News about Our Work - 26 September 2018 Statement of the campaign for clean clothing (CCC) on the implementation concept of the Green Button of the BMZ The Federal Ministry for Economic Cooperation and Development is planning to introduce a state-owned metaseal for the textile supply chain ("Green Button") and therefore invited to a round table in September 2018 to discuss the implementation concept of this metaseal. The Clean Clothes Campaign took part in this discussion and is now sharing its views in writing with this opinion: The Green Button (GK) is supposed to be a state metaseal, which initially only refers to the stage of assembly. If they want to use the GK, companies must prove that: they comply with their corporate due diligence obligations, accepting as evidence the recognition of a roadmap within the framework of the Textile Alliance. the products covered by the GC comply with the minimum social, environmental and credibility requirements for a product label rated ‘good’ and ‘very good’ on the comparison platform ‘seal clarity’. Despite criticism of the fundamental weakness of product seals, the campaign for clean clothing welcomes the combination of company and product-related criteria in the awarding of the GK. However, we have massive requests for the previously planned design of this combination, which concern the claim level, the reach, the control, the communicable ability and thus also the credibility of the planned metaseal. We are critical of the following aspects: A state and legal reference system, similar to that of the Blue Angel, is not planned. Rather, the BMZ plans to integrate standards from commercial, private providers under the Green Button umbrella seal by using the ‘Seal Clarity’ reference system. Instead of a state standard setting and control, the supervision therefore lies with private institutions. Experience so far (see Rana Plaza, Tazreen, Ali Enterprises) has shown that this system of commercial and private certification is deficient, especially in the field of social standards and labour rights. The focus in the initial phase (years 2019 and 2020) is on assembly, even if the expansion to lower levels of the value chain is planned in the subsequent phases from 2021. However, the biggest problems in the environmental sector (and in some cases also in labour rights) lie in the processing stages that are upstream of assembly (such as wet processes). These are therefore not addressed in the initial phase of the Green Button. With this limitation to assembly, the Green Button lags behind the market development, which is characterized by the fact that many companies already offer products with certified raw materials and also use seals that cover the entire supply chain. The presentation of the roadmap of companies that are members of the Textile Alliance is insufficient as proof and access authorisation for the use of the Green Button, as the requirements (time and quantity targets) currently do not even cover all ILO core labour standards (such as freedom of association or anti-discrimination, which would include measures against gender-based violence in the workplace) and the level of ambition of the individual objectives is left to the members themselves. the time and quantity targets set out in the roadmaps do not provide sufficient information on the actual exercise of the due diligence obligations, as only the roadmaps are published, but not the underlying actual state (the ‘baseline’) that the roadmaps are intended to improve. In addition, the verification process is non-transparent, as the evidence is not published and there are no clear, substantive criteria for the accepted evidence. The seals rated ‘good’ on the ‘Siegelklarheit’ platform, which according to current plans of the BMZ are to be accepted as sufficient for the Green Button, do not meet the demands made by ambitious companies in the sector and consumers interested in sustainable purchasing. The Green Button does not require any disclosure of the supply chain, although many companies have now published their suppliers (e.g. Aldi, Lidl, C&A, Primark, H&M, Esprit, Tchibo, etc.) and also standard organizations disclose the certified production companies (e.g. GOTS). As a result, the requirements for the GK fall short of the standard already established in the market today. The Green Button is a voluntary seal, there is no legal regulation for the award criteria of the GK as well as for the duty of care of all companies. Public communication that promises "100% socially and ecologically sustainable products" is unreliable and possibly legally vulnerable. Audit results and certifications have to be questioned and verified by the state, they currently only represent steps, but do not always reflect reality. If consumers are to trust a green button, they must meet the following requirements: As an access authorisation to the Green Button, minimum due diligence requirements for companies must be met. The roadmaps in the Textile Alliance are insufficient as evidence according to the current state of play. These minimum requirements shall include, in accordance with the OECD Guidance for Textiles and Footwear, inter alia: The purchasing policy of the company wishing to use the GK must be reviewed (e.g. PPSA of ACT). In audits, trade unions/NGOs must be involved and content of audits must be shared with employees. Secure, trustworthy complaint mechanisms must be in place. Preventive measures against gender-based violence must be implemented. Measures to implement ILO core labour standards and livelihood wages must be implemented. A state control system must be in place: It is necessary to establish legal rules for monitoring the certification of third parties, e.g. in the form of independent controls, and to plan an on-site inspection in the producing countries with the involvement of trade unions and NGOs from the outset (proof-keeping). The governance structure and verification system of the Green Button must provide for mechanisms that can penalise misuse of the GC. The CC must also be applied to the other production stages of the entire supply chain at the initial stage. If this does not happen, the Federal Government must set clear time and binding targets for the various stages of the GK from the outset so that the strategic character of the meta-seal becomes clear. This must also be transparently noted to the public on the roof seal itself. Under the GK umbrella seal, only those seals/standards of the ‘Siegelklarheit’ platform that are rated ‘very good’ (subject to an assessment of the revised criteria) may be recognised. Control of these seals/standards through a credible and transparent multi-stakeholder initiative is also an important criterion. All measures must be reported transparently to the public. This also includes the audit reports of the certified production facility. The evidence must demonstrate the extent to which it has contributed to improving working conditions and the environment (impacts). It must be clearly communicated to consumers which stage of value creation the GK covers and which does not yet. In the Advisory Board, it must be ensured that low-ambitious companies and association representatives are not overrepresented and, above all, that ambitious companies are heard.In general, we are critical of the introduction of a metaseal. In the context of strengthening human rights due diligence obligations in accordance with the UN Guiding Principles on Business and Human Rights, we see the introduction of a legal framework for transparency, due diligence and liability obligations as a priority.Dr. Gisela Burckhardt (FEMNET e.V.) Dr. Sabine Ferenschild (Südwind e.V.)
