Submission for a ReMade in Australia Partners Program:

Supporting Sustainability in the Textile and Garment Industries

GREN Pty Ltd – Rae Knopik, CEO

Cosignatories: Rosella Street – Mick Fritzy, Cofounder | Circolink – Alison Jose, CEO

February 2023

About GREN

GREN is a responsible and sustainable clothing company that’s leading the way in creating a circular economy. At GREN, we are dedicated to providing high-quality, circular t-shirts made from recycled cotton. Our unique supply chain model ensures that the t-shirts we produce are collected and recycled again and again, creating a truly closed-loop system. As a vertical supplier, we are committed to creating a positive impact on the environment and our communities.

Section 1: Background on the ReMade in Australia brand

The ReMade in Australia brand is focused on promoting products made from recycled materials and promoting sustainability in the manufacturing process. It aims to raise awareness about the importance of reducing waste and promoting environmentally conscious consumption patterns. The government’s initiative to establish this brand could help to drive the growth of a green economy in the country, create jobs and support the development of a circular economy. Overall, it seems like a positive step in promoting sustainability and reducing waste in Australia.

Based on the discussion paper, it is unclear whether the ReMade in Australia brand would be applicable to secondhand textiles and clothing collected from consumers and resold. The discussion paper primarily focuses on promoting products made from recycled materials, but does not specify whether it includes secondhand products.

For instance, if a blank tshirt is collected from either a) post-consumer waste or be b) pre-consumer waste, and then altered in some way, it is not clear if that altered product could use the ReMade in Australia brand.

In the context of a circular economy, the inclusion of secondhand products in the ReMade in Australia branding is a crucial issue. The circular economy aims to reduce waste and extend the lifecycle of products, and secondhand products play a significant role in this regard. By reusing pre-existing products, such as t-shirts, rather than creating new products from raw or existing materials, the circular economy reduces the environmental impact of production and the demand for finite resources. As such, the inclusion of secondhand products in the ReMade in Australia brand helps to reinforce the idea that the brand is not only about recycled materials, but also about the circular economy and its principles. Additionally, it gives consumers a clear indication of the products’ circular journey, providing a sense of transparency and accountability in the supply chain. The lack of clarity around whether altered secondhand products can use the ReMade in Australia brand raises important questions about the branding’s ability to effectively promote the circular economy and its principles.

Section 2: Key design considerations for the brand

2.2 Scope of the brand’s application

Should business-to-business or intermediate products be included in the scope of the brand, if so what type of business-to-business products would you like to see included?

By incorporating business-to-business or intermediate products made from recycled materials, the brand can not only boost its credibility and reach but also encourage the use of recycled materials in a wider range of products. The business-to-business category could encompass remanufactured products such as mattresses, interior design products, carpet, underlay, and soundproofing, as well as regenerated products made from say, 80% or more, waste, including plastic products like glasses, hair clips, and furniture. Choosing the right types of products to include in the brand’s offerings requires careful consideration of factors such as recycled content, sustainability, circularity, and alignment with the brand’s values and goals. To ensure the integrity and transparency of the brand, the Australian government and relevant stakeholders must also consider the certification and monitoring process for these products.

The inclusion of business-to-business products could have a substantial positive impact on the initiative, given the larger volume of trade between businesses. To maximize the impact of this initiative, it would be beneficial to include a label or tagline, such as “Made in Australia from Recycled Content,” on all certified products. This clear and straightforward messaging will help communicate the concept effectively.

How should the ReMade brand be presented to effectively differentiate between a product and its packaging when only one is ReMade?

To clearly distinguish between products and their packaging, the ReMade brand would label each with specific labels indicating the use of recycled materials. For instance, the product could be labeled “ReMade Product” and the packaging “ReMade Packaging,” with additional information such as the percentage of recycled materials used in each for clarity. The brand would provide clear guidelines through its website or marketing materials to educate consumers on the difference and importance of both product and packaging sustainability. By providing transparent information, the ReMade brand can effectively communicate the sustainability of each aspect of a product and contribute to the circular economy.

