Make the Label Count is an international coalition of organisations representing a wide range of natural fibre producers and environmental groups, but we all have one thing in common. We are all working to ensure that sustainability claims for textiles in the EU are fair and credible.



We are pleased to see that the Commission has listened to stakeholder concerns around the limitations of the Product Environmental Footprint (PEF) methodology, especially for the apparel and footwear product category. The Commission acknowledges that PEF omits the consideration of crucial impacts, such as microplastic release. We believe that the impact of plastic waste generation and the circularity of materials should also be considered as they are all driving forces behind the fashion industry’s huge environmental damage.

The proposal must be strengthened to ensure that any future identification of a single harmonised framework, either in the Directive or delegated acts, is only included if it delivers EU consumers meaningful information on the sustainability of their purchasing choices. A single framework would prevent companies from cherry-picking the label or scheme most favourable to their marketing objectives, and help to fight greenwashing, and promote consumers’ responsible behaviours in the long run. Therefore, we support the Commission’s commitment to improve the PEF methodology. However, the PEF should be considered in the context of the Directive only if it is amended to include the above-mentioned impacts of microplastic, plastic waste and circularity.

Read our white paper here to learn more.


Watch now and hear from coalition members in this short film:


The EU is shifting to a climate-neutral and circular economy, which means products need to be more energy efficient, durable, reusable, repairable, and recyclable. Because the fashion and textile industry has such a big environmental footprint, the European Commission is reviewing sustainability claims on apparel and footwear, as well as ecodesign requirements. The Commission is exploring using the Product Environmental Footprint (PEF) methodology to substantiate green claims and inform ecodesign requirements.

Make the Label Count wants to ensure textiles sustainability claims in the EU are transparent, accurate and complete, allowing producers and consumers to make informed choices about the clothing they make and buy.

MAKE THE LABEL COUNT. Do clothes contribute to the microplastics problem?


Having a standard methodology to measure sustainability can help make fashion and textiles greener. The EU is likely to set a global standard and could deliver positive outcomes, but only if the proposed methodology behind it is amended. We must act now and get it right to ensure that textiles sustainability is measured with credibility to provide a sound basis for fully transparent consumer information and to help the industry make the green transition the EU wants to see.


Following thorough research from independent LCA experts, we’re recommending the European Commission adopt three easily implementable improvements to the PEF methodology:

PEF inclusions pie chart graphic PEF inclusions pie chart graphic

Include an indicator for microplastic emissions. This will make the PEF consistent with the EU’s other policies and follow the precautionary principle. Failing to include an indicator for microplastics effectively assigns zero impacts to this emission in the PEF system. This risks unintentionally encouraging more production and consumption of plastic products and fibres, further increasing microplastic pollution. Microplastics can be added as an inventory level indicator, ahead of complete integration into the PEF system.

Include an indicator for plastic waste. The EU is focused on reducing plastic waste, however the PEF currently does not share this priority. There is a need to reduce the demand for this material, and/or divert plastic products away from landfill to be recycled instead. At present, the recycling of synthetic fibres is negligible. Plastic clothing is also incinerated at the end of life, and while energy can be recovered from this process, the incineration of plastic waste also releases fossil CO2, contributing to global warming. Including a plastic waste indicator will enable the PEF to reflect the EU’s environmental priorities.

Include an indicator for circularity. Despite the EU’s progressive Circular Economy Action Plan (CEAP), the PEF currently places little emphasis on circularity. Fossil materials are not renewable or circular, and currently none of the 16 PEF indicators directly measure circularity. Including circularity as a stand-alone indicator in PEF is the best means of assessing the sustainability of raw materials originating from renewable and non-renewable sources.



MTLC responds to Substantiating Green Claims delay

The European Commission has delayed its proposal on Substantiating Green Claims. The proposal is intended to ensure a unified approach to measuring and communicating meaningful information about the environmental impact of textiles and clothing, which is urgently needed to combat the rise of fast fashion.

Our coalition appreciates the complexity involved in this proposal and we are eager to help the Commission to ensure that sustainability claims for textiles in the EU are fair and credible, yet the proposed Product Environmental Footprint methodology is currently incomplete.

Read our recent white paper to learn about improving Product Environmental Footprint methodology here.

MAKE THE LABEL COUNT. Do clothes contribute to the microplastics problem?

Open Letter to the European Commission

The coalition has delivered a letter to the President and Members of the European Commission urging them to ensure that the PEF, or any alternative tool used to regulate ecodesign requirements and the substantiation of green claims, includes the necessary indicators to address the most critical environmental impacts of the fashion industry, and successfully deliver the EU’s circular economy strategies. To make the PEF fit for purpose and ensure it helps deliver the EU’s sustainability and circularity ambitions, three key indicators must be included: microplastic release, plastic waste, and circularity. Targeted strategies exist for each, yet targeted indicators to measure and report progress for textiles are lacking. In other words, the EU cannot manage what it does not measure.

Read the letter

MAKE THE LABEL COUNT. Do clothes contribute to the microplastics problem?

