiest and least rigorous standards and certification

schemes.

Some respondents believed that integrity of compliance with any new scheme would be critical, and that

the current ‘joint stakeholder management’ structure of ECA accreditation works very well. It was claimed

that this existing structure works effectively and could be modified to include other interests and

stakeholders in order to address other product categories as well as specific technical and scientific

expertise.

One respondent was very clear about the need to maintain, nurture and further grow the uptake of the

existing ECA accreditation program, and to ensure that any new voluntary EQM did not undermine or

cannibalise the existing labour rights focussed initiative. The same respondent was also of the view that any

new voluntary EQM should remain primarily focussed on supporting and developing Australian

manufacturing and local employment. It was also noted that the extent to which the worker’s voice was

being heard as part of the study was limited, yet workers are directly affected by such initiatives.

One respondent directly involved in TCF manufacturing noted that much work has been done around

environmental management and cleaner production for TCF related companies, and that such schemes and

programs should be more seriously considered as part of any detailed EQM development process.

A key decision maker and business owner involved with manufacturing highlighted that the focus of any

future voluntary EQM should be on product safety and human health issues associated with finished

product as well as production processes.


One respondent was of the view that they had been through a similar process and were well advanced on

product safety and environmental issues compared to other sectors within the TCF industries. The same

respondent noted its significant investment of funds, time and expertise over the last two decades resulting

in its own product-specific environmental programs. It was their view that a TCF industries-wide EQM

would do little to enhance their current activities and outputs.

Regardless of any specific solution, program design or EQM, several respondents believed that a ‘level

playing field’ was essential. It was considered imperative that any initiative would need to be applied in a

fair and equitable manner across the industries, whether the product was made in Australia or overseas.

The need to avoid creating any new initiative that resulted in a competitive disadvantage for local

manufacturers compared to importers was seen as important.

One respondent noted that an EQM would further aggravate existing business challenges and be a

‘backward’ step. The same respondent believes that this feasibility study starts from an incorrect premise

and that much of the industry did not support Professor Green’s recommendation in 2008.

A common issue raised among several respondents (chiefly from business) was the absence of any

significant evidence or drivers in support of an EQM and the necessary investment to design and administer

such a program. In other words, it is currently perceived as a cost with little benefit to those who would be

potentially affected by it.

A view from some business respondents also characterised a voluntary EQM as something ‘warm and

cuddly’ driven by altruistic motivations rather than justifying its measurable benefits to the environment,

business, human health and consumers.

One respondent noted that even the existing ECA program and its focus on labour rights was irrelevant to

its sector, and questioned why it should be imposed indirectly through procurement processes.

A respondent involved in manufacturing raised the issue of effective monitoring and ‘policing’ and the

difficulties with ensuring effective enforcement of manufacturers, importers, brand owners and retailers to

prevent them making misleading claims (e.g. greenwash) in the market place. An example was cited where

even the ACCC failed to pursue an issue related to product safety and environmental claims leaving the

supplier in question to promote a questionable product to consumers.

Some respondents from business noted that within their product category, there was little or no demand

or interest for EQM-type information from buyers, retailers, and consumers generally.

Several respondents noted that existing initiatives and certification schemes available overseas and in

Australia could be used more effectively as part of any process to advance the environmental, product

safety and ethical performance of Australian TCF companies.

The majority of respondents acknowledged that diversity within the TCF industries provided a challenge to

designing, administering and funding a ‘one-size-fits-all’ EQM solution that has relevance to all sub-sectors

and products categories i.e. a potentially effective voluntary EQM for clothing or possibly footwear for the

business-to-consumer market might not be effective with commercial textiles and non-wovens for the

business-to-business market.

It was also evident that some respondents were very clear on the drivers and demands for EQM type

initiatives and how they relate to specific environmental, product safety and labour rights issues.


A respondent involved with TCF manufacturing highlighted that more opportunities need to be exploited at

the research, design and development stage of the process, and that product sustainability objectives

related to durability, longevity and extended product life, could contribute to improved environmental and

sustainable resource use outcomes.

