What is ‘Sustainable Cotton’ and how is it measured?
Pro bono article Published in Apparel Insider Issue 12 March 2020
What is Sustainable Cotton and how is it measured?
As Steven A. Cohen of Columbia University observes, substantive sustainability can be carefully defined and measured. But these days, there is also a symbolic field of sustainability, where organizations merely aspire to present an image.
So which category does ‘sustainable cotton’ fall into? Is it substantive or is it merely symbolic?
As Cohen notes, the measurement of ‘sustainability’ is currently conducted and verified by a host of non-profit organizations, who generate revenues by certifying the “sustainability” of other organizations. Since they do this without the equivalent of the Independent Audit, or Generally Accepted Accounting Practices, there is no uniformity. There is no assurance.
You can’t measure something if you can’t define it, and you “can’t manage something if you can’t measure it.” Without measurement we have no means of telling if the sustainability sectors’ decisions are making things better or worse. If their proclaimed “more sustainable” is substantive or merely symbolic. And without a definition, we don’t know what, if anything, is being, or should be measured.
As Cohen concludes, there are objective methods for measuring energy efficiency, effluents and emissions. These can be combined into a set of generally accepted environmental sustainability metrics. The same applies to health and economic impact. A sustainable, or more sustainable fiber would then be defined as one that meets or exceeds these minimum metrics.
Definition and Metrics
So how does this play out with ‘sustainable cotton’? What is Solidaridad’s definition? What are their sustainability metrics? How do they measure it?
Well, as you can see from their response, they don’t have a definition. All they have provided is a ranking, a list of initiatives whose cotton has been declared ‘more sustainable’ by the interested parties. Specifically: Better Cotton Initiative (BCI), organic (Textile Exchange (TE)) and so on.
Solidaridad tell us: “Sustainability standards aim to address the challenges associated with conventional cotton cultivation by prescribing sustainable farming practices”
Quite. But not one of these initiatives has a study showing that their prescribed farming practices actually are more sustainable (more on that shortly).
Solidaridad further claim: ”Together with their associated Chain of Custody, they assure buyers that the product meets specified requirements”
Chain of Custody
In February 2020, a fire at Nandan Denim killed 7 people. Nandan Denim was BCI, and the Chiripal group was TE certified - and yet the fire revealed a second floor factory with no ventilation, and a single ladder for access and egress. How did such construction pass certification?
Both BCI and TE invested heavily in the Xinjiang Production and Construction Corps (XPCC). The role of the XPCC in financing and organising one of the largest systems of internment and reeducation the world has ever seen, is now public knowledge, but regional experts have had suspicions since 2014/15. Moreover, the fact that the XPCC was a paramilitary organisation, that child and prison labour were involved in Xinjiang cotton production, and that cotton farming was being used to promote sinification, was well known, even in 2009, when BCI and TE launched their Xinjiang programs. How did all that pass certification?
It is self-evident that dangerous production facilities, and child and prison labour meet nobody’s “specified requirements”. The chain of custody does not exist.
Is labeling organic and BCI cotton more sustainable, misleading?
Solidaridad assert that despite having neither a definition, nor metrics to measure comparative sustainability, their ranking is not misleading:
“The editorial by Veronica Bates Kassatly looks critically at the sustainability claims drawn from two Life Cycle Assessments on cotton production[3]. We agree that any sustainability claims should be considered with a certain dose of skepticism. However, her editorial insinuates that no claims at all can be made about the positive change that cotton standards bring about. This is where we diverge.”
My November article states clearly at both the beginning, and at the end: “at the present time there is no data to substantiate claims that at a global level, one type of cotton is more sustainable than another.” That is not an insinuation, nor is it an editorial opinion. It's a statement of fact. Sustainability is not a question of what I, Solidaridad, or anyone else believes. It’s substantive. It can and should be measured - so where are the measurements?
In 2015, after 3 years of discussions under FAO aegis, all interested parties - including the 4 initiatives named by Solidaridad - reached agreement on “an empirically driven set of recommendations for a core set of indicators defining a minimum standard for sustainable cotton production”.(p.VII)
Solidaridad clearly values that FAO report ; it’s attached to their response. As you can see (p. 66), as a result of this analysis, 68 indicators were identified for assessing the sustainability of cotton production. The thrust of my article was precisely that on those principal metrics there is no evidence that one type of cotton is more sustainable than another. Indeed, despite the fact that the FAO report was supposed to be only a start, five years later, there seems to have been virtually no attempt by BCI or TE/organic cotton, or indeed the rest, to measure the impact of their production systems by any of these metrics. Why not?
