Sustainable Action Leadership

Are You Being Bamboozled? A Guide on How to Avoid Mislabeling

This Brochure is a Collaboration of:

Dr. Gwendolyn Hustvedt, Texas State University‐San Marcos
and
Coral Rose, Eco‐Innovations Sustainable Textile Services

Download Brochure Here

You Can Have Your Bamboo and Eat it Too--"Rayon Made From Organic Bamboo"

by Coral Rose

The FTC recently charged four textile companies with making false unsubstantiated “green” claims. According to the FTC these companies were deceptively labeling and advertising textile related items as made of ‘bamboo’ fiber, when they are made of rayon, and must legally be labeled "Rayon made from bamboo."

The question has again been raised......

"Can bamboo(technically "Rayon from bamboo") textiles be certified organic to the USDA National Organic Program (NOP)?" 

The last time this question was posed a few years ago, I was informed that bamboo was considered a product of a forest and therefore could possibly be eligible for FSC Certification.

Given the existing controversy that is still running wild in the textile market, I decided to again reach out to the USDA NOP for clarification. I received the following response:

According to Joan Shaffer, Office of Public Affairs at the USDA National Organic Program (NOP) “Bamboo” as a raw material for textiles is available for Organic Certification according to the USDA NOP.

“The organic standards cover agricultural products from livestock and crop.  Bamboo is a crop.”  Please see the explanations for textiles in this (Labeling of Textiles Under National Organic Program (NOP) Regulations) fact sheet.” 

“Below is an excerpt from the “Preamble” on “nonedible fibers products” in the organic standards.” 

“(6) Nonedible Fibers Products in the NOP. Some commenters asked the NOP to clarify the certification status of fibers such as cotton and flax. The final rule allows for certification of organically produced fibers such as cotton and flax. However, the processing of these fibers is not covered by the final rule. Therefore, goods that utilize organic fibers in their manufacture may only be labeled as a "made with..." product; e.g., a cotton shirt labeled "made with organic cotton."   USDA-AMS Office of Public Affairs

 The proper labeling in accordance with the FTC would be:

“Rayon(or Viscose) made from organic bamboo”

*Note that it is the bamboo itself as the CROP (raw material) that is allowed to be certified as organic to the USDA NOP Standard, and that the processing of the fiber and or garment is NOT considered in the process of certification to the USDA NOP Standard.

While this may sound a bit absurd (and about as clean as coal) that rayon can indeed be considered an organic textile, it is the bamboo itself as the raw material that is being certified as organic.

***See August 1, 2009 Post below: Labeling of Textiles: National Organic Program (NOP)

First Clean Coal, Now Organic Bamboo? By Coral Rose

FTC Mulches False Bamboo Textile Claims  By Coral Rose

FTC Charges Companies with 'Bamboo-zling' Consumers with False Product Claims

Bamboo-based Textiles, Actually Made of Rayon, Are Not Antimicrobial, Made in an Environmentally Friendly Manner, or Biodegradable

Note from Coral Rose: After much hard work and effort, THE FTC is to be congratulated on bringing integrity back to the Eco-Textile Market.

Press Release 8/11/09:

The Federal Trade Commission has charged four sellers of clothing and other textile products with deceptively labeling and advertising these items as made of bamboo fiber, when they are made of rayon. The complaints also charge the companies with making false and unsubstantiated “green” claims that their clothing and textile products are manufactured using an environmentally friendly process, that they retain the natural antimicrobial properties of the bamboo plant, and that they are biodegradable.

“With the tremendous expansion of green claims in today’s marketplace, it is particularly important for the FTC to address deceptive environmental claims, so that consumers can trust that the products they buy have the environmentally friendly attributes they want,” said David Vladeck, Director of the FTC’s Bureau of Consumer Protection. “When companies sell products woven from man-made fibers, such as rayon, it is important that they accurately label and advertise those products – both with respect to the fibers they use and to the qualities those fibers possess.”

FTC ALERT: HAVE YOU BEEN BAMBOOZLED BY BAMBOO FABRICS

FTC BUSINESS ALERT: HOW TO AVOID BAMBOOZLING YOUR CUSTOMERS

For the entire Press Release  Use this FTC Website link

How Green Is Your Wardrobe?