One respondent felt that very little work had been undertaken by the TCF industries as a whole, to find

common ground in relation to environmental issues, including carbon related issues. The same respondent

believed that many of the answers and solutions rested with effective regulation as opposed to voluntary

initiatives, which can suffer from limited industry uptake. The same respondent believed that the ‘ideal

next step’ would be a regulatory framework underpinned with significant resources, and a strong education

and capacity building component. Meeting existing requirements for labour standards should remain a pre-

requisite to obtaining or meeting any environmental standards.

One respondent noted that they were not in a position to manage compliance in relation to environmental

requirements and this would require specific expertise as part of any new initiative. Furthermore, the

respondent believed that any new scheme requires a multi-stakeholder management structure to ensure

compliance integrity and transparency.

The same respondent noted that they will always have the view that environmental issues cannot be done

at the expense of labour rights, and that we have to start with those issues where there is realistic control

and influence i.e. ‘manufacturing on shore’. The respondent also emphasised that something positive had

to be done to ‘create jobs in Australia, not lose them’, and ‘if there is no requirement for local production,

how does this create jobs?’

One respondent believed that a global environmental label would have more advantages than creating a

new EQM just for Australia. The same respondent also felt that regulations, government support for

industry, and voluntary industry driven initiatives, are better placed to improve the environmental

performance of TCF products in Australia, compared to environmental labels.

Several respondents suggested several successful labelling schemes as either relevant to TCF or as a

noteworthy model. These included: Good Environmental Choice Australia and Australian Certified Organic,

the ACCS Environment Certification Scheme for Carpets, Oeko-Tex and the Energy Star Rating Scheme.

The majority of industry respondents did not believe that a new voluntary EQM would help improve the

performance of Australian TCF companies, nor did they believe that consumer demand is a major driver.

Another stakeholder involved with TCF manufacturing in Australia believed that while a voluntary EQM is

needed and should be developed quickly, the respondent also felt that regulation was the most effective

method for requiring companies to meet environmental performance standards.

One respondent involved with the leather industry believed that Australia is operating at world’s best

practice in terms of environmental standards and performance. This is a result of the sector being a highly

regulated space, as well as stringent demands from product manufacturers. The same respondent believed

that regulation and government support to industry and training would be best placed to improve the

environmental performance of TCF products in Australia. They remained undecided as to whether a new

EQM label is necessary.


Workshop Results

The workshop process was built around four key questions as a way of generating discussion and

facilitating an inclusive forum for idea generation and debate. The feedback from the workshops is

summarised under each of the four questions below.

Workshop Question 1: “What is happening today to create more ethical and environmentally sustainable

TCF products and services that excites you, both here in Australia and around the world?”

Ideas and Observations from the Participants

• Growing influence of cradle to grave management or life cycle thinking. This contributes to the

approach with Eco-Index and the Sustainable Apparel Coalition.

• Good examples exist of producers and suppliers of upholstery and carpets in Australia, as driven by

Green Star rating tools and the Green Building Council of Australia.

• More manufacturers are asking supply chains to improve their standards; increased corporate social

responsibility reporting.

• Labels such as OEKO-TEX are making it possible to identify harmful substances and avoid them.

• Large companies are being proactive, and there is increasing leadership from big corporates such as

Marks & Spencer (i.e. Plan A), Gap.

• Increasing collaboration between organisations working on similar issues e.g. Eco-Index is a good

example of sharing and collaboration in relation to textiles and sustainability.

• ECA is setting new standards for cleaning up the industry and having a positive effect.

• Individual TCF companies are taking action by themselves and gaining ECA accreditation.

• Big trend towards SA 8000 (Social Accountability) in South East Asia; China is increasing its investment

in ‘sustainability’ and the debate is starting to move beyond ‘minimum wages’.

• Development of ‘Made in Melbourne’ as an opportunity.

• Increased visibility of social and environmental impacts via documentaries, blogging, activism.

Issues and Concerns Identified by the Participants

• Much more development overseas than here at the moment, and overseas consumers are more

engaged; ‘Ethical’ doesn’t need to mean ‘Australian made’.

• Gen Y consumers seem to be more receptive to such issues.

• Consumers say they want Australian made, but will still buy cheap imports.

• There is potential for government to use local resources, but it appears they are looking for cheaper

prices instead.

• The message needs to be simplified to become ‘mainstream’. We run the risk of not building on what

we’ve already done. The challenge is the balance between access and credibility.

• There is a very complicated subset of people purchasing clothes; need to address this issue.

