We Need To Talk About Cotton

31 Jan

This article was written pro bono and published in Apparel Insider, Issue 7, May 2019

What is the most pressing sustainability challenge facing the global fashion industry today? Two words: underpaying and overconsumption. We’re producing too much clothing, and paying too little for it.

This ever cheapening of apparel production is reflected in the end cost of clothing. Figures from the European Environment Agency, for instance, show that the relative price of clothing in the EU is about 64 percent of what we paid in 1996; in the UK and Ireland it's nearer 33 percent.

We get what we pay for, and a whole generation of consumers have come to expect that, where fashion is concerned, they shouldn’t have to pay very much, and it is taken as given, that the burden of cost-cutting should be shouldered by unseen farmers, factory, and garment workers a world away.

As far as sustainability goes, this is surely the number one issue the global fashion industry needs to address. And yet, if one takes a look at the websites of major brands and the environmental initiatives in the fashion industry, the sustainability debate is heading along a completely different path. Discussions around sustainability are focused on fibres - and farmed fibers in particular.

The switch to ‘more sustainable’ fibres, particularly ‘sustainable cotton’ is what dominates the sustainability conversation. At the annual Copenhagen Fashion summit, the ‘Pulse of the Fashion Industry’ (Pulse) is measured, based in large part on whether the brands concerned are moving to "more sustainable fibres’. But who decides what makes a fibre more sustainable? This question is vital, for if the sustainability of fibres is the yardstick by which large swathes of the fashion industry are measuring progress, the information and data on which fibres are actually labelled ‘sustainable’ needs to be absolutely bullet-proof.

I want to focus attention here on cotton to illustrate how, where questions around ‘sustainable’ fibres are concerned, nothing is ever quite as it seems.

A quick look at the corporate responsibility pages of brands generally cited as those on the cutting edge of environmental concern, from Marks and Spencer (M&S), ASOS, and H&M to Stella McCartney, reveals an array of claims that their cotton is more sustainable - primarily because they use Cotton Made in Africa (CmiA), organic cotton, or Better Cotton Initiative (BCI) cotton.

One recommendation by last year's, House of Commons Environmental Audit Committee (EACOM) report on ‘Fixing fashion: clothing consumption and sustainability’ was that the UK Government reform taxation to reward fashion companies that move from conventional to organic cotton.

In February this year, with the support of the Prince's Trust and M&S, Textile Exchange (TE) launched the 2025 Sustainable Cotton Challenge (SCC 2025) aimed at promoting a move by fashion brands, away from conventional cotton, towards ‘more sustainable’ cultivation methods - once again, that primarily means CmiA, organic or BCI cotton.

Concomitantly in terms of fibre ‘scoring’, the Higg MSI, used by the Pulse, sets the impact of conventional cotton fibre at 60.6 per kilo; switch to CmiA and that drops to 14.0; a move to organic cotton lowers it to 11.2. That is a drop in harmful impact of between 77% and 82%!. Higg is a widely used industry tool and has huge credibility in the apparel and textile space. And the use of these kinds of numbers is surely an important factor in the improved sustainability ratings that H&M and others, regularly report, and receive awards for.

The message from this tool then – as well as from the websites of brands and retailers - is clear: conventional cotton is bad, and a switch to a ‘sustainable’ alternative, such as organic, is a smart move for the environment and for farmers.

Is organic cotton more sustainable than conventional cotton? And if so, where is the data which proves this?

Actually, much of the published information on organic cotton sustainability – including that on brand websites - circles back to Textile Exchange as the origin. For example, TE’s organic cotton Life Cycle Analysis (LCA) was the sole source for the EACOM recommendation.

(http://farmhub.textileexchange.org/upload/library/Farm%20reports/LCA_of_Organic_Cotton%20Fiber-Full_Report.pdf)

Does this LCA show that organic cotton is more sustainable than conventional production? No. In fact, in terms of the global debate, it doesn’t really prove anything.

And why is that? Because, as the organic LCA itself points out on page 57, to assess comparative sustainability you need more than just an LCA. To quote: “Life Cycle Assessment is a powerful standardised tool for quantitative evaluation of potential environmental impacts on product basis; however, given the social and socio-economic dimensions of sustainability, further aspects than those investigated in this study need to be considered for a holistic assessment of sustainability of a production systems or a comparison with another production system.”

In other words, to see if a method of agricultural production is really sustainable, you first and most importantly, need to look at how it impacts the farmers. In study speak, you need not just an LCA but also a social and economic impact analysis (SEIA).

So does Textile Exchange (TE) list an SEIA for the cottons that it recommends as more sustainable? No. The SCC 2025 lists no SEIAs at all. Arguably then, we can make no comparative assertions whatsoever about the general sustainability of the different cotton production methods at this time.

Can we at least make some restricted assertions, such as “consumes less water” or “reduces emissions”? For this we need to look at LCAs. So does TE list LCAs for the cotton production systems that it represents as more sustainable?

For BCI, there does not appear to be so much as an LCA - certainly none are listed in the SCC2025. With no LCA and no SEIA, can we make any comparative assertions about the relative sustainability of BCI versus conventional cotton on a global scale? No, we can’t.

