Proposal title

New Technical Specification for textile composting

Your name

Stephanie Devine and Blake Lindley

Email address

stephanie@theverygoodbra.com and blake@cirqsolutions.com

Name of employer

The Very Good Bra and Cirq Solutions

Web address

www.theverygoodbra.com and www.cirqsolutions.com

1A: Provide details of the proposed documents

#

 Title

(e.g. Masonry cement)

Project type

(e.g. revision, amendment¹ or new²)

Designation

(e.g. AS 1316:2003)³

Product type

(e.g. AS, AS Int, SA TS, etc...) ⁴

1

Compostable textile products

New

TBC

Technical Specification

1B: Write a clear and concise statement of the nature of the issue to be addressed by your proposal.  Describe who is affected e.g. businesses, community organisations or individuals affected by the problem. What are the consequences of no action?

The nature of the textile waste issue:

Globally, it has been estimated that the textiles industry (across production, manufacture, use and disposal) generates around 1.2 billion tonnes of CO2e emissions every year – or 6-8% of the global total. Natural fibre textiles generate methane, a potent greenhouse gas when disposed of too landfill – which is unfortunately the only available end-of-life scenario for textiles in Australia.

The federal Environment Minister, Susan Ley has nominated Textiles as a priority for the government, stating ‘we want to keep clothing out of landfill, where it can take hundreds of years to break down, releasing harmful carbon emissions along the way’. Creating new recovery pathways for natural fibre textiles and avoiding landfill is critical to the low carbon future now committed to a host of future minded organsiations along with every state government of Australia (who have now committed to net-zero targets by 2030).

However, there is a current blockage. Clothing and textiles are commonly sewn with non-natural thread, fabrics can be blended with synthetic fibres, some make use of chemicals of concern (inc. PDBE’s and flame retardants), and can contain non-natural dyes.  All of which currently conspire to make composting unviable – organics recovery facilities do not know what they are getting and accepting this material without burdensome prior testing risks their output product being certified to AS4454.

Needless, in controlled industry run trials suitable clothing has shown positive results, increasing the nitrogen/carbon ration in composting processes and providing beneficial structure in vermiculture. But, until a AS standard is in place for brands and textile manufactures to adhere to, those operating organics recovery facilities cannot confidently accept textile material or products.

Wide ranging impacts:

Broadly, all people, organisations and governments can benefit from this work as through its contribution to net-zero emissions by 2030.  At this strategic level, composting textiles has a range of other benefits:

1.     Organics recovery facilities are an existing and installed technology (no technological barrier) avoiding the need for expensive textile recycling plant and equipment

2.     Due to state government food recovery mandates this infrastructure is expanding rapidly across the country (providing high accessibility beyond any future specialist textile recycling plant)

3.     Complimentary benefits in plants when processing high volumes of (wet) food waste balancing the nitrogen:carbon mix

Manufacturing products to an AS will allow brands to transition entire product lines to entirely ecologically renewable natural fibre textile, offer their customers take-back programs and reduce the use of synthetic (plastic) non-renewable alternatives. This is a stepping stone on the journey to a regenerative and circular economy.

By virtue of its emissions intensity, businesses and the public across Australia is affected by current wasteful handling of textiles (the continued consequence of no action).

The consequences of inaction are clear…

Natural fibres (cotton, wool, hemp etc.) as organic cellulosic materials, emit CO2 and methane in the anaerobic conditions found when disposed to landfill – addressing these materials is the focus of the proposed standard. Natural fibre textiles comprise around 300,000-400,000t of textiles imported to Australia annually (or 30-40% of all textiles) – and business as usual is no longer an option.  

Natural fibre textiles (the focus on this project) are a major component of two major textile product streams; clothing and linens. These occur in both household waste as shown below, and also directly from business especially accommodation (linens and towels), uniforms and in clothing take-back programs.

*Kerbside textiles waste audit , Hunters Hill Council, 2022

With no existing recovery pathway for end-of-life natural fibre textiles, this project when fully realised could provide both a cost effective (no additional infrastructure required) and emission reducing solution for natural fibre textiles.

The industry-led creation of an Australian Standard for natural fibre compostability/degradability will contribute to the nation’s net-zero ambitions, state waste handling infrastructure planning, and most importantly allow consumers to exercise their preferences for sustainable products.