• Retailers must understand that the risk of not being involved is greater than being involved.

• Much more could be done with government initiatives.

• Design quality should not be undermined. It can be undermined through ‘greenwash’.

• There is an absence of drivers and significant demand for an EQM; it’s yet another cost with no

certainty on a return.


• Major buyers and consumers aren’t interested in an EQM.

Workshop Question 2: “How can we get more of these exciting actions to create more ethical and

environmentally sustainable TCF products and services happening in Australia?”


• Don’t reinvent the wheel; adopt models, schemes and labels from other parts of the world.

• Develop a better understanding of what the specific issues and impacts are.

• Government policy change, support and endorsement, including legislation and tariff changes.

• Use the carbon tax as an opportunity.

• Education and training including ‘green’ education for designers.

• Target different segments and generations of consumers (particularly children).

• Help consumers understand the value of clothing and create demand e.g. Country Road.

• Use business registration as a check-point to provide people with education and training.

• Make green ‘sexy’ without greenwashing; use soft clever marketing using social technology.

• Mainstream the message to reach the most people (but dealing with complex consumer base).

• Buy less at better quality. We have moved into throwaway society (on the cusp of slowly turning

back?).

• Help people change their lifestyles and values.

• Have engagement across all areas of what is being improved (chicken and egg: education and product

availability) and promote more active engagement across the world. Take a holistic approach.

• Engage and educate by targeting businesses and consumers simultaneously; use government policy and

programs to achieve this.

• Effective carrot and stick approaches i.e. regulation + incentives + good business case studies.

• Understand what motivates commitment from retailers and manufacturers; connect the business case

to the ethical/environmental case.

• Assess the potential of business moving from a product-based business model to a service-based model

e.g. new revenue streams through mending, servicing, leasing clothing.

Issues and Concerns Identified by the Participants

• Do consumers and companies understand the difference between ‘ethical’ and ‘environmental’?

• Is this issue about saving the ‘environment’ or saving the ‘industry’?

• Europe is looking at a global label that brings in environmental factors.

• If things are environmental and ethical, does that mean that they will be recyclable?

• If this is a fashionable thing, does the industry embrace it at a surface or deeper level? Run the risk of

green-washing the conversation.

• Australian consumers don’t understand how big this issue is already.


Workshop Question 3: “Looking at the actions we’ve identified: how desirable and feasible is each option?”


Highly desirable and highly feasible Highly desirable but low-medium feasibility

EQM – building on existing initiatives

Import overseas expertise

Assist small business with education and training

Government subsidies and programs

Cadetships in TCF industries

Improve enforcement of existing standards

Give consumers more information, and increase

national pride (e.g. through marketing – target

emotional areas [baby products])

Increase in regulation

Government procurement policy for locally made

Deeper understanding of issues

Incentives for locally made

New innovations for the industry

Free Trade Agreement’s need to include ethical &

environmental sustainability considerations

Investment in development of training and

knowledge products for designers and new

businesses

Create/greater international partnerships

Change in tariffs

Transparency in Government procurement (subsidies

etc)

Tax concessions for sustainable business

Incentives to buy locally produced materials

Mentoring to industry by experienced people

Carbon tax to support local product

Workshop Question 4: “How would you design the EQM so that it was more desirable and feasible, and

contribute to creating thriving and viable TCF industries?”


• Early Innovation meetings were all about promoting Australian product for export; how did we move

from wanting to achieve a ‘Brand Australia’ Mark (to promote Australian made product) to an EQM?

And how did this become something we might accredit companies for – locally and/or globally?

• An EQM is one piece of work and ‘Brand Australia’ is another piece of work; they are separate but

related. Achieving an EQM doesn’t necessarily mean you’re achieving ‘Brand Australia’; they are two

things along a continuum.

• That we import a billion units of clothing into Australia every year (there are only a few companies that

actually knit the stuff here) means the logistics of the supply chain need to be considered. Are we going

to accredit the product or the company? There are so many links in the supply chain, where do you

ring-fence this on an international and domestic scale?

• Is it about social and environmental output, input and impact?

• Talking to companies informs the process; while initially supportive of an EQM its important to

investigate how it would actually work.

• Use a rating scale (e.g. Energy Star); companies should not be given only a ‘yes’ or ‘no’.

