Extended Producer Responsibility for the marine industry

Over the last four months, we have been working to understand the impacts of changing legislation upon the marine industry. We focused on sails, since it is our area of expertise, but it will affect everything that is a textile and a number of things which can fall into a definition of a textile, even if they don’t necessarily look like a textile (glass and aramid pre-preg systems with a low resin content, for those who work in the composites industry).

This has been the work of Joe, Sam and the University of Nottingham. We’re sharing the executive summary below to give everyone a feel for the scope of the work. If this is an area you want to know more about, drop us a line. The full report will also be available online.

Executive Summary

The textiles industry is considered one of the most polluting industries of the 21st century. In the EU, it is the third largest contributor to environmental degradation, while in the UK it is the fourth. Textiles use 73% of all of the fibres produced globally by 2030, dwarfing other uses. These fibres are produced from bio-based or petrochemical sources, which can then be blended, coated, laminated or fixed into place as part of a composite. The range and chemical complexity of the textiles utilised globally contributes to the environmental impacts of the textiles industry. These impacts are significant, with textiles responsible for approximately 10\% of total global carbon emissions. The industry also contributes to substantial water pollution due to its heavy reliance on synthetic dyes and hazardous chemicals, as well as the production of microplastics during the use and end of life phases of textiles use. However, clothing and linen is not the only use for textiles in the marine industry.

In the marine industry, there is a significant volume of textiles and composites that are used to make sail cloth. These sails then provide motile force or energy for vessels.

Sail cloth is predominantly made of petrochemical-derived polymers such as (poly)ethylene terephthalate (PET or Dacron), and Nylon (polyamide 6). There are also composite and laminated fabrics that can incorporate carbon fibres, aramid fibres, UHMPE (such as Dyneema) fibres, or a combination of all of the above, bound in place by laminated PET or polyester resins. Dacron accounts for the largest sale volume of about 60-80 % of sails sold in a given year, with a smaller volume of Nylon sails (10-22%) and composite sails (5-18%). Between 1600 and 2000 tonnes of sails are produced annually, for a total market value of $400-725 million annually (2-6% CAGR).

The synthetic fibres used in sail cloth production pose an environmental menace especially once they reach their end of life. This is predominantly due to their inability to degrade fully. They fragment into microplastics that leach into the environment leading to significant contamination of natural resources including marine and land ecosystems.

Although some grades of sail cloth can be repurposed into new products such as bags at their end of life, extensive use in one of the harshest environments on the planet ensures that this is not the case for the majority of older sails. Current estimates suggest about 1% of the sails that reach end of life annually are repurposed, predominantly into bags. While recycling technologies are scaling-up, primarily Sustainable Extricko’s recycling technology, these are not available globally. In addition, the responsible management fee to pay for sail recycling is paid by the individual looking to recycling that item, generally the individual least able to afford to pay. As a result, 1600-2000 tonnes of sails are landfilled and/or incinerated annually, with the associated environmental impacts

There are a range of upcoming sustainable textile policies are intended to minimise the environmental impact of the textile industry and incentivise the scale-up the utilisation sustainable textiles. These policies include textiles Extended Producer Responsibility (EPR), Eco-design Requirements for Sustainable Products and the Green Claims Directive. When implemented, the policies will minimise textile landfilling and incineration by prioritising the waste management hierarchy’s prevent, reuse and recycle principles.

This legislation will shift the financial responsibility of managing waste from consumers and municipal authorities to textile producers. The policy defines the producers as companies that avail textile products in the EU/UK market. This would include importers, physical and online distributors, and manufacturers.

The proposed legislation will mandate products labelled as sustainable to be durable, recyclable, incorporate sustainable raw materials such as recycled fibres, and minimise the use of hazardous materials. It will further obligate producers to integrate digital product passports to ensure transparency in product composition, performance and recyclability. Alongside this legislation is intended to empower consumers to make sustainable choices by tackling greenwashing marketing strategies. The policy will require green claims to be supported by scientific reports and recognise the environmental impact of products throughout their life cycle.

Producers will be required to pay eco-modulated waste management fees on placing products on the EU/UK market. They will be further mandated to register with approved Producer Responsibility Organisations (PROs) that will process the eco-fee payments and oversee their overall compliance in their respective countries of operation. The legislation is expected to become law by the close of 2024 and be implemented across EU member states by the end of 2025. The need for legislative harmony with major trading partners means EPR for textiles in the UK is expected in similar timescales.

The sustainable textile policies will apply to all sail cloths, including dacron, nylon, laminated and composite sails. In the marine industry a textile producer will be considered to be a company that avails sail cloths in the EU/UK market. This includes importers, manufacturers, distributors and sail repurposers.

A case study of the French textile EPR implementation was conducted as part of this analysis to establish the impacts of the policies on the UK sail cloth market. It was established that producers would be required to obtain membership with approved Producer Responsibility Organisations (PRO). The PRO will manage the eco-fee payments and oversee overall producer compliance. Producers will be required to declare sails (number and area) upon placing them on the EU/UK market. They will be obligated to make the respective eco-fee payments on the basis of both number and area of sails sold. It is expected that the eco-fee payments will increase the costs of individual sails by €1-100, depending upon sail size and how challenging that sail will be to reuse or recycle at end of life.

These fees will then be utilised by the PRO to develop and provide end of life solutions for these sails, which are appropriate for individuals across the industry. This may be through funding research into recycling, supporting sorting and scale-up activities or targeting the development of more durable textile production.

The legal requirement for one or more Producer Responsibly Organisations across the UK and EU has therefore led to the clear need for a maritime industry specific organisation. This organisation will ensure that the unique challenges of the maritime industry are addressed, while delivering recycling which is free at the point of access for sails. This opportunity is one which must be taken by the maritime industry globally, to reduce the environmental impact and decarbonise, for the future of people and planet.

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