To further promote sustainability, the brand could consider creating a Material Passport for each product that outlines the volume and percentage of each component material. This data, which vendors would be required to provide to be certified under the ReMade program, could be aggregated and analyzed over time and by geographic area to monitor the use of

recyclable materials in products and facilitate future reuse, remanufacturing, or recycling. The Material Passport would also store information such as the origin of recycled materials, whether they are pre- or post-consumer, contaminate data (if relevant), recyclability and biodegradability, estimated product life, resources used in production, use, and disposal, and ease of extraction of biodegradable and recyclable materials.

Should there be guidelines to define how the ReMade in Australia brand should be displayed on labels, products and projects, or should this be left up to the brand user? For example, should there be a black and white version of the brand as well as a coloured one?

To enhance the clarity and consistency of the ReMade brand’s message to consumers, guidelines for its display are necessary. These guidelines should outline the proper usage, size, and placement of the ReMade brand on labels, products, and projects. Having both colored and black and white versions of the brand will also allow for versatility in different design settings. These guidelines not only make the brand easily recognizable and distinguishable from others, but also reinforce its values and goals of promoting sustainability and circular economic practices.

What unintended consequences could the ReMade in Australia brand have on consumers’ understanding or valuation of related labels that might appear alongside the ReMade in Australia brand?

The ReMade in Australia brand could have unintended consequences on consumers’ understanding and valuation of related labels if the brand is not clearly defined and communicated. For example, if consumers see a product that is labelled as “ReMade in Australia” and another product that is labelled with a different sustainability certification, they may not understand the difference between the two labels or place more value on one over the other. This could result in confusion and potentially undermine the effectiveness of other sustainability labels. It is important for the ReMade in Australia brand to be clear and consistent in its messaging and to clearly differentiate itself from other sustainability labels. Additionally, it is important for the brand to be transparent about the standards and criteria that a product must meet in order to use the label. This will help to ensure that consumers can make informed decisions about the sustainability of the products they purchase.

What consequences could the ReMade in Australia brand have for brand owners’ use or adoption of on-pack recycling labels such as the Australasian Recycling Label?

The ReMade in Australia brand could potentially create confusion for consumers as it may lead them to believe that the product is fully made from recycled materials, which may not be the case. This could result in mistrust of other on-pack recycling labels, such as the

Australasian Recycling Label, which only indicate that the product or its packaging is recyclable. The concept of a Material Passport could address this issue by providing more detailed information about the product’s composition, which could be displayed in a table or through a QR code that could be scanned for further information. The ReMade in Australia label could also include an indication of both the packaging and product’s compliance with the requirements of the label. However, it is important to consider potential areas of confusion and negative impacts that may still arise.

Are there specific types of products that should not be eligible to use the brand, because they do not support the intent of the brand or might damage the brand’s reputation?

Yes, certain products may not be eligible to use the ReMade in Australia brand due to their incompatibility with the brand’s goals and values. For example:
Examples of products that may not align with the intent of the ReMade in Australia brand and potentially damage its reputation include:

Products made from a low percentage of recycled materials, or where the environmental benefits are minimal. ie:
- products made from recycled materials that were not sourced sustainably
- products that have a limited lifespan or high environmental impact during their production or disposal.
- products made from highly toxic or non-renewable materials, such as certain types of single-use plastic
Products made using unsustainable production processes or with a negative impact on the environment or human health.
- single-use plastics like plastic bags and bottled water
- products made from hazardous materials like lead or asbestos
- products manufactured using fossil fuels and leading to high carbon emissions.
- products made in sweatshop conditions or with child labor can also have a negative impact on human health and violate ethical considerations.
Products that have been falsely or misleadingly labeled as made from recycled materials.
Products made from mixed waste streams where hazardous materials are present and not properly managed.
- electronics made from mixed waste streams that contain hazardous materials such as lead, mercury, or cadmium, which can be harmful to human health and the environment if not properly managed.
- products made from mixed waste plastic streams, where some of the plastic may contain harmful chemicals or additives that can leach into the environment.
Products that harm human health, or may be considered racist or offensive, should also be considered for ineligibility.
Brands that use more than 20% new manufactured textiles, including rPET, should also be excluded from using the ReMade in Australia label.

The use of software by accredited resource recovery providers can help determine the use of hazardous materials in products and which circular materials stream is appropriate for repurposing the fibers. This information can then be used for the certification and standards of “new” products.

To ensure the integrity of the brand and maintain consumer trust, clear criteria and guidelines should be established for product eligibility. The discussion paper did not provide specific guidelines, but it is important to consider the factors mentioned above in the development of the brand.