• Something that could be used at different stages, but could not get to the consumer point/be put on a

product until the company has reached at least 90 % accreditation.

• A label with an environment and ethics component, with various different facets.

• What constitutes the two different categories - ‘environment’ and ‘ethics’?

• Use one of the many highly successful labels from overseas, many have set the precedent for improving

companies profitability, longevity and impact on the environment.

• No label is really enough.


• Keep it small and tight to start off with, a select number of small companies with small supply chains

could get accredited first (to maintain credibility). This would set standards, and could be built upon.

The full supply chain would need to be involved to maintain the integrity and credibility of the EQM

(couldn’t have everything ticked, and still have yarn being made by child labour, wouldn’t be

reasonable in terms of public expectation). Could work along a continuum to get accredited.

• An EQM would need to target the majority of Australian clothing.

• Enable consumers to research the supply chain of a garment.

Online Survey Data

Below are tabulations of survey responses not included in text as part of Research & Analysis, 2. Australian

TCF Industries Stakeholder Consultations.

The following results represent a sample of the key questions and scenarios posed in the online survey.

The results are sampled against the key themes i.e. Context; What should be done; Who should do it etc.

This section seeks to provide a summary of the main questions, the primary findings and the study team’s

conclusions.

Context

Which sector best describes your role? Response percent Response count

Manufacturing 15.3 % 17

Brand owner 6.3 % 7

Retailer 8.1 % 9

Importer 5.4 % 6

Designer 10.8 % 12

Union 19.8 % 22

Education and research 9.9 % 11

Industry and professional association 5.4 % 6

Government 0 % 0

Environment or consumer organisations 4.5 % 5

Other 14.4 % 16

Highest participation in any single category came from Union officials and members (19.8 %), which is likely

to reflect their interest in, and involvement with, labour rights issues and the associated Ethical Clothing

Australia accreditation program. It is important to note that the combined representation of business i.e.

manufacturers, brand-owners, retailers and importers, totalled 35.1 %. As a result business and union

interests dominated the survey responses.

Which product category are you primarily involved with? Response percent Response count

Fashion and apparel 52.2 % 58

Footwear 6.3 % 7

Commercial textiles 5.4 % 6

Technical textiles and non woven 1.8 % 2

Leather 3.6 % 4

Carpet and other floor coverings 4.5 % 5

Other 26.1 % 29


The majority of respondents considered themselves to be most directly involved with fashion and apparel

at 52.2 %, with relatively low counts being associated with the other product categories. This may be a

result of several factors including: significant media and editorial coverage of the survey in clothing and

fashion related publications; high participation of Union officials and members involved with ECA

accreditation; and available stakeholder contact lists featuring a greater percentage of fashion and apparel

related organisations.

Environmental issues are of great concern to the TCF

industries



Agree 18 % 20

Undecided 8.1 % 9

Disagree 8.1 % 9


A total of 63.9 % of respondents either agree or strongly agree that environmental issues are of great

concern to the TCF industries. This represents a significant count and is likely to influence views, positions

and opinions related to subsequent questions and scenarios. There is clearly a strongly feeling of ‘industry

interest, concern and responsibility’ among respondents.

What do you believe to be the three most significant

environmental issues resulting from the TCF industries?


Land degradation associated with the production of natural

fibres

9.9 % 11

Emissions to air, water and soil from the production of synthetic

fibres

7.2 % 8

Emissions to air, water and soil from manufacturing TCF products 22.5 % 25

Energy consumption and associated carbon emissions/global

warming

46.8 % 52

Consumption of non-renewable resources 19.8 % 22

Hazardous and/or toxic substances used in the manufacture of

TCF products

48.6 % 54

Solid waste arising from end-of-life TCF products 42.3 % 47

Water consumption during fibre production and product

manufacture

14.4 % 16

Water, energy and detergent consumption during the use phase

of TCF products

17.1 % 19

Other 13.5 % 15

The issue of ‘hazardous and/or toxic substances used in the manufacture of TCF products’ was considered

the most significant environmental issue among a large group of respondents at 48.6 %. This response is

also consistent with general and anecdotal concerns related to overall product safety issues for both

workers and consumers. Concern about ‘energy consumption and associated carbon emissions/global

warming’ was also seen as significant with 46.8 % of respondents nominating it as a major environmental

issue. Given the nature of fashion and typically short life cycles for many clothing items, it is not surprising

that 42.3 % of respondents also considered ‘solid waste resulting from end-of-life TCF products’ as a

significant issue.