The 2025 Sustainable Cotton Challenge cites two cotton production LCAs. One for CmiA (https://www.cottonmadeinafrica.org/en/english-docs/cmia-standard-1/impact-measurement/76-cmia-life-cycle-assessment-pe-international-2014-11-2014/file ). And the one for organic cotton, already mentioned

http://farmhub.textileexchange.org/upload/library/Farm%20reports/LCA_of_Organic_Cotton%20Fiber-Full_Report.pdf

Both of these LCAs state quite clearly they cannot be used to make comparative assertions between different cotton production systems – basically because in agriculture you can only compare production methods if you are looking at crops grown (or livestock raised) in the same place, at the same time, under the same conditions. And because the ISO has strict standards on what sort of information needs to be provided for comparative assertions disclosed to the public https://web.stanford.edu/class/cee214/Readings/ISOLCA.pdf .

Of course ISO is voluntary and whilst the LCAs adhere to its standards, the textile and clothing industry in general appears not to. The anti-competitive nature of unsubstantiated sustainability assertions does not seem to be considered. https://www.iso.org/files/live/sites/isoorg/files/archive/pdf/en/environmental-labelling.pdf

So neither of these LCAs can tell us whether, on environmental grounds alone ( that is, even ignoring the crucial social and economic aspects), either CmiA cotton, or organic cotton, is more sustainable than conventional cotton.

Do they at least give us an indication that in terms of water consumption or emissions, CmiA and/or organic cotton are more sustainable than conventional cotton? No. They do not even do that.

SCC2025 states:

For CmiA cotton: ‘Water Consumption: 1 m3 / 1,000 kg fiber (~100% reduction - LCA)’

For organic cotton: ‘Water Consumption:182 m3 / 1,000 kg fiber (91% reduction - LCA).’

But the LCAs concerned show no such thing.

The CmiA study actually only considered Cotton produced in Zambia and the Ivory Coast. Zambian agriculture is almost entirely rain fed, so conventional cotton from Zambia will consume approximately the same amount of blue water as CmiA cotton - virtually none. The same applies to Ivory Coast cotton. https://unctad.org/en/PublicationsLibrary/websuc2017d2_en.pdf

As for the organic cotton LCA, this considered data from India, Turkey, China and the USA, and of the 9 regions considered, 4.5 were effectively, completely rain fed. So conventional cotton produced in those regions will have consumed approximately the same amount of irrigation water - none. Another 3 regions averaged 50-150 m3 of irrigation water per year - again, conventional cotton from those regions probably used much the same amount of irrigation water as the organic cotton - very little.

So how did TE arrive at the massive “Water consumption” figures shown?

a) By only looking at blue or irrigation water, rather than water as a whole.

The organic LCA actually puts total water consumption at 15,000 m3 per tonne of fiber, rather than 182. The CmiA study claims the total freshwater used to produce 1,000 kg of CmiA lint cotton was around 3,400m3, not 1m3.

And

b) By comparing the CmiA and organic irrigation water consumption, with that of a now outdated LCA of conventional cotton ( COTTON INC. 2012), which studied primarily irrigated cultivation.

In this context the CmiA LCA states:

“101. CmiA is rain fed, i.e. no water is used for irrigation. In contrast, all the regions under investigation in COTTON INC. 2012 were at least partially irrigated. It therefore comes as no surprise that blue water consumption, which is of environmental relevance here, was orders of magnitude smaller for CmiA (1m³/1,000 kg lint cotton) compared to the global average.”

And

The Organic LCA states:

“5.2.4 Water use

In the regions under study, organically cultivated cotton receives relatively little irrigation in addition to naturally occurring rainfall. The irrigation water requirement of a crop is obviously mainly determined by climatic conditions although the actual usage is also influenced by irrigation techniques. This is why low irrigation rates cannot be attributed exclusively to the organic cultivation scheme.”

In short, the two LCAs themselves state that the comparative assertions on irrigated water consumption that TE is making are neither valid nor permissible.

How about emissions then, does either study indicate that at least on that basis, CmiA and/or organic cotton are more sustainable than conventional? Not really.

Both of these studies take livestock inputs to be burden free. This is actually a major issue for organic cotton, due to the importance of cattle manure and urine as fertilisers and pesticides (manure is also a common input in Zambian and Ivory Coast agriculture). Manure, like leather, is a by-product of the beef and dairy industries. It is standard in the sustainability industry, to assign a significant portion of the livestock burden to leather, but – interestingly - none at all to manure.

The TE organic cotton LCA (page 44) actually considered the implications of abandoning this anomaly, and found that if as little as ten per cent of the livestock burden is assigned to cotton, the environmental impact of organic production roughly doubles.

I pointed all of this out to TE, in a series of emails throughout March, 2018. They were unable to help.

In summary, my own research into this issue suggests there is no clear and unambiguous evidence that either CmiA or organic cotton consume less water when grown under the same conditions as conventional cotton. Nor is there any conclusive evidence that emissions are lower. The data simply is not there to make such a claim at the current time.