What factors should the department consider in developing a rule that could allow the licensing body to refuse granting the brand to products that may devalue the brand?

The department should consider the following factors in developing a rule for licensing the ReMade in Australia brand:

Compliance with environmental and sustainability standards: Products must be made using environmentally friendly and sustainable production processes and with a minimum negative impact on the environment and human health.
Percentage of recycled content: The amount of recycled materials used in the production of a product should be substantial enough to make a meaningful difference in reducing waste.
Management of hazardous materials: The presence of hazardous materials in mixed waste streams should be properly managed to prevent negative impacts on the environment and human health.
Transparency and traceability: The production process, materials used, and environmental impact should be transparent and traceable, allowing for independent verification of environmental claims.
Brand reputation: The department should consider the potential impact on the reputation of the ReMade in Australia brand, and take steps to prevent the use of the brand by products that may devalue it.
Consumer understanding: The department should consider how consumers may interpret the brand and whether products bearing the brand may mislead consumers or create confusion.

2.3 Making recycled content claims

Is ISO 14021:2016 the best way to define eligible recycled content for ReMade in Australia? If not, how should eligible recycled content be defined?

The ISO 14021:2016 standard provides guidelines for environmental labels and declarations, including recycled content claims. However, it may not necessarily be the best way to define eligible recycled content for the ReMade in Australia brand. The department may consider other factors such as the source and quality of the recycled materials, the sustainability of the production process, and the overall environmental impact of the product. The definition of eligible recycled content should be based on a comprehensive evaluation of these factors and aligned with the overall goals and objectives of the ReMade in Australia brand.

If pre-consumer recycled material is used in ReMade products, how could this be distinguished from virgin inputs or post-consumer recycled content used in that product?

Differentiating the types of recycled materials used in ReMade products is crucial in informing consumers about the sustainability and environmental impact of the product. To achieve this, a clear tracking and labeling system must be established to distinguish between pre-consumer recycled material, virgin inputs, and post-consumer recycled content.

It is also essential to differentiate between “Reused” and “Remade” as these terms have different meanings and consequences. “Reused” refers to the practice of using a product again without significant changes, while “Remade” refers to transforming a product into a new form through significant modifications. Understanding the distinction between the two terms helps consumers make informed decisions based on their sustainability and environmental values.

The Material Passport can store this information, including details such as the origin and type of recycled content used in the product. If the information is too extensive to fit on the product label, a QR code to the Material Passport can be used. Consumers who are interested in more detailed information can access it through the Material Passport, which can be stored electronically and updated as necessary, such as when the components of the product change.

The Circlolink software can capture ReMade applicants’ entries, and products made with known chemicals, such as high-vis fire retardant workwear, will have specific certifications included in the “new” product certification requirements.

If ISO 14021:2016 is adopted to define recycled content, how could ReMade applicants demonstrate pre-consumer material has come from another manufacturing process to the one developing a ReMade product?

ISO 14021:2016 defines recycled content as the proportion of recycled materials used in a product compared to the total weight or volume of the product. To demonstrate that pre-consumer material has come from another manufacturing process, ReMade applicants could provide evidence of the source and composition of the pre-consumer material, as well as how it was collected and processed. This could include documentation of the original manufacturing process, the type and weight of the waste material generated, and the methods used to collect and process the material. Additionally, ReMade applicants could implement traceability systems to ensure the source and integrity of the pre-consumer material used in their products. These systems could include product labeling, barcodes, and certifications.

Should the minimum amount of recycled content required for consumer goods, construction materials and construction projects be set at 10% by weight? If not, what should the minimum amount be?

The minimum amount of recycled content required for various sectors should vary. For example, the textile industry may have a minimum requirement of 40% recycled or reused materials, while a different sector may have a lower requirement. This approach allows for the unique challenges and opportunities of each sector to be considered and ensures that the minimum requirement is achievable and promotes the use of recycled materials.

How often should a company’s operations be assessed by the licensing body to verify percentage recycled content claims?

The frequency of assessments by the licensing body to verify a company’s recycled content claims may vary depending on several factors, such as the company size, the products being manufactured, and the associated risk level. Smaller companies may only require annual or bi-annual assessments, while larger companies may need more frequent assessments.