The aim of this work is…

·       To establish a Technical Specification that prescribes the test processes to confirm that a suitrably designed garment will fully and safely decompose in composting processes.

·       To allow stewardship programs, business and textile collection services to have eligible textiles processed by organics recovery facilities at end of life.

·       Develop a Technical Specification, pre-empting an Australian Standard.

A consistent and certifiable standard is required for broader adoption and integration to organics recycling, and would support the following outcomes:

• Manufacturers and importers can correctly label products eligible for recovery by these means
• Consumers can exercise purchasing preferences and dispose of end-of-life materials appropriately
• Provide a cost effective and viable outlet for brand led take-back programs
• The organics recovery industry can confidently process natural fibre products directed to them without the risk of contamination
• Emissions reductions, and an ecologically circular route for material recovery.

The project team does not consider textile collection in household Food Organics services viable at this stage, and in no way encourages or promotes this. Substantial consumer education, labelling authority are just the initial barriers to overcome to do so.

1C: Write a clear and concise proposed scope that will outline how to address the identified issue(s).

Unless this is a proposal for a new document, this should not be a scope of the document, but a scope of the work which you propose to undertake.

Include what is going to be changed from the status quo and summarise the specific intent of the change.

If you wish to include proposed revisions as tracked changes in the Standard, or an outline of a new Standard, please summarise the scope and note the attachment here, and include the document as an appendix to this form.

For composted products to be ‘eligible’ for reapplication to land, they must meet the requirements of:

·       AS4454 – Soils composts and mulches 

·       State regulations (i.e. The NSW Compost Order 2016), which in some instances are stricter than the AS. 

State Compost Orders and AS4454 set out the allowable amounts of common contaminants that are tolerable in compost products to maintain the health of our natural soil systems, and avoid bioaccumulation over time. The scope of this work is reverse engineered from these established and immovable requirements in order to define a ‘compostable’ textile or product.  We have certainty from these documents on what must be tested for, and what the requirements of what a fully composted textile must become. 

Project scope:

The technical specification will be applicable to any textile product (be it clothing, bedding or otherwise) or fabric and is intended to be applied to finished products inclusive of stitching and other components.  It is possible that fabric manufacturers may also elect to certify ranges of ‘compostable’ fabrics, in this case, finished textile products will still require testing to achieve compostable certification.  

Simply, the project scope is given in the following 4 steps. 

These are outlined under the headings below.

1. Establish definitions and taxonomy 

Develop a suite of relevant project definitions and FAQ to ensure accurate and precise definitions so potential users, regulators and composting facilities can understand the proposed standard, and discuss it productively.  

This should include, but not be limited to:

• ‘Textile’ 
• ‘Fabric’
• ‘Stitching’
• 'Biodegradable’
• ‘Compostable’
• ‘Man-made cellulosic fibres (MMCF)’ 
• ‘Regenerated fibres’
• ‘Natural fibres’
• ‘Synthetic fibres’ 
• ‘Blended fibres’
• ‘Contamination’ (in the context of textiles)

2.     Systemise existing standards and state guidance to develop minimum guidance on compost

Review AS4454 and all state requirements (e.g. NSW Compost Order 2016) to establish a minimum standard for national acceptability and re-application of compost to land. These criteria are set out in the following documents (others may be added if identified): 

• AS4454 - Composts soils and mulches - specifically the physical and chemical requirements for composts soils and mulches outlined in:
• Table 3.1A 
• Table 3.1B 
• Table 3.1C
• NSW Compost Order 2016
• Section 5 - Processor Requirements 
• VIC EPA 1588.1 - Designing, constructing and operating compost facilities 
• Section 8.1 - Product Requirements (Table 9)
• Section 8.2 - A Product - not a waste

Identify any additional textile specific treatments or substances of concern (given that that current standards for compost relate to food waste), which is unlikely to include any of the following: 

A.              Presence of formaldehyde (anti-wrinkle and flame-retardant coatings)

B.              Presence of poly fluorinated compounds (water repellent coatings)

C.              Presence of boron and phosphorus (flame retardant coatings)

D.             Presence of biological active agents

E.              Presence of heavy metals

F.              Presence of toxic colourants (including carcinogenic arylamines and cleavable aniline

Building from AS4454 Section D6 (which outlines the requirements for all sample test reports), updated requirements for testing should be established in the standard including common treatments used in textiles. Facilities processing textiles would be required to expand existing testing regimes to include these. 