Solidaridad admits: “Of course, all organisations working towards greater sustainability in cotton farming ultimately need to verify their theory of change by measuring this change. Most are aware of this and working on it.”
Ultimately? Working on it? Most - not all - are aware of it? TE was co-founded by Patagonia (as Organic Exchange) in 2002. BCI was ‘born’ in 2005, established in 2009.
It is a fundamental premise of development economics that it is unethical to intervene in the life of very vulnerable individuals - and most cotton farmers are poor, many are actually illiterate or semi-literate - without clear evidence that your intervention will benefit them. “Working on becoming” data driven and impact orientated is simply not good enough. This is where all these initiatives should have started in the first place - more than ten years ago.
BCI Cotton
When BCI was founded, it was apparently decided "We will ultimately need to test this standard and find places to test it." I asked BCI for those test results in November 2019. Coincidentally, I also asked - referencing the 2015 FAO report - : “Are BCI using this? Is anyone? Or has it died a death?” BCI did not reply to either question. Presumably then, we can conclude that BCI neither tested its standard ten years ago, nor did it have any intention of testing it in 2015 - or indeed, now. Why not?
The BCI website does promise one evaluatory publication: “A second part of the study investigated the following impact question: ‘How did the BCI standard affect the income, work, and environmental conditions of farmers and on-farm workers in the two countries in 2014-2015?’ A second briefing paper will be produced soon with the main findings from that part of the study.”
But we are now in 2020, and that study has never been published - it’s not listed on their website, and I have asked for it, repeatedly, without success. If the study demonstrates how thoroughly effective the BCI intervention was, they should have no issue with publishing it.
BCI has published one recent RCT . We have neither time nor space to go into details here, but this evaluation found no statistically significant impact on treatment farmers. After 3 years of BCI intervention, the study found a Hedge's g of less than 0.2 for production costs, yield and profit, meaning that on those measures, at the end of the study period, the control and treatment groups were effectively the same - just as they had been at the start (p.90).
Organic Cotton
As for organic cotton, apart from the TE desk study LCA in 2014 - which as my November 2019, article notes, under ISO standards, can’t be used to make comparative assertions, and can’t be used to attribute blue water consumption to the respective production systems (and has the wrong data for Xinjiang in any case) - I can find no independent studies whatsoever produced by organic initiatives, other than the C&A Foundation (C&AF) 2018 LCA, and SEIA.
As noted in my article, the latter showed that whilst (fortunately) the most affluent farmers self selected into organic farming, organic farmers ended up with a lower net income than their conventional neighbours; 1.6 times more debt and 20% higher input costs; their yields were lower than they had been led to believe they would be; and they received neither the subsidised inputs, nor the higher sales prices that they had been promised. As a result, a significant percentage had quit organic farming, and a significant percentage of those who remained were getting by, by not actually adhering to organic practices, and by using prohibited fertilisers and pesticides.
The C&A Foundation's own study concluded that one thing that urgently needed to be investigated was why farmers were abandoning organic production. That was in 2018. We are now in 2020. Despite clear evidence that their own initiative is causing harm to some of the poorest people on the planet, I can find nothing to suggest that such a study is even planned.
As for the C&AF LCA, as I noted in my article, that found that organic cotton actually consumed 10% more blue water per kilo than conventional production, even without including the upstream impact of manure. Once you include that, organic cotton’s emissions and water consumption per kilo, exceed conventional cotton’s. As for toxicity, manure in water is toxic - to both humans and aquatic life - more so than some pesticides. When we include this, the advantage of organic production on the toxicity count, also becomes far less clear.
Conclusion
I am not saying nothing needs to be done in conventional cotton farming. There are a wealth of measures that need to be introduced - banning Monocrotophos; finding non BT seeds better suited to local conditions; promoting regenerative practices and targeted irrigation... But at present, we have no evidence that any initiatives are actually achieving this globally, or even that Western initiatives are in fact, the best medium for this purpose.
Solidaridad’s response twice claims that my analysis is an editorial (their bold) - implying that it is primarily an opinion piece. As I said at the beginning and as I have further demonstrated here, there is currently no data to substantiate claims that at a global level, one type of cotton is more sustainable than another.
If that is merely my opinion, why haven’t Solidaridad produced the data that proves me wrong?