Moreover, companies that meet certain criteria could be awarded “trusted trader” status, which would allow them to reduce or eliminate the need for ongoing assessments. This recognition would demonstrate their commitment to using recycled materials and maintaining high standards for their products.

How should the ReMade in Australia brand appear when applied to construction projects, such as a new bridge or road? For example, should the brand appear on existing project material and signage?

The brand could appear on project signage, on materials used in the construction, or both, to communicate the use of recycled materials to the public.

A QR code could be scanned to view the project’s Material Passport details.

2.4 Promoting Australia’s circular economy

Does a requirement for Australian recycled content to make up at least 50% of the total (both imported and domestic) recycled content used in ReMade products strike an appropriate balance between promoting the use of Australian recyclate and ensuring flexibility for businesses to manage supply? If not, should a lower or higher amount be required and why?

A higher requirement for Australian recycled content may support local job creation, reduce carbon emissions from transportation, and foster the growth of local recycling infrastructure.

Should the amount of Australian recyclate required as a percentage of total recycled content used in ReMade products increase over time?

The requirement for the amount of Australian recyclate to make up a certain percentage of total recycled content used in ReMade products could be reviewed and adjusted over time to align with the goals and objectives of the circular economy. This could be based on factors such as the availability of local recyclate, market demand, and the environmental impact of importing recyclate from overseas. Increasing the amount of Australian recyclate over time could help promote local recycling and support the development of a robust circular economy in Australia. However, it is important to consider the impact on businesses and ensure that the requirements are feasible and attainable.

How should ‘Australian recycled content’ be defined?

“Australian recycled content” can be defined as the material that has been collected, processed, and remanufactured within Australia, regardless of its original source. For the purpose of the ReMade in Australia brand, this definition can include both pre-consumer and post-consumer recycled materials, but exclude waste exported overseas for processing.

For clothing and textiles, the definition of “Australian recycled content” should include the reuse of clothing and textiles made elsewhere if they are processed, reused, or remanufactured within Australia, using Australian labor and resources. Onshore production refers to the production of clothing and textiles within Australia using domestically sourced raw materials, whether new or recycled.

What recycled materials used by Australian businesses are not collected or processed in Australia?

Some recycled materials used by Australian businesses may not be collected or processed in Australia and may need to be imported. This includes certain types of materials that are in high demand and are not available in sufficient quantities in Australia. Examples of these materials could include recycled cotton, high-tech plastics, and rare metals. Additionally,

some recycled materials may need to be imported due to a lack of processing capacity in Australia or a lack of local demand for the material.

2.5 End of use outcomes

Is a recyclability requirement the best way to ensure that ReMade products support Australia’s transition to a circular economy?

A focus on recyclability alone may not fully address the sustainability and environmental impact of ReMade products. While a product may be technically recyclable, it could still have negative consequences, such as the release of microplastics from polyester products. To promote a truly circular economy, it’s important to consider not just recyclability but also the biodegradability of materials and their impact throughout their lifecycle. For instance, natural fibers like cotton, which can biodegrade at the end of their life, may be more preferable than synthetic fibers like polyester, even if the polyester is made from recycled materials.

To gain a better understanding of the sustainability of ReMade products, it would also be useful to gather data on the volume of products that contain recycled materials but cannot be recycled themselves. This information would provide a clearer picture of the materials that would be excluded if the program only focused on recyclable products.

When considering recyclability, should the department take into account different factors for packaging, consumer goods and for construction materials and projects?

Yes, different factors should be taken into account when considering recyclability for packaging, consumer goods and construction materials and projects. Packaging recyclability, for example, could be evaluated based on the materials used, design features, and the end-of-life disposal options available for the product.

Consumer goods could be evaluated based on their ability to be recovered and recycled, as well as their potential for being refurbished or repurposed. In the case of textile materials and projects, recyclability could be evaluated based on the materials used, the ability to disassemble and reuse components, and the potential for materials to be recovered and recycled at the end of the product’s life. Each sector will have its own unique challenges and considerations, and the department should carefully evaluate these when developing guidelines for the ReMade in Australia brand.

If a recyclability requirement is mandated for ReMade products, what key elements should be included in recyclability is defined? And why?