A review and alignment to OKEO-TEX requirements and assessment criteria will be conducted to ensure that all required tests and relevant substances are identified in the creation of the technical specification.  This will also assist in the technical specification integration to existing certification once published. 

By providing a clear set of criteria for compost outputs, garments may be tested in simulated decomposition environments to ensure that once decomposed they do not reach these threshold values, and thus achieve certification as a ’compostable’ textile product. 

3.     Establish typical ‘compost’ conditions for lab testing

As testing to meet the compostable standard will be lab based, industry engagement (and internal engagement with those involved in establishing AS4454) will be required to put parameters on the conditions typically found within commercial composting facilities (across various technologies). 

At a minimum this should cover: 

A.              temperature, 

B.              aeration, 

C.              microbial activity,

D.             duration of decomposition 

These test conditions need to be defined in order for lab testing of textile compostability to be accurate.

4.     Refine to Technical Specification

The final technical specification should outline key substances and threshold values of textile decomposition - from scope item (2) that must be tested for in order to achieve compliance.

It should also provide a clear guide to certification bodies/labs on the conditions and duration of composting processes. 

NOT INCLUDED in project scope:

·       Integration of Home Composting to the initial technical specification:  whilst this remains a logical evolution and even an end-goal for this program, it is conservative initially to work within the constraints of industrial composting as this predetermines clothing (re)collection and accurate sortation. Allowing home compositing opens the door to misuse of labelling and also mis-education of consumers and increases the likelihood of unintended outcomes and/or regulatory scrutiny.  Further, processing at a composting facility means that physical screening of contaminants is also assured, meaning zippers, buttons which may not be compostable will be safely extracted after composting (this is not possible in the home composting scenario) meaning the technical specification will be able to be much more widely applied. 

·       Design guidelines: creating design and manufacturing guidelines are not a part of project scope. The Technical Specification will set out a series of tests that MUST BE PASSED in order to certify an item compostable, these will be based around lab scale simulation of decomposition. The publication of a ‘how-to’ design compostable garments may developed subsequently by suitably qualified organisations.

·       Alignment to OKEO-TEX and other certifications - a technical standard must be developed to test against, before it can be integrated to existing certification programs. Whilst these programs will be understood to identify areas of alignment, the technical standards will necessarily be a standalone document. 

·       Licencing and acceptance of textiles in composting facilities - there are licencing restrictions that currently do not allow textile products to be processed at commercial composting facilities. Addressing facility licensing (to allow the intake of suitably certified textiles) is beyond the scope of this project, but remains a concurrent conversation with state regulators held separately to the development of this standard.

1D: Are you proposing an adoption of an International Standard (i.e. ISO or IEC)?   

If so answer the following:⁵

Is it a Modified or Identical Adoption?

Note: if Identical please use the Proposal Form – Identical Adoption

What is the designation?

e.g. ISO 10303.212-2004

Reasons for non-identical adoption?

Why can’t the current international standard be adopted identically?

1E: Is the existing document referenced in Australian State, Territory or Commonwealth legislation or regulatory framework?

For joint documents, also consider New Zealand legislation.⁶

Yes (List all legislation or regulation that refer to the existing document.⁷)

Note: For National Construction Code (NCC) and WaterMark proposals, the Australian Building Codes Board (ABCB) needs to be consulted prior to submission.

No (Go to 1F)

No

1F: Is there an ISO/IEC document that also covers the issues in question?

Yes (Go to 1G)

No (Go to 1H)

No

1G: If there is an existing International Standard that covers the scope of this proposal, is it being adopted?

Yes (Go to 1H)

No (Please clarify this position explaining why the existing International Standard is not being adopted)

1H: Will the proposed document include any conformity assessment requirements?⁸

Yes

No

2A: What will be the impact of the proposed project in the below categories? Explain this in terms of a positive or negative impact on the following “Net Benefit” criteria.⁹

Public health and safety (max 200 words)

The occurrence of Polybrominated Diphenyl Ethers (PDBE’s) in textile products (used to promote fire resistance and water proofing in household products and outerwear garments particularly) is now a monitored chemical of concern nationally. These compounds are bioaccumulative and persistent in the environment and known to cause serious health effects in humans. Textiles and textile containing products (mainly furnishings and insulation) are a known contributor of this substance to landfills and other waste treatments. 