Is there any more information out there which rigorously compares the environmental credentials of cotton grown to different standards? Actually, there is. Last year, the C&A Foundation published an LCA https://www.candafoundation.org/en/resources/4332environmentallcareport4th.pdf

and an associated SEIA https://www.candafoundation.org/en/resources/4333socioeconomicstudyweb.pdf

comparing cotton production by BCI, conventional and organic cotton farmers in Madhya Pradesh, India.

These studies were not included in the SCC2025 document, which is a shame because they are the most up to date research we have in this area and would be very useful reading for brands considering whether or not to sign up to this initiative.

So what do they tell us? The LCA found that organic cotton consumed more blue water than conventional cotton. Moreover, in terms of water consumption, farmer income and farmer debt, the clear winner in the C&AF studies was actually conventional cotton.

In December 2018, the C&A Foundation issued a statement which said: "Organic cotton cultivation consumes 60 per cent less blue water when compared to conventional cotton cultivation,” along with some other favourable statistics for organic cotton about eutrophication, climate change and so on.

For Emissions etc.,these were certainly understated because:

a) possibly as a result of a mix-up, or due to social desirability bias, the amount of chemical fertilisers and pesticides used by organic farmers was set to zero, despite the fact that the associated SEIA had found 33-35 percent of organic farmers were using them.

and

b) once again, manure was assumed to be burden free - despite the fact that a 2013 study

(http://www.krepublishers.com/02-Journals/JHE/JHE-41-0-000-13-Web/JHE-41-2-000-13-Abst-PDF/JHE-41-2-107-13-2399-Biradar-N/JHE-41-2-107-13-2399-Biradar-N-Tx[2].pmd.pdf )

found that for farmers in Maharashtra, India, Manure ranked second in a list of reasons to keep livestock after milk to sell. Indeed, 7% of the farmers surveyed ranked manure as the main reason to keep animals.

As for blue water (all freshwater inputs excluding rainwater, so primarily irrigation water in this context) the LCA definitely does not show that organic cotton consumes 60% less. Indeed it probably consumes 15% more than conventional cotton.

The raw data on irrigation and yield per hectare included in the report shows that in irrigation alone, blue water consumption was 350 tonnes per tonne of organic seed cotton. In a telephone discussion on March 12, 2019, CA&F confirmed this figure, but were unable to explain where the figure of 140 tonnes that they were using came from. Nor were they able to tell me what the upstream blue water consumption was for organic cotton. We can however conclude that if, as stated, rainwater was estimated at 79%, then of the 1880 tonnes of blue water used by organic farmers, rainwater provided 1485 tonnes. In that case, bluewater excluding rainwater, equaled 395 tonnes per tonne of organic cotton. That is 15 per cent more than the 344 tonnes of bluewater used to grow one tonne of conventional cotton.

What conclusions can we draw from all of this? The C&A studies were in one area, measured over one period of time, so to draw broader conclusions from them would be misleading. But this is the point: basing comparative assertions on the C&A Foundation’s LCA has the same limitations as using the LCAs related to organic and CmiA cotton referred to above. None of these LCAs, in isolation, should be used to influence cotton sourcing on a grand scale, as appears to be the case at the present time.

So is the Higg overstating the negative impact of conventional cotton - probably. Is it understating the relative impact of CmiA and organic cotton - almost certainly. So are brands such as H&M and Kering overestimating their progress to sustainability as a result - yes, by definition. And what about what I will loosely refer to as “factory fibers” that the Higg prefers? Clearly, we should start looking at those closely on a case by case basis. One obvious issue is that most LCAs assume best practice. But much of the damage caused by the textile industry is precisely because, in order to cut costs, best practice is not followed. Effluent is dumped into lakes and rivers, untreated; harmful emissions are leaked… But the environmental impact of fibers is calculated as if everyone was purchasing their inputs from the pristine shores of Lake Como. But that conversation is for another time. For now, let’s stick with cotton.

So where to from here? All of this is by no means intended to criticise apparel brands or retailers for shifting towards BCI-accredited or organic cotton. Instead, it is hoped that it can help kick-start a much-needed debate around issues of cotton sourcing and, particularly, claims around sustainable sourcing. Is the move towards cotton standards such as BCI, organic and CmiA actually more sustainable ? Based on my own investigations into the issue, we simply do not know.

Do we need more data comparing the different ways in which cotton is grown? Of course we do. If brands are switching in their droves to various cotton standards, we need to be absolutely sure they are doing it for the correct reasons and based on top quality research and data.

Above all, we need to be sure we are doing the right thing by cotton farmers - many of whom are extremely poor. Switching from conventional to identity cottons comes at a cost to farmers, and the conversion can be challenging, particularly with organic cotton. This is not a switch to be undertaken lightly, and should not be made without comprehensive data to demonstrate that this is the right step for farmers – as well as for the environment.

We Need To Talk About Cotton

Further Reading

Veronica Bates Kassatly

We Need To Talk About Cotton

Further Reading

Sustainable Cotton: Myths versus Reality

Veronica Bates Kassatly