When defining recyclability for ReMade products, there are several key elements that should be considered, particularly in the context of the textile industry. These include:

Material composition: The type of material used in the production of textiles is important for determining recyclability. For example, natural fibers such as cotton or wool are more easily recyclable than synthetic fibers like polyester.
Collection and sorting systems: In order for textiles to be recycled, they must be collected and sorted into their different materials. Collection and sorting systems must be in place to ensure that recyclable materials are separated and processed.
Recycling infrastructure: A well-established recycling infrastructure is necessary for the processing and reuse of recyclable textiles. This includes facilities that can break down materials into their individual fibers, clean and sort them, and then spin them into new yarns or fabric.
Product design: The design of the product must also be considered, as products that are difficult to disassemble or separate into different materials may not be recyclable.
End market: The end market for the recycled materials is also important, as demand for recycled textiles must exist for the recycling process to be economically viable.

These elements should be considered when defining recyclability for ReMade products, as they will impact the ability of textiles to be recycled and the overall sustainability of the textile industry.

It would be ideal if participating products indicated the ease with which component materials can be separated for recycling. This information could be included in the Material Passport.

Are there any types of products that use recycled content that are not recyclable but should be eligible for the ReMade in Australia brand? If so, what are these products and why should they be eligible?

Yes, there are certain products that use recycled content that may not be recyclable but are biodegradable and should still be considered for the ReMade in Australia brand. For instance, in the textile industry, natural fiber textiles such as cotton, linen, and wool can be made from recycled materials but are not infinitely recyclable. Nevertheless, they are biodegradable and will break down into natural elements at the end of their lifecycle, causing minimal harm to the environment. These products align with the principles of a circular economy and the goal of the ReMade in Australia brand, which is to promote the use of sustainable materials and practices.

Moreover, the ReMade initiative has the potential to create new production processes that blend recycled and non-recyclable materials, resulting in new products that didn’t contain any recycled content in the past. This will create a new market and provide more opportunities for recycled content to be transformed into useful products. The question of whether to restrict the supply to only products that can be recycled needs to be answered. If so, then the label should only apply to products that can be recycled.

Should the ReMade in Australia brand include a different requirement where recycled content products can achieve outcomes that are higher on the waste hierarchy than recycling?

The ReMade in Australia brand has the potential to drive sustainability and environmental responsibility beyond just recycling. By requiring products that use recycled content to also prioritize waste reduction through reuse and reducing virgin material usage through product design, the brand can align with the principles of a circular economy and promote the development of truly sustainable products.

It’s crucial to take into account not only a product’s end-of-life disposal, but also its entire lifecycle, from production to use to disposal. This comprehensive approach to sustainability can incentivize businesses to create more environmentally responsible products.

The Material Passport should include this information, providing a comprehensive resource for consumers to make informed decisions based on their sustainability values.

2.6 Product safety, standards and regulation

What relevant voluntary or mandatory standards, specifications, quality, safety, or label requirements are used within your sector (please specify your sector)?

In the textile industry, relevant voluntary standards and specifications include the Cradle to Cradle (C2C) certification, which evaluates a product’s sustainability and environmentally safe design. The C2C certification takes into account the entire lifecycle of a product, from raw material sourcing to manufacturing, use, and end-of-life disposal. Other relevant standards in the textile industry include Global Recycled Standard (GRS), Organic Content Standard (OCS), and the Global Organic Textile Standard (GOTS). These standards provide guidelines for the production and labelling of textiles made from recycled or organic materials and ensure that these materials meet certain environmental and social criteria. Additionally, the textile industry adheres to various quality, safety, and label requirements, such as Oeko-Tex Standard 100, which tests for harmful substances in textiles, and the U.S. Federal Trade Commission’s Green Guides, which provides guidelines for environmental claims made on product labels.

What systems or data do you have in place or collect to show compliance with safety and information standards?

The garment and textile industry typically use various systems and data to show compliance with safety and information standards, such as:

Product testing and certification: Textile and garment products are tested for safety and quality by third-party laboratories and are certified to meet specific standards,
such as the Oeko-Tex Standard 100 for textiles or the Global Organic Textile Standard (GOTS) for organic clothing.
Traceability systems: Traceability systems are used to track raw materials, intermediates, and finished products from the supply chain to the final product, ensuring that the products meet the necessary standards and regulations.
Supply chain audits:Regular supply chain audits are conducted to verify that suppliers are compliant with safety and information standards, including social and environmental standards.
Labelling requirements: Textile and garment products are required to have specific labels or markings that provide information on the product’s composition, care instructions, and origin, among other things.
Management systems: Internal management systems, such as quality management systems (QMS) or environmental management systems (EMS), are implemented to ensure that they are meeting the necessary safety and information standards.

