Do e-Textiles for Fashion Require Specific Legislation and Developmental Guidelines in Order to Avoid Harmful Waste?

This research aims to identify the legislative gap that lies within textiles, electronics and nanomaterials for the safe disposal and recovery of e-textiles. This research examines the current knowledge and understanding of the environmental impact of new e-textiles and the legislation in place to make them safe as they are developed, manufactured and discarded within design for disassembly principles and circular economy theory. E-textiles are a rapidly expanding body of materials, with extensive prototyping and market testing being carried out globally for fashion, military and medical applications. This is leading to novel combinations of nanomaterials, electrical components and fibers. A small number of researchers such as Kohler 2011, 2013 and Veske, P. et al. (2019) have identified the need for regulations specifically in this area and have highlighted the potential environmental impact of e-textiles, stating, “Lack of standardisation of smart textiles and their waste management seems to be a significant barrier for industry entering the mass-market” Veske, P. et al. (2019). These new materials are partially covered by a myriad of directives and legislature within the EU and UK, which is leading to a call for action to clarify where e-textiles reside within current legislation and where e-textiles require specific consideration in this regard. Heinzel, T. and Hinestroza, J. P. (2020) discuss the philosophical questions needed to categorize materials that are both organic and inorganic and how we can address this dilemma. Electronic waste is a global problem as illustrated by Fedele (2016) [6], highlighting unregulated e-waste recycling in Ghana. In January 2018 the Chinese government enacted a ban on receiving waste from other countries, pressing countries to find solutions at home. The EU Waste Electrical and Electronic Equipment (WEEE) directive instigated in 2006 to address electronic waste management provides clear and actionable outlines for electronic devices with emphasis on producer and user responsibilities. In 2019, the WEEE directive stated the need to assess whether nano-embedded materials require specific treatment to avoid harmful waste. WEEE is based on circular economic theory, de Jesus and Mendonça (2017) highlight the barriers to a circular economy advocating intervention and environmental innovation to create a global multi-layered consensus. The same cannot be said for the complex directives and legislation relating to fashion and textile waste, where there are many recommendations and self-regulatory options with little incentive to take part when it comes to disposal and recovery. The Pulse report (UK Gov 2019) identified the need for producer responsibility in fashion and asked for “increased pressure from international political level(s)” and the UK government found that “clothing companies are not yet required by legislation to take responsibility for end of life recovery … unlike electrical and electronic goods.” The World Economic Forum (2019) makes the point that, “in contrast to paper, aluminium or steel, there is no credible recycling concept for the billions of tonnes of fast fashion items sold every year, mainly from non-biodegradable fibres”. Thus, considering the potential of e-textiles in fashion, the projected waste profiles are chilling. The EU and UK have sought to explore the effects of nanomaterials; however, there is currently no specific direction on the disposal of nanocomposite materials other than to assess nano substances as part of existing REACH legislation. The NanoRisk Governance Council are bringing together three nano research areas, RiskGone, Gov4Nano and NanoRigo, with one aspect of their remit being to consider the safe and sustainable growth of nanomaterials with a “safety by design” approach. A number of researchers have highlighted the potential impact of nanomaterials often used in e-textiles. Souza (2020) showed that silver nanoparticles “can be genotoxic, cytotoxic and induce morphoanatomical and biochemical changes” and Begum et al. (2011) recommend the ecologically safe disposal of graphene. The Royal Commission on Environmental Pollution (2009) led to the UK Government Facility for Environmental Nanoparticle Analysis and Characterisation, to detect and monitor manufactured nanoparticles in the environment, and a further body in the Nanotechnology Research Coordination Group (NRCG). Currently, nanotechnologies are being monitored and a number of research projects are underway however “specific regulatory measures for nanomaterials are still rare”, Fautz, C. (2013)