The environmental performance of the TCF industries in

Australia is best described as:


Creating products which demonstrate best of class

environmental features

1.8 % 2

Meeting regulatory requirements but not much more 9 % 10

Pragmatic about improving its environmental commitment and

performance

9 % 10

Having made a strong start but has much more to do 2.7 % 3

Diverse with some companies as world leaders, and others as

laggards

8.1 % 9

Reactive to the market and adopting new initiatives if

commercially viable

18 % 20

Showing few if any measurable environmental improvements

and benefits

26.1 % 29

Embarrassed about its achievements to date 5.4 % 6

Other 1.8 % 2

A relatively high number of respondents were not overly positive about the environmental performance of

Australia’s TCF industries with 26.1 % believing that ‘few if any measurable improvements and benefits’

were being achieved. This may also reflect a lack of knowledge and awareness of positive industry-wide

environmental initiatives underway in the carpet industry and those manufacturers and suppliers of

commercial textiles. In contrast, a relatively small percentage of respondents categorised the industries as

‘creating products which demonstrate best of class environmental features’.

Do you believe existing Government and industry initiatives on

product safety in the TCF industries are effective and meeting

stakeholders’ needs?


Yes 9 % 10

No 33.3 % 37

Undecided 11.7 % 13

Not aware of initiatives 27.9 % 31

A significant number of respondents were either unaware of Government and industry initiatives related to

product safety in the TCF industries (27.9 %), or believed that existing initiatives were not ‘effective and

meeting stakeholders’ needs’ (33.3 %). These results are consistent with earlier results that highlighted that

respondents were concerned about hazardous and/or toxic substances.

Do you believe existing initiatives in Australia on labour rights

in the TCF industries are effective and meeting stakeholders’

needs?


Yes 39.6 % 44

No 16.2 % 18

Undecided 14.4 % 16

Not aware of initiatives 11.7 % 13


In contrast, a significant number of respondents (39.6 %) believed that existing labour rights initiatives in

the TCF industries were ‘effective and meeting stakeholders’ needs’. This is most likely due to the high

number of union officials and members that participated in the survey, combined with a high number of

‘fashion and apparel’ participants. It could be concluded that these results tend to indicate indirect support

for the existing ECA accreditation program.

Do you believe overseas manufacturers and brands should be

held to the same labour rights standards and requirements as

local manufacturers?


Yes 63 % 70

No 10.8 % 12

Undecided 8.1 % 9

With 63 % of respondents believing that local and overseas manufacturers should be subject to the same

labour rights requirements, it could be concluded that a level ‘playing-field’ without any exemptions is a

priority issue for the majority of survey respondents.

What Should be Done

Which of the following initiatives do you believe are best

placed to improve the environmental performance of TCF

products in Australia?


Voluntary environmental labels 15.3 % 17

Environmental regulations 52.2 % 58

Government support to industry 59.4 % 66

Voluntary industry-driven programs 15.3 % 17

Training and professional development 26.1 % 29

Nothing new should be done i.e. business as usual 1.8 % 2

Other 12.6 % 14

There is considerable support among the majority of respondents (59.4 %) for ‘Government support to

industry’ as a key initiative, which can improve the environmental performance of TCF products in

Australia. Also noteworthy, is the view among 52.2 % of respondents that ‘Environmental regulations’ is an

important tool in achieving environmental improvement. 15.3 % of respondents believed that a ‘voluntary

environmental label’ would be best placed to deliver environmental improvement.

A new voluntary Environmental Label for the TCF industries is

much needed in Australia



Agree 10.8 % 12

Undecided 19.8 % 22

Disagree 9.9 % 11


As a combined percentage (47.7 %), a relatively high number of respondents either strongly agree (36.9 %)

or agree (10.8 %) that a new Environmental Label is much needed for the TCF industries. These figures

indicate that is more support among respondents than there is opposition to a voluntary EQM.


Can you provide an example of similar environmental labels for other products/sectors in Australia? Describe why

you believe they have been successful or unsuccessful.