These systems and data help the garment and textile industry to demonstrate their commitment to safety, quality, and sustainability, and provide consumers with the necessary information to make informed purchasing decisions.

Do you consider the ReMade in Australia certification rules would benefit from the development of standards, guidelines, or technical specifications to support their interpretation? If so, what should the department consider?

Yes, it could be beneficial for the ReMade in Australia certification rules to have the development of standards, guidelines, or technical specifications to support their interpretation. This can help to provide clarity and consistency in the application of the rules, and ensure that all stakeholders, including businesses and consumers, have a clear understanding of what is required to meet the certification criteria.

The department should consider factors such as:

Defining clear and consistent criteria for recycled content, biodegradability, and recyclability
Developing guidelines for assessment and verification of recycled content claims
Providing technical specifications for the use of specific recycled materials, such as textiles, in different product categories
Establishing a system for ongoing review and updating of the standards and guidelines to keep pace with technological advancements and changing market conditions.

Incorporating these elements into the development of standards, guidelines, or technical specifications can help to ensure the long-term success of the ReMade in Australia brand and support the transition to a circular economy.

2.7 Verifying recycled content claims

Providing records to demonstrate ReMade claims could be difficult for newly established products. What additional evidence could be used to support new businesses and product lines?

To better support new businesses and product lines, evidence could be provided in the form of:

Documentation showcasing the implementation of recycled materials, including plans for using recycled content, record-keeping, chain of custody models, and traceability.
Test results demonstrating safety and adherence to information standards.
A declaration of the systems and procedures in place to ensure compliance with safety and information standards.
Ingredient and formulation information for all batches of products produced.
Evidence of business controls to guarantee compliance with relevant standards.

This information could be stored in the Material Passport, with some information being restricted and accessible only for auditing purposes by authorized parties.

Does proof of purchase information, such as invoices and receipts, typically provide sufficient information to prove the provenance of materials? What other records can prove the use of Australian recyclate in ReMade products?

Proof of purchase information, such as invoices and receipts, may not always provide sufficient information to prove the provenance of materials used in the textile and garment industry. Other records that can be used to prove the use of Australian recyclate in ReMade products include a chain of custody records, traceability system records, production records, and supplier inquiries. These records can provide information on the volume of Australian recyclate purchased, the incorporation of the recyclate into the final product, and the location of the manufacturing process. Additionally, site visits to review the manufacturing process and assessment of documentation provided can also provide evidence of the use of Australian recyclate.

How can percentage recycled content claims be verified where the percentage of recycled content may change from batch to batch? Is a mass balance approach that averages the use of recycled contentment over time sufficient?

The percentage of recycled content claims in the textile and garment industry can be verified through a combination of methods, including laboratory testing and record-keeping. The mass balance approach, where the average use of recycled content is calculated over time, can provide a good indication of the overall recycled content of a product, but it may not accurately reflect the recycled content of each individual batch. To ensure that each batch of a product meets specific recycled content standards, it is important to have detailed records of the inputs and outputs of each batch, including the source and amount of recycled

materials used. These records can be audited and compared to the results of laboratory testing to verify the accuracy of the recycled content claims.

Are there existing recycled content certification schemes that could be recognised to help shortcut the application process for the ReMade in Australia brand? Examples could include Good Environmental Choice Australia, Global Green Tag or International Sustainability and Carbon Certification.

Yes, there are other certification schemes for recycled content in textiles and garments, including

Cradle to Cradle Certified, which evaluates the entire lifecycle of a product and recognizes high levels of recycled content and closed-loop recycling processes.
GRS (Global Recycled Standard), which verifies the use of recycled materials and requires traceability of those materials throughout the supply chain.
Bluesign, which is a sustainability certification system that evaluates the environmental impact of textiles and garments, including the use of recycled materials.
OEKO-TEX Standard 100, which evaluates the presence of harmful substances in textiles and recognizes recycled content.
RCS (Recycled Claim Standard), which is a certification system that verifies the use of recycled content in textiles and other products.