White Paper details current problems with PEF

The PEF system is designed to facilitate like-with-like comparisons, but assessments of textiles made from natural and synthetic fibres are not yet comparable. Current PEF limitations present a significant challenge to the delivery of both EU strategy and the PEF goal of providing fair comparisons of products based on their environmental credentials. This white paper addresses the concerns with the current PEF methodology, identifies the main challenges posed and provides recommendations to not only offer more meaningful guidance to the EU consumer but also assist in delivering the EU’s environmental policy and sustainability objectives.

Download Now

Response to joint  
‍guidance from
‍consumer authorities
‍in the Netherlands and Norway

We welcome the joint guidance from consumer authorities in the Netherlands and Norway stating that environmental claims based on the Higg Material Sustainability Index (MSI) tool need to be revised to mitigate the risk of misleading consumers.

These guidelines are based on the interpretation of current EU consumer law and confirm the shortcomings of current life cycle assessment-based methods used to quantify the environmental impacts of textile products. The two authorities send a timely and important message to fashion retailers and governments - environmental claims need to be accurate if they are to empower consumers to make well-informed and truly impactful purchasing decisions.

‍Read our recent white paper to learn about improving methodologies, here.

MAKE THE LABEL COUNT. Do clothes contribute to the microplastics problem?

Joint MEP letter distributed to European Parliament

MEP Carlo Calenda and 29 colleagues delivered a letter to the EU executive, asking them to carefully consider the upcoming textile legislation. The letter draws their attention to the PEF process, which could result in supporting a greenwashing scenario in the fashion and textile sector. If the PEF methodology is not adjusted to include renewability, biodegradability and microplastic pollution, the 30 signatories believe it would “fundamentally undermine the credibility of any EU action and the ability of consumers to act responsibly”.

Read the full letter.

MAKE THE LABEL COUNT. Do clothes contribute to the microplastics problem?

The Great Greenwashing Machine

A series of white papers, published by Veronica Bates-Kassatly and Dorothee Baumann-Pauly with the Geneva Center for Business and Human Rights (GCBHR), attempts to expose fast fashion’s false sustainability promises. The first highlights a flawed definition of sustainability in fashion and how unscientific methods and selective implementation hinder meaningful change. The second white paper demonstrates that even the environmental impact of fashion is not being correctly assessed, neither broadly, nor narrowly.

Read Part 1 here and Part 2 here.


Watch the recording of the Make the Label Count launch event with EU policymakers, academics and industry representatives.

Make the Label Count. What if a label could tell me which top is designed for longevity?

WATCH: PEF explained

This short animation explores what the new EU policies could mean and why PEF should not be used in its current form. Watch the video now.


About PEFCR public consultation & natural fibres


Guide on how to submit a PEFCR response


Response template to the public consultation on PEFCR for Apparel & Footwear


Delivering EU environmental policy through fair comparisons of natural and synthetic fibre textiles in PEF – Executive Summary (ENG)


Delivering EU environmental policy through fair comparisons of natural and synthetic fibre textiles in PEF - White Paper (ENG)


Make the Label Count - Briefing Document (ENG)


Make the Label Count - Briefing Dokument (DE)


Make the Label Count - Document d’information (FR)


Make the Label Count - Documento informativo (IT)


Make the Label Count - Documento Informativo (ES)


Make the Label Count - Documento Informativo (PT)

“We’ve had major advancements in research and knowledge around the environmental impacts of the textile industry, but these aren’t yet included in the current PEF methodology. If the Commission proceeds to use the PEF without updating it, the fashion and textile industry won’t make the green transition we all want to see.””
Dalena White
Make the Label Count spokesperson and
Secretary General of the International Wool Textile Organisation
“Credible claims in the fashion industry is a fundamental step towards ensuring consumers make informed choices when buying garments. The fact that this is now being implemented at EU level is wonderful. But it is fundamental for claims on labelling to be accurate and comprehensive, so it does not misrepresent or unfairly favour certain fibre groups. This is why I am proud to be working on the Make the Label Count campaign, calling for a level playing field for sustainability claims and in doing so, drive the change we so urgently need.”
Livia Firth
Creative Director of Eco-Age
“Life Cycle Assessments can only be compared if they follow exactly the same methodology and boundaries. Such a suite of generic LCAs for textile fibres does not exist. The EU cannot create non-fiscal barriers to trade that will negatively impact some of the poorest on the planet, without first commissioning the studies required.”
Veronica Bates Kassatly
Independent Analyst


Join us in advocating for improvements to PEF for substantiating textiles sustainability claims and inform ecodesign requirements in the EU. Together we can make the label count!

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Contact Make the Label Count

Have a question or want to be a part of the Make the Label Count? Contact us here.


American Wool
Australian Wool Innovation
The Campaign for Wool
Cashmere and Camel Hair Manufacturers Institute
Cashmere and Camel Hair Manufacturers Institute
Changing Markets Foundation
Cotton Australia
Cotton USA
Discover Natural Fibers Initiative
Cotton Egypt Association
European Industrial Hemp Association
European Institute of Innovation for Sustainability
G. Modiano
IndiDye Natural Color Co.,Ltd
International Alpaca Association
International Sericultural Commission
International Silk Union
International Wool Textile Organisation
John Smedley
Mohair RSA
Peru Alpaca Yarn & Textile
Plastic Soup
Sachsen-Leinen e.V.
Sustainable Fibre Alliance
The Schneider Group
US Cotton Trust Protocol
Zegna Baruffa Lane Borgosesia