Orginal Post on EcoTextile News click here

MATLOCK – [08.07.08] A new on-line calculator which allows consumers to calculate the environmental impact of their clothing has been launched by Colour Connections Ltd – the same company which developed the ground-breaking textile eco-metrics (click here or see this blogs 7.18.08 post) for manufacturers and clothing brands.

The new ‘Household Textile Environmental Impact Calculator’ differs from textile eco-metrics in that it's aimed specifically at shoppers instead of the textile industry. Using a series of drop-down menus and a set of complex mathematics hidden behind its user friendly interface allows consumers to assess the environmental impact of the choices they make when they buy, care and dispose of household textiles and clothing.

All users have to do is choose from a list of common clothing items in terms of how many items they buy and how they are disposed in a twelve month period. Then users are asked how these items are washed, dried and ironed in a typical week. After pressing the 'calculate' button, users score a rating in terms of 'Environmental Damage Units' or EDU’s. The EDU value is an environmental measure which is scientifically arrived at based on water and energy use, the use of non-renewable resources and pollution.

The overall EDU score for each item of clothing depends on each individual consumer’s buying preferences, how they care for their garments and ultimately how they dispose of them.

“You may be surprised at how much impact your personal or family clothing preferences have on the environment,” said Phil Patterson, managing director of Colour Connections. “Doing one fewer tumble drying cycle per week saves 170 EDU’s, which is enough to make the fabric for 50 pairs of underpants.”

CLICK HERE to see how your wardrobe stacks up.

Copyright © 2008 Mowbray Communications Ltd 

Labeling of Textiles: National Organic Program (NOP)

USDA regulates the term “organic” as it applies to agricultural products through its
National Organic Program (NOP) regulation, 7 CFR Part 205.(LINK HERE)

● Raw natural fibers, such as cotton, wool ,flax, etc., are agricultural products and
are covered under the NOP crop/livestock production standards. Off-farm treatment of
raw organic fibers are not covered under the NOP crop/livestock production standards. 

● Although the NOP has no specific fiber or textile processing and manufacturing
standards, it may be possible for fi bers grown and certified to NOP crop/livestock standards
to be processed and manufactured into textile and other products which meet NOP
standards. 

Labeling for Certified Handling/Processing/ Manufacturing Operations 

Only textile products certified to the NOP production AND processing standards are eligible to be labeled
“100 percent organic” and “organic.” 

100 percent organic 

● 100 percent organic fiber content.

● Only organic processing aids.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing and manufacturing the final product must be
certified. 

Organic 

● Minimum of 95 percent organic fiber content.

● 5 percent nonorganic substances, as listed in Section 205.605 of the NOP regulation.

● No non-organic fibers.

● USDA Organic seal may be displayed on final product, in marketing materials, and in retail
displays—in proximity to certified products only.

● All operations producing, handling, processing,and manufacturing the final product must be certified. 

Other Uses of the Word “Organic” in Textile Product Labeling 

The NOP does not restrict the use of the term “made with organic …” in the labeling of textile products to
only those products manufactured in certified organic facilities or containing a minimum of 70 percent
organic fibers. However, all fibers identified in these textile products as “organic” must be produced and
certified to NOP standards. 

Labels on textile products from non-certified handling/processing/manufacturing operations: 

● May identify specific fibers as being organic if certified to the NOP crop/livestock standards.

● May state the percentage of organic fibers contained in the final product.

● May not use the USDA Organic seal.

● May not imply or lead the consumer to believe that the final product is certified organic 

Other Labeling Laws 

● NOP label requirements are in addition to those required by the Federal Trade
Commission’s (FTC) Textile and Wool Acts.

● Information on FTC labeling requirements for textiles can be found at the following websites:

Threading Your Way Through the Labeling Requirements of The Textile and Wool Acts

Calling it Cotton

Web Tool Calculates Textile Eco-Footprint

Originally Posted Here on Eco Textile News

PONTEFRACT – [07.18.08] Textile eco-metrics, the world’s first tool for simple assessment of the environmental impacts of textile production and use has been now been launched by Colour Connections in conjunction with Ecotextile News. It is now available to access directly from this web-site.

This revolutionary new web-based calculator takes into account the entire production route from fibre selection through to fabric production to dyeing and finishing. It also compares the production impacts of different washing and drying methods over the lifetime of a garment by consumers.

Using cleverly derived Environmental Damage Units (EDU’s) the impact of different fibres, fabric weights and dyeing and finishing methods can be compared in terms of water impact, energy use, use of non-renewable resources and pollution.