By far the dominant example put forward by respondents was the Energy Star rating scheme as used on major

appliances in Australia. This was considered high profile and effective with consumers while also having industry-wide

involvement. It is critical to note that the energy star rating scheme is administered under Federal and State laws and

regulations and is governed by detailed, product specific energy efficiency standards developed by Australian

Standards. Also very popular among respondents was the Australian Certified Organic program.

With regard to TCF specifically, there were minor references to the Sustainable Apparel Coalition and the Australian

Carpet Classification Scheme’s environmental extension – the ACCS Environmental Certification Scheme for Carpets.

The Fair Trade label was also proposed by a few respondents as a successful example, as was some reference to the

Good Environmental Choice Australia certification program.

Plastics recycling symbols were also mentioned in relation to providing consumers with guidance on where and how

to recycle specific plastic types. The Body Shop brand was seen as positive in terms of product safety and prevention

of cruelty to animals.

A small number of respondents mentioned the Woolmark label, Made in Australia, the Heart Tick and the Forest

Stewardship Certification scheme, as other worthy labels and schemes.

Why it Should be Done

The need to address labour rights issues AND environmental

issues is a priority for TCF companies in Australia:



Agree 13.5 % 15

Undecided 9 % 10

Disagree 13.5 % 15


The majority of respondents (54 %) considered that labour rights and environmental issues are a priority for

TCF companies in Australia. Only 17.1 % respondents either strongly disagreed or disagreed with the

‘priority’ view of addressing both labour rights and environmental issues. There is clearly a view that both

issues/impacts should be addressed.

Who Should Do it

Which stakeholder/s bring the most independence and

credibility to the design of a voluntary TCF based environmental

label?


Australian Government 6.3 % 7

Educational/academic organisations 1.8 % 2

Environment and consumer NGOs 4.5 % 5

Industry and professional associations 9 % 10

Research organisations 1.8 % 2

State and Territory Governments 0.0 % 0

Unions 3.6 % 4

A combination of the above 50.4 % 56


As a single entity, ‘industry and professional associations’ were the single biggest group (9 %) who were

considered to bring independence and credibility to the design of a TCF based environmental label,

however the vast majority of respondents (50.4 %) believed that a combination of organisations was best

placed to ensure ‘independence and credibility’. The dominant combination among respondents was

‘unions + industry + associations + environment and consumer NGOs’. The popularity of this particular

combination is associated with a high number of respondents involved with the union. This combination

was closely followed by a variation which included government and research organisations.

How it Should be Done

What do you believe is the most significant factor in designing a successful voluntary Environment Label for the TCF

industries in Australia?

Significant factors listed by respondents included:

• independence, transparency, robust data and international perspective

• credibility and effectiveness

• clear communication and awareness raising

• industry commitment to a real solution

• creating a system that include metrics and guides industry towards true sustainability

• effective, regulated monitoring aimed at achieving continual improvement in industry behaviour

• strong knowledge base and flexible labelling systems

• a life cycle assessment approach

• effective communication of process and scheme

• integrated to address environment, health and safety, product safety and social accountability

• effectiveness or take-up

• collaboration and consultation

• public recognition and understanding.


respondents as part of the survey. While no particular method (e.g. royalties versus annual application fee)

emerged as a clear preference, there was an overt view that the cost of being certified should be kept

minimal and focused on cost-recovery. The importance of government support to ensure independence

and transparency also was considered important by stakeholders.

Business, Consumers & Timing

A new voluntary Environmental Label should be available to

any manufacturer, importer, brand owner or retailer supplying

the Australian market?



Agree 15.3 % 17

Undecided 5.4 % 6

Disagree 5.4 % 6

Strongly disagree 27 % 30


Respondents were divided on the issue of who should be eligible to receive a voluntary Environmental

Label. A total of 32.4 % of respondents either strongly disagreed (27 %) or disagreed that any manufacturer,

importer brand owner or retailer should be eligible. On the other side, 34.2 % of respondents either

strongly agreed or agreed that any new Environmental Label should be available to any manufacturers,

importer brand owner or retailers supplying TCF products to the Australian market. These figures highlight

one of the more contentious issues associated with the scope and eligibility requirements for any new

EQM.

Future Options for a TCF Label in Australia

Which of the three options outlined above is most likely to be

attractive to consumers?


