Making the label count for cotton: why accurate sustainability metrics matter.

Cotton is one of the world’s most important natural fibres - renewable, biodegradable, and vital for the livelihoods of millions of farmers. Yet today, the way its sustainability is measured could define its future. Increasingly, global textile marketsare shaped not just by fashion trends, but by environmental labelling systems intended to inform consumer choices. Among these, the European Union’s Product Environmental Footprint (PEF) methodology has emerged as a frontrunner, designed to underpin future product labelling and green claims. But behind the promise of transparency lies a critical challenge: current environmental impact models often fail to reflect the true benefits of natural fibres like cotton. The risk? Simplified scoring systems may unintentionally favour synthetic fibres - oil-based and persistent in nature - over fibres that are renewable and biodegradable. For cotton, this could have far-reaching implications for demand, market access, and its role in delivering a sustainable future for textiles. This is where the Make the Label Count (MTLC) campaign steps in. 

What is Make the Label Count? 

MTLC is a global coalition of natural fibre industries, researchers, NGOs, and sustainability experts advocating for fair and accurate environmental labelling in textiles. The campaign was launched to address the limitations of the EU’s PEF methodology, which, in its current form, overlooks critical aspects of natural fibres’ performance and ecological contributions while ignoring some of the synthetic fibre environmental impacts. Many cotton industry bodies have officially joined MTLC, recognising a shared challenge with other natural fibres: how sustainability is measured matters just as much as how it is delivered. If the methodology guiding consumer-facing labels is flawed, the very fibres that support regenerative agriculture, rural economies, and circular systems could be penalised.

The problem with current metrics 

The PEF system relies heavily on Life Cycle Assessment (LCA) - a tool designed to measure environmental impacts across a product’s life. While LCA provides valuable insights, it is not a suitable method to measure agriculturally farmed products such as cotton and compare them to mined products like polyester, hence the current PEF approach fails in several key areas when applied to textiles.

 Overreliance on PEF & missing metrics 

Despite well-documented shortcomings, the European Commission continues to make the PEF methodology the cornerstone of its regulatory agenda - including the Ecodesign for Sustainable Products Regulation (ESPR) and the framework forsubstantiating green claims. This insistence persists even though the model overlooks critical factors such as microplastic and plastic waste pollution - issues strongly linked to synthetic fibres. By relying on a flawed and incomplete system, these policies risk misguiding consumers and brands, favouring fossil fuel based textiles over natural fibres that offer genuine circularity and biodegradability. Positive ecosystem services ignored Cotton grown under climatesmart or regenerative systems can provide measurable environmental benefits, from soil health improvement and biodiversity support to carbon sequestration in soils. These services enhance resilience and contribute to climate mitigation, yet they are not accounted for in current models. Failing to capture these positive impacts undervalues natural fibres and misrepresents their role in sustainable production systems. 

Assumed behaviour vs. real-world evidence.

Policies increasingly link sustainability to product longevity and physical durability, yet these assumptions often ignore real consumer behaviour.Synthetic fibres perform well in lab durability tests, but most fast fashion items - made from synthetics - are discarded quickly due to fast changing fashion trends, not material failure. Current models reward this technical strength while overlooking natural fibres like cotton, which offer other forms of durability. Cotton garments are easier to repair, maintain comfort, and often enjoy multiple life cycles through resale and donation. These practical and emotional durability factors drive real-world longevity but remain largely unmeasured in today’s metrics. 

Grower voices and rural livelihoods excluded.

 PEF methodology development has largely excluded the social and economic dimensions of sustainability, sidelining cotton growers - who are central to rural economies in over 70 countries. Millions of smallholders rely on cotton as a primary source of income, supporting education, healthcare, and community development. Ignoring these factors not only creates an incomplete sustainability picture but also undermines fair policy outcomes that affect livelihoods globally. The result? An incomplete picture that risks shaping policy and consumer behaviour in ways that undermine natural fibres and incentivise further reliance on fossil fuel-based textiles. 

What has the campaign achieved so far? 

Despite these challenges, MTLC has made significant progress - turning a niche technical issue into a recognised priority inglobal sustainability policy debates. 

1. Securing commitments to improve metrics The EU instructed its Technical Advisory Board to develop better indicators for natural fibres, including biodiversity impacts, better circularity indicators as well as biogenic carbon storage. These elements are essential to recognising cotton’s role as a renewable fibre and its contribution to circularity. 

2. Elevating critical issues The campaign helped achieve formal acknowledgment of microplastic pollution in EU discussions – a key milestone for fair fibre comparisons. Synthetics are responsible for microplastic leakage, a burden cotton does not carry. 

3. Building a strong, science-based coalition Since launch, MTLC has: Hosted over 100 speaking engagements and three policy events, engaged with 80+ EU policymakers directly, doubled coalition membership, adding key sectors including cotton and garnered strong support from researchers, NGOs, and industry stakeholders - cementing its credibility as a constructive, evidence-driven voice. 

How the conversation has shifted 

In just three years, MTLC has moved the sustainability debate beyond simplistic narratives: 

• Raised awareness of the limitations of PEF in accurately assessing natural fibres. 

• Challenged the “one-score-fits-all” approach, which risks misleading consumers. 

• Positioned natural fibres as central to circularity and nature-positive solutions for fashio

Ms. Elke Hortmeyer, Head of Economic Research & Communications at Bremen Cotton Exchange and Co-Spokesperson at Make the Label count.