These certifications can provide assurance that a product contains recycled materials and help to shorten the application process for the ReMade in Australia brand.

Should or could a conformity assessment standard or information standard be developed to define and verify recycled content use as part of the ReMade in Australia brand?

In regards to the textile and garment industries, it could be beneficial for a conformity assessment standard or information standard to be developed to define and verify recycled content use as part of the ReMade in Australia brand. This could establish clear criteria and methods for measuring recycled content, as well as provide a reliable means for consumers to verify the accuracy of recycled content claims made by manufacturers. Such a standard would also help to ensure consistency and fairness across the industry and could be recognized by relevant authorities and organizations.

Are you aware of existing information standards that could support or streamline verification for the scheme?

Yes, there are existing information standards in the textile and garment industries that could support or streamline verification for the ReMade in Australia brand. Some examples include:

Global Recycled Standard (GRS) – This is an international certification system that verifies the content of recycled materials in products, including textiles and garments.
Oeko-Tex Standard 100 – This is a globally recognized standard that certifies textiles and garments as free from harmful substances and safe for human use. It also verifies the use of recycled materials in products.
Organic Content Standard (OCS) – This is an international standard that certifies the organic content in textiles and garments, including recycled content.

By using these existing standards, the ReMade in Australia brand could streamline the verification process and provide more credibility to their claims of using recycled content in their products.

Should verification requirements be phased, becoming more sophisticated over time as the circular economy matures? For example, should the brand include a requirement to use a chain of custody model or to use traceability systems to prove recycled content claims in the future?

In regards to the textile and garment industries, verification requirements for recycled content claims could be phased and become more sophisticated over time as the circular economy matures. For example, the ReMade in Australia brand could include a requirement to use a chain of custody model or traceability systems to prove recycled content claims in the future. This would help ensure transparency and accuracy in recycled content claims, while also encouraging the development of more advanced technologies and systems to support a circular economy in the textile and garment industries.

As technology advances, it may become possible to incorporate blockchain technology into the verification process for the ReMade in Australia brand in the textile and garment industries. The use of blockchain can help provide an additional level of transparency and traceability, allowing for more secure and efficient tracking of recycled content use.

For example, a blockchain-based system could allow for the secure and transparent recording of transactions related to the use of recycled materials, such as the transfer of ownership and custody of materials, as well as the tracking of materials through the production process.

As the technology continues to evolve, it may be possible to add even more sophisticated features, such as real-time tracking and monitoring of materials, the use of smart contracts, and integration with other sustainability certification programs.

However, it is important to note that the implementation of blockchain technology would likely require significant investment and coordination between stakeholders in the textile and garment industries, as well as the development of industry-wide standards and protocols for using blockchain technology in this context.

Section 3: Licensing conditions

3.2 The role of the licensing body

Are there any other activities you expect a licensing body for the scheme to carry out?

Yes, there are several other activities that a licensing body for a scheme like ReMade in Australia could carry out, excluding those mentioned in the discussion paper. These include:

Developing and maintaining the standards, guidelines, and requirements for the scheme, including requirements for recycled content and verification of claims.
Approving and monitoring the use of the ReMade in Australia brand, ensuring that products bearing the brand meet the standards and requirements of the scheme.
Providing technical and scientific expertise to support verification of claims, such as recycled content and environmentally sustainable production practices.
Conducting regular audits and inspections of participants to ensure compliance with the standards and requirements of the scheme.
Providing training and education for participants, including ongoing support for the improvement of environmentally sustainable production practices.
Promoting the benefits of the ReMade in Australia brand and the circular economy to the wider public and stakeholders, including customers and suppliers.
Managing and maintaining a database of participants and their products, which could include information on recycled content, production processes, and sustainability practices.
Working with other organizations and initiatives to promote the circular economy and support the development of the industry.
Updating and adapting the standards and requirements of the scheme in response to new technologies, scientific developments, and market trends.

What relevant experiences and capabilities would you expect the licensing body to have?