Option 1 36 % 40

Option 2 10.8 % 12

Option 3 9 % 10


Other (please describe) 9 % 10

A large group of respondents (36 %) believed that the expansion of the current ECA label to include

environmental/sustainability accreditation as an optional adjunct to the current labour rights accreditation

for local TCF industries would be most attractive to consumers. This indicates that the ECA program has

relatively strong support among respondents. This may also be explained by the high number of union

respondents with pre-existing knowledge (and involvement) of the ECA program that participated in the

survey. The least popular option among respondents was posed as being new and separate to the ECA.

Which of the three options outlined above is most likely to be

attractive to TCF companies


Option 1 33.3 % 37

Option 2 11.7 % 13

Option 3 9.9 % 11



In terms of desirability among TCF companies, the breakdown was similar to that of consumer

attractiveness. An expanded and/or modular upgrade of the ECA accreditation program was considered to

be the most attractive to companies with 33.3 % of respondents selecting Option 1. A strong fashion

representation with pre-existing ECA knowledge is likely to be significant influencing factor for this

proposition.

Of the three options outlined which has the highest risk of

failure or low-level adoption by TCF companies?


Option 1 16.2 % 18

Option 2 27 % 30

Option 3 14.4 % 16




Appendix E: Global Industry Sustainable Supply Chain Initiatives

The Global Social Compliance Program www.gscpnet.com

WHAT IT DOES: The Global Social Compliance Programme (the GSCP) is a business-driven programme for

the continuous improvement of working and environmental conditions in global supply chains. The GSCP

was created by and for global buying companies wanting to work collaboratively on improving the

sustainability (ethical, social and environmental) of their often-shared supply base. To this end, these

companies are working on harmonising existing efforts to deliver a shared, global and sustainable approach

based on consensus and best existing practice.

GOVERNANCE:

• Task Force

⇒ Composed of Retailer and Brand Manufacturer Companies from all over the world and all

Consumer Goods Markets who nominate one representative to have decision making authority

on the board. The chairman of the Task Force is elected by majority from this group of

representative.

⇒ The Task Force appoints Executive Board Members and are also eligible for appointment to the

Executive Board.

• Executive Board – Responsible for the general management of the GSCP

⇒ Composed of 6-12 members who fairly represent the diversity in role, geography and sectors of

member companies in the task force.

⇒ The Chairman of the executive Board can be appointed from within the board or outside and

chairs the Task Force Meetings.

⇒ All decisions are made by a consensus vote.

• Expert Working Groups – Appointed by the Executive Board

⇒ Composed of 4-12 operational experts drawn from Task Force members who then vote on a

chairperson.

⇒ They are set up to execute a specific task and are disbanded on completion.

• Advisory Board

⇒ Composed of 6-12 members selected for their expertise in issues linked to labour conditions in

the supply chain.


⇒ Drawn from a balanced variety of civil society stakeholders (NGOs, trade unions, Academics

etc).

⇒ Appointed by the Executive Board on recommendation of Task Force, Executive Board and

Advisory Board members

⇒ Membership of the Advisory board does NOT signify endorsement of the programme

• Decision Making:

⇒ Initial recommendations are made based on the decisions of both the Task Force and the

Advisory Board.

⇒ Actions taken on these recommendations and are executed by the Task Force only after a

consensus is reached by all the members of the GSCP governance structure.

The Sustainability Consortium www.sustainabilityconsortium.org

WHAT IT DOES: The Sustainability Consortium is an independent organization of diverse global participants

who work collaboratively to build a scientific foundation that drives innovation to improve consumer

product sustainability through all stages of a product's life cycle.

GOVERNANCE:

• Board of Directors

⇒ Consists of two Co-Directors who represent each of the Academic Institutions that house the

Sustainability Consortium.

⇒ Additionally a new Board of Directors has been appointed that comprises 5 elected

representatives of member organizations.

• Steering Committee

⇒ Consists of representatives of all Tier 13 Industry members, NGOs, Governments and Academic

Partners.

⇒ The Steering Committee includes a Government Task Force, External Relations Committee,

Financial Committee and Developmental Task Force.

• Working Groups and Initiatives

⇒ The permanent Working Groups are split on the basis of industry and additionally sustainability

measurement categories (i.e. Science, IT and assurance).

Se

cre

tari

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Board of Directors Steering

Committee

Working Group and Initiatives 1



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