This technical specification would provide the starting point for a certifiable standard for industry to conform with emerging national guidance on the use of these compounds in textile production and a clear public health and safety benefit. 

The integration of supply chain compliance to an Australian standard for natural textiles would address the use of national chemicals of concern entering our household products and benefit public health.

Based on comparable industry standards, the costs of testing to meet the standard are expected to be in an affordable range for manufacturers i.e. $40-$80 per test delivering a clear public benefit.

Social and community impact (max 200 words)

The technical specification will deliver a range of direct and indirect benefits. These include:

·        Decrease in landfill burden and its related costs and negative impact on the community

·        Increased awareness of the natural products which might filter into all areas of consumption and potentially influence more sustainable behaviours more broadly

·        The benefit of communities feeling they are able to positively impact the environment and working together to do so

·        Decreased burden on charity stores currently having to pay to dispose of abandoned textiles that are unsuitable for re-sale

Environmental impact (max 200 words)

In Australia we send 85% of textile waste – 600,000 tons a year, to landfill.  In total textile consumption, use and disposal accounts for 16,608,028t CO2e, or 0.698t CO₂e per person per year. This technical specification has two important impacts:

1. It opens avenues for importers or manufacturers of textiles to support and be certified as supporting low carbon production systems for textiles
2. Provides the authoritative basis for labelling to inform consumer awareness campaigns, and confidently integrate compostable products into the existing suite of organics recovery infrastructure in a tested and predictable way. Without such labelling and testing in place, the risk of contaminating end products (i.e. compost) is generally too high for current operators to accept new materials

Further, this technical specification will assist in ensuring we have a better understanding of the chemicals currently being imported into Australia through textiles an area of federal interest.

The proposed technical specification would address each of these areas to create a net positive environmental benefit.

Competition (max 200 words)

The proposed standard is not anti-competitive in nature.

Whilst textile composting is subject to differences in climate globally, there is the potential for this technical specification to be the basis of local standards and potentially an ISO standard for commercial composting in more controlled conditions.

Economic impact (max 200 words)

Currently there is no objective or widely recognised standard for compostability of textiles in Australia. Regardless, many brands are seeking to test and verify their own claims individually leading to replication and difficult comparability in industry. 

Economies of scale by shifting the burden of testing will reduce the economic burden of compliance and consumer costs in the long-run and is a net-benefit. 

Research by the federal government has shown that where landfilling actives provides 2.8 jobs / 10,000t of waste, recycling activities provide 9.2 jobs / 10,000t. By resolving the barriers to natural fibre textile recovery, composting fibres will create additional jobs across Australia.

3A: Describe the process taken to gain stakeholder support for your proposal (max 100 words)

3B: Identify the Australian stakeholder organisations that you have consulted with.
Evidence of stakeholder support MUST be provided in a letter (on company letterhead) or email (company email only).

At least two New Zealand-based stakeholders must be included for projects relating to joint AS/NZS Standards. Include those that do, and those that do not, support the proposal.

Key stakeholder groups

Organisation Name

Contact name

Position

Letter or email evidence is attached: Y/N

Interested in membership of standards committee: Y/N

Research and academic organisations

Manufacturer associations

Testing bodies

Certification and auditing bodies

Supplier associations

User and purchaser associations

Employer and industry associations

Professional and technical bodies

Unions and employee associations

Consumer and community groups

Government and regulatory agencies

Independent experts

New Zealand stakeholders

Other

I consent to Standards Australia making information relating to Standards development projects public, including information contained within a proposal form I have submitted in part or in full. In the event that Standards Australia publishes proposals on its website, proponent details at page 1 and stakeholder contact details provided at Section 3 will not be included.  However, with prior agreement, my contact details may be provided to interested parties wishing to contribute or comment on the proposal or the proposed project.

The information provided in this application is complete, true and accurate to the best of my knowledge. I believe the proposed document will result in Net Benefit¹⁰ to Australia.  I have consulted with, and have the support of, national organisations with a relevant interest in this project.

