Apparel & Footwear Ecology Question 4

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Does the brand (company) have an environmental policy related to the ‘wet processes’ within the production cycle, like bleaching and dying of fabrics?

  • Dutch version: Heeft het merk (bedrijf) haar milieubeleid gepubliceerd dat betrekking heeft op de 'natte processen' in de productieketen, zoals het bleken en verven van stoffen?
  • German version: Setzt der Markenhersteller Maßnahmen um, um alle umwelt- und gesundheitsschädlichen Chemikalien aus dem kompletten Produktlebenszyklus und Produktionsprozess für Kleidung und Schuhe zu eliminieren?


This question relates to the production stages for aspect EN21 in the Reporting Guidelines & Apparel and Footwear Sector Supplement of the Global Reporting Initiative.

Using raw materials for the production of apparel and footwear products involves many chemical processes, especially bleaching, dying and finishing. In many ‘high risk’ production countries, the use of harmful chemicals and poor water effluent treatments is devastating to nature, groundwater, rivers and the people that depend on these resources, read e.g. [1] and [2]. In 'low risk' countries (such as the EU) legislation often takes these processes into account.

There are various certification schemes that guarantee a certain level of responsible chemical and water use during production. Examples of environmental certification schemes are the EU Ecolabel (the flower),GOTS (Global Organic Textile Standard), Oeko-Tex 100 Plus, Oeko-Tex 1000, Nordic Ecolabel, bluesign, Soil Association Organic, IVN (International Association of Nature Textile Industry).

For global clothing companies, Greenpeace drafted a Zero-Discharge Commitment. Companies that signed this document promise to 'eliminate all hazardous chemicals from the whole lifecycle and all production procedures that are associated with the making and using of company's products by 2020'. A group of companies (Adidas Group, C&A, H&M, Li Ning, Nike and Puma) drafted their own version of a zero discharge roadmap. The draft version was critized by Greenpeace. A useful resource to get a better picture which brand has signed the Zero-Discharge Commitment, plus is considered as either a "Leader", "Greenwasher" or "Laggard" according to Greenpeace can be found here: The Detox Catwalk. In case you find other resources please contact our verifier.

Please note that abiding the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) standards is not sufficient enough for this question.

Ranking guidelines

A ‘Yes’ is applicable when:

  • The company mentions that they use one of the approved certification schemes mentioned on this page, such as:
    • EU Ecolabel, GOTS, Oeko-Tex 100 Plus, Oeko-Tex 1000, Soil Association Organic, bluesign, Nordic Ecolabel, IVN.
    • Note: brands should be specific when referencing the approved certification schemes (eg if the certification only applies to a specific collection or line, or brand, etc. that should be stated).
  • When the company has signed the Zero Discharge Commitment drafted by Greenpeace and is not categorized as a "Greenwasher" by Greenpeace.
  • You can also give a ‘Yes’ to companies that: have rules for wastewater treatment* in the production processes of all their products, PLUS one of the following:
    • A publicly available restricted substance list that meets or goes beyond local legislation and that is regularly updated;
    • Measures to increase water use efficiency;
    • Monitoring of the quality of (treated) outgoing wastewater;
    • A full record of chemical use and wastewater for inspection.

'*Note that the wastewater treatment could either be a simple biological treatment system for when only natural dyes and auxiliaries are used, or a 2-stage treatment plant for when chemical dyes and auxiliaries are used.

A ‘No’ is applicable when:

  • A brand uses Oeko-Tex 100 which does not throughly meet our criteria since it doesn't (for example) cover the water effluent issues for the production stages.

A ‘?’ is applicable when:

  • A brand uses Made in Green. This certification process SOMETIMES makes use of the Oeko-Tex 1000 standard, but also has the option for less stringent standards as alternatives.
  • A brand uses Business for Social Responsibility BSR which is also on hold until we have found an expert opinion from a leading environmental NGO (the request is vacant).
  • A brand does not provide enough information to determine whether or not it meets our criteria.

Answering guidelines


  • [Brand]'s clothing is [EU Ecolabel / GOTS / Oeko-Tex 100 Plus / Oeko-Tex 1000 / Soil Association Organic / Nordic Ecolabel / bluesign*] certified, which means that high standards are maintained for suitable chemical use and water policies during production. This certification is applicable to [some / most / all*] of the [childrens / entire / ___] collection.
  • [Brand] has signed the <name version> Zero-Discharge Commitment. Companies that signed this document promise to 'eliminate all hazardous chemicals from the whole lifecycle and all production procedures that are associated with the making and using of company's products, by 2020'. In this matter, according to Greenpeace, [Brand] is categorized as a "Leader".
  • [Brand] has rules for wastewater treatment in the production of all their products, as well as [*insert practice(s)*].
  • All products are made in [...], which [is a low risk country / are low risk countries] as defined by MADE-BY.


  • [Brand] only mentions the Oeko-tex standard 100 for textiles. This standard is not acknowledged since it does not have strict criteria water effluent issues in the production stages.


  • [Brand] refers to the Made in Green standard for textiles, which does not thoroughly meet our criteria.
  • [Brand] refers to the BSR standard for textiles, but BSR is not yet acknowledged since there is no independent review of the BSR criteria.
  • [Brand] does not communicate any information on an environmental policy related to the ‘wet processes’ within the production cycle on its website.

- * You can pick the topic that applies to 'your' brand.


  • You can find the above certification schemes by searching for their names using keywords and/or looking for their logos.
  • Substitution is a core action to reduce the risks hazardous chemicals pose to the environment and public health. However finding a safer substitute can be a challenging task – the SUBSPORT web portal is a very practical resource to facilitate this work.
  • The Institute of Public and Environmental Affairs (IPE) - a registered non-profit organization based in Beijing - provides an existing, well-known, publicly accessible and independent online database where a company’s suppliers can disclose chemical discharge data.