A simple colour coded report is produced that enables users to see at a glance where a particular product has most impact and highlights the areas that require attention or, conversely, where products and methods are good. The easy-to-read colour coded grid conceals the complex mathematics involved but an overall indicative EDU score enables easy comparisons between different textiles to be made.

Textile eco-metrics also provides simple, easy to understand explanations of what is good or bad about a particular fibre, fabric or process so it can be used to increase the levels of understanding about what is fact and what is ‘greenwash’ in the world of textiles and clothing.

Of particular interest to those committed to a sustainable textile industry are the Sub-Optimal Durability Units (SODU’s) that are calculated to show just how bad low durability clothing merchandise is for the environment. For example a product that has a production impact of 10 EDU’s and lasts for 50 domestic washes is far better than a similar garment that an impact of five production EDU’s but only lasts five washes – the latter garment would need to replaced nine times in the same lifetime so a penalty of 45 EDU’s would be awarded.

Textile Eco-metrics will be developed on an on-going basis and is available for an annual subscription.

To see how to use Eco-Metrics CLICK HERE.

CLICK HERE for more information on how to subscribe to EcoTextile News.

Copyright © 2008 Mowbray Communications Ltd

 

Sustainable Textiles.....

Here is the definition of Sustainable Textiles that I have been using the last two years in my  Eco-Innovations workshops

 

•  All materials and process inputs and outputs are safe for human and ecological health in all phases of the product life cycle.
• All energy, material and process inputs come from renewable or recycled sources.

• All materials are capable of returning safely to either natural systems or industrial systems.

• All stages in the product life cycle actively support the reuse or recycling of these materials at  the highest possible level of quality.

• All product life cycle stages enhance social well being.

Above Design by Harmony Art

 

THANK YOU.......

Thank you to all the regular readers of this blog, you have made this blog one of the
most searched for and read blogs on Organic Cotton, and Sustainable Fashion.... facts, practices and processes on the global internet.

Our regular readers are from every continent and dozens of countries including: France, Italy, Sweden, Ireland, Sri Lanka, South Africa, Australia and the UK.

Navigating Organic~Eco Labels; Smart Solutions for Sustainable Business

 

by Coral Rose

The terms “eco, green, sustainable and organic” are being used openly and interchangeably in the market with the term ‘certified organic.’ Inappropriate use of environmental labels has caused confusion in the apparel market. To be sold in the US as certified organic cotton, all textile fiber must be certified organic in accordance with the USDA NOP (National Organic Program) program (or) for Europe the EU organic certifications EU 2092/91. Currently that is the legal requirement for certified organic cotton.

This is NOT business as usual, nor is this a trend, this is an entirely new business model, one where you need to know your supply chain clear back to the farm or fiber production facility. Where does your fiber come from? What is the country of origin? Bottom line: There needs to be Supply Chain Transparency back to the farmer and to the seed.

One reason that there is confusion in the apparel market is that the NOP Organic Standards were originally created for food.

So why is cotton included? The USDA considers cotton a food product until it leaves the gin. Upon completion of the ginning process, where the seed and fiber are separated, cotton consists of 60% seed and 40% fiber. Cotton seed enters the food chain. Cottonseed oil is found in many processed snack foods, among them chips, cookies, crackers and salad dressings. Cotton seed is fed to livestock, dairy cattle and poultry as a high protein supplement. The remaining fiber is baled and shipped to textile mills to be spun into yarn for fabric.

The Global Organic Textile Standards (GOTS)has been submitted for trademark rights. GOTS has offered the world the first globally accepted standard for certified organic fibers. (As early as Fall 2008, we may see the USDA NOP adopt GOTS as the USDA NOP official standard for fiber. )

The GOTS standard for organic textiles covers the production, processing, manufacturing, packaging, labelling, exportation, importation and distribution of all natural fibres. The final products may include, but are not limited to fibre products, yarns, fabrics and clothes.

“The aim of the standard is to define requirements to ensure organic status of textiles, from harvesting of the raw materials, through environmentally and socially responsible manufacturing up to labelling in order to provide a credible assurance to the end consumer.” The standard provides for a subdivision into two label-grades. “ according to GOTS.

a) "organic" or "organic in conversion" 95% or more of the fibres must be of certified organic (or in conversion) origin. The remaining balance up to 5% may be made of non-organic fibres including defined regenerated and synthetic fibres. Blending (= mixing the same fibre in organic and conventional quality in one product) is not permitted.

b) "made with x % organic materials" or " made with x % organic in conversion materials" 70% - 95% or more of the fibres must be of certified organic (or in conversion) origin. The remaining balance up to 30% may be made of non-organic fibres. Regenerated and synthetic fibres are limited to 10% (resp. 25% in the US). Again blending is not permitted.