Name of proponent

Date of declaration

The Technical Specification/AS needs to focus on ensuring the integrity of the output (AS4544 for mulch and compost) by the design of tests which enable all textile products to pass or fail

1) Testing and certification of products for compostability is 100% voluntary

2) The Technical Specification/AS for textile composting will be the last resort for when products made from 100% natural fibres, including Man Made Cellulosic Fibres (MMCF), have maybe passed through multiple hands and are no longer suitable for resale or recycling, to divert them from landfill

3) Valuable nutrients can be recaptured through composting that will be lost in landfill

4) At this stage we propose the Technical Specification/AS applies to finished products as well as any raw materials (off-cuts for example) that can’t be used or recycled. We do not propose to test individual materials prior to manufacture of an end-product

5) The aim of testing and certification is to enable existing waste infrastructure facilities (FOGO) to confidently take in certified textile products without risking the integrity of their output product, which will still meet AS 4544 for Mulch and Composts

6) The Technical Specification/AS would ONLY be a brand take-back scheme and not to FOGO bin, to ensure the highest likelihood of maintaining integrity of mulch output. This way if a consumer adapts a product through printing/dying/embellishing, that product can be removed by the brand prior to going to a waste facility

7) The best solution for textiles is to design and prepare them (shredding) in such a way that they can fit within the FOGO lifecycle of 7-21 days. Some slower products like wool or bamboo may need to be shredded finer. This will all be developed by the expert panel assembled by SA when the proposal is accepted and goes into development.

8) It seems right that the cost of testing should therefore be borne by the brand, which is then also responsible for ensuring that the materials used at the front end (including processing) are likely to pass the tests, based on advice given in the Technical Specification/AS

9) The cost at this stage is unknown but there is a cost to all certification that brands have to bear ie BCorps, Cradle to Cradle, Oeko-tex etc

10) It appears to become too complex to specify all materials and chemicals up front, new ones will appear all the time. Whilst up-front guidance can be developed on materials likely to pass or fail, as well as clear definitions, all we can successfully and consistently measure/test for is fitness to enter existing FOGO systems, allowing their output to meet  AS4544

11) Using pre-certified OEKO-TEX or GOTS materials will likely help products pass the test. This is the same for raw material offcuts. It would make sense for brands to use more of these materials

12) Over time educational tools can be developed which include definitions of materials most likely to comply to guide supply chains on likely compliance, but it is ultimately the brand’s responsibility to pass the test if it wishes to voluntarily submit an item for certification against the Technical Specification/AS

13) The Technical Specification/AS is for 100% natural textile products/materials, including cotton and wool as well as MMCF including rayon and Tencel, but as in 2) and 3) above, brands sourcing strategies should ensure materials purchased are likely to meet the testing standard in terms of chemicals used in processing and dying. These products should include NO plastics ie spandex/lycra, polyester (labels and threads), nylon, plastic buttons or zips so these need to be designed out at the design stage, or designed for disassembly (by the brand) in the case where buttons, tapes or zips need to be removed

14) In the end, we won’t know the answer on which chemicals go through for sure until testing takes place, but we can design for that by using ‘cleaner’ products and as brands, only trying to certify those products which are likely to pass the tests – essentially it's a PASS or FAIL system and brands don’t have to try and certify everything for each season. This is a start on a long process for everyone of designing waste out upfront. It may just be one item in one collection, but it's a start.

15) Neither the proposers of the Technical Specification/AS nor Standards Australia (SA) is responsible for designing and executing testing, rather, once the scope and proposal are finalised, SA assembles a panel of experts via accredited industry bodies to design repeatable testing standards to be used by anyone nationally to attain Technical Specification/AS certification.

16) Labelling for life – we don’t yet have the answer on this but as was raised, the EU digital product passport is coming 24-27 and this may guide us

17) Regarding accidental contaminants and factory substitutions, an idea is to test pre-production and shipping samples. We can never be 100% sure but this is potentially the closest we can get

18) Given Australia produces 7m tonnes of food waste pa, and 600,000 tonnes of textile waste, of which conservatively only 40% is ‘natural’ and has a long way to go before being ‘100% natural’, small amounts of breakthrough contamination should not spoil AS4544 output

19) We understand it’s a lot of work for potentially little outcome right now, but even if one brand produces one T shirt or towel that can be Technical Specification/AS certified, we’ve created a pathway for natural textile waste which will grow over time.

20) A Technical Specification can be developed and in use within 6-12 months whereas an AS can take up to 2 years, so that aim is to start with the Technical Specification and once that is in use, continue to an AS which in turn could become an ISO.