There is concern in the organic food and apparel market with standards that seek to certify blends and or low percentages of organic fiber content. If USDA/NOP recognizes GOTS as the US Standard for apparel, these minimal standards could go away as quickly as they appeared.

Your label claims CANNOT be deceptive according to the Federal Trade Commission (FTC) Environmental Marketing Guides.

“It is deceptive to misrepresent, directly or by implication, that a product, package or service offers a general environmental benefit.” Additionally, claims should be adequately qualified to avoid consumer deception.

FTC is an Independent Agency, appointed by the President. Its goal is to enforce consumer protection and antitrust laws AND the FTC has jurisdiction over environmental claims and Textile Labeling.

FTC’s GREEN GUIDES(link)  

The Green Guides do not set performance standards or grant eco-labels but require that labels and communications:

• Tell the truth
• Have substantiation
• Are based on consumer perceptions and require claims controls so they are not misleading
• Have clear qualifications & disclosures
• Specify whether claims apply to the product, the package, or both
• Do no overstate the product attributes

General Environmental Claims:

• Qualify: identify specific "green" attribute
• Third Party Certifications must be independent from advertiser
• Certification does not insulate advertiser - Avoid broad claims unless it is based on LCA (Life Cycle Assessment) and sustainable product standard addressing multiple environmental impacts      across the supply chain and social equity.

Symbols

• Avoid unqualified symbols, e.g. generic recyclable
• Use disclosures to qualify claims. Recyclable e.g. for this bottle may not exist in your area.

Bottom line; Before you label-Educate yourself!!!!!!

 

Have You Been Bamboozled by Bamboo?

By Coral Rose

BAMBOO IS NOT A FIBER.

BAMBOO IS NOT LEGALLY RECOGNIZED AS A FIBER BY THE FTC.

Bamboo is not, in and of itself, recognized as a fiber in the US or EU.  What is referred to as bamboo fiber in the market is actually viscose/rayon.

All viscose or rayon fiber from Bamboo (as a source) that is imported into the US must carry a legal fiber content label declaration of viscose or rayon. All bamboo imported into the EU must use of the legal content declaration viscose; the EU does not permit the use of the word rayon.

According to the FTC, you can label your garments; "Rayon from Bamboo"

As one of the fastest growing plants in the world, bamboo grows to its maximum height in about 3 months and reaches maturity in 3-4 years.  It spreads rapidly across large areas. Because of relatively quick growing time and the ability to be grown without fertilizers or pesticides, the fiber is currently being marketed as an ‘eco-green-sustainable fiber.’ There are also claims that viscose or rayon from bamboo is biodegradable and anti-microbial. There are potential risks associated with using bamboo as a polymer source for rayon since there is currently a lack of transparency in the supply chain. It is not always clear which type of bamboo is used for fiber, where it is grown, how it is cultivated, harvested etc. To date there are no known organic certification of bamboo. 

The process to make viscose or rayon fiber from bamboo is the same process used to produce viscose/ rayon from any other plant source. The cellulose is extracted from the bamboo, and then the cellulose is mixed with chemicals to convert the plant pulp into textile quality fiber. This process can be very polluting unless it is carefully controlled, which can be influenced by the age and condition of the equipment as well as whether there is any by-product recycling or effluent treatment.  

There is only one case of manufacturing a regenerated cellulose fiber-where the chemicals used in the process are completely recycled  with a recovery rate of 99.5%, this is known as a closed loop system. The fiber made using this closed looped process is Lenzings TENCEL ® Lyocell. More accurately described Lyocell is a solvent spun fiber in which the cellulose is directly dissolved keeping the cellulose much closer to that found in nature. TENCEL® Lyocell,  also carries the Oeko Tex 100 certification and FSC certification ( http://www.fsc.org/en/) Currently organic standards are not in place for certifying regenerated fibers using trees as a source e.g. Eucalyptus, or Beechwood.  FSC certification for TENCEL® Lyocell is for the forest and for the pulp, they also have been awarded the European-Eco flower label. (www.Lenzing.com)