For a scheme like ReMade in Australia, the licensing body should have relevant experiences and capabilities in the following areas:

Knowledge of circular economy and sustainable production practices in the textile and garment industries.
Ability to develop, maintain and enforce standards, guidelines and requirements for the scheme, including requirements for recycled content and verification of claims.
Experience in brand management, marketing and promotion, with a focus on promoting the benefits of the ReMade in Australia brand and the circular economy to the wider public and stakeholders.
Technical expertise in verification of claims related to recycled content and environmentally sustainable production practices.
Knowledge of auditing and inspection processes and the ability to conduct regular audits and inspections of participants to ensure compliance with the standards and requirements of the scheme.
Ability to provide training and education for participants, including ongoing support for the improvement of environmentally sustainable production practices.
Experience in database management and maintenance, including maintaining a database of participants and their products, which could include information on recycled content, production processes and sustainability practices.
Experience in collaborating with other organizations and initiatives to promote the circular economy and support the development of the industry.
Ability to adapt to new technologies, scientific developments and market trends, and update and adapt the standards and requirements of the scheme as needed.

The above-highlighted information could be drawn from the Material Passports for each product so as not to duplicate data collection.

Do different industry sectors require the licensing body or certified approvers to have particular attributes or technical capabilities to verify their compliance with the certification rules?

Yes, different industry sectors within the textile and garment industries may require the licensing body or certified approvers to have particular attributes or technical capabilities to verify their compliance with the certification rules. For example, the technical requirements for verifying recycled content in the textile industry may differ from those in the garment industry. The licensing body or certified approver would need to have the relevant technical expertise and knowledge of the specific industry sector to effectively verify compliance with the certification rules. It may also be beneficial for the licensing body or certified approver to have a deep understanding of the production processes and supply chain dynamics of each industry sector to effectively verify claims and assess environmental sustainability practices.

3.3 Licensing conditions

How long should an initial licence be granted to use the ReMade in Australia brand?

The length of the license could range from a few years to an indefinite period and will depend on factors such as the maturity of the circular economy, the level of compliance with the certification rules, and the success of the brand in promoting the circular economy. It is important for the licensing body to regularly review and evaluate the performance of the brand and adjust the licensing framework accordingly to ensure the ongoing sustainability and success of the scheme.

Should applications to renew a licence to use the brand be as rigorous as the first application to use the brand, or is it sufficient to demonstrate the product remains compliant with the certification rules?

The renewal process should demonstrate that the product remains compliant with the certification rules, however, the rigor of the renewal process may depend on the specific requirements of the certification scheme and the licensing body. The licensing body may choose to periodically conduct audits or inspections, or review updates to production processes, to ensure ongoing compliance. If there have been changes to the certification rules or standards, the licensing body may require the renewal application to demonstrate compliance with the updated requirements. It’s important for the licensing body to have a clear and transparent renewal process that balances the need for ongoing compliance with the administrative burden for participants.

What regular activities should the administrator take to ensure compliance with the brand?

For the textile and garment industries, regular activities that the administrator should take to ensure compliance with the ReMade in Australia brand include

Conducting regular audits and inspections of participants to verify that their products continue to meet the standards and requirements of the scheme.
Monitoring the use of the ReMade in Australia brand, to ensure that products bearing the brand are still compliant with the standards and requirements of the scheme.
Maintaining and updating a database of participants and their products, which should include information on recycled content, production processes, and sustainability practices.
Providing ongoing training and education for participants, including support for the improvement of environmentally sustainable production practices.
Updating and adapting the standards and requirements of the scheme in response to new technologies, scientific developments, and market trends.
Evaluating the performance of the brand and making recommendations to the department to support the ongoing performance of the brand, including providing regular audit and review reports.
Conducting random and targeted audits to monitor the use of the ReMade in Australia brand by participants, and investigating any complaints or instances of non-compliance.
Providing an annual report to the department relating to the administration of the scheme, including the number and type of products certified, any licensing and other fees received, and information about compliance and enforcement activities.
Protecting the goodwill and reputation of the ReMade in Australia brand by promoting its recognition as a trusted indicator of recycled content.

Other branding schemes such as the Australian Made Australian Grown brand use a tiered licensing fee structure to encourage the participation of small to medium

businesses, with licensing fees scaling according to business turnover. Should a similar fee structure be used to implement the ReMade in Australia brand?

Encouraging the participation of small to medium businesses in the circular economy is crucial for its success. By implementing a tiered licensing fee structure similar to the Australian Made Australian Grown brand, the ReMade in Australia brand can make it more accessible for small to medium businesses to participate. This will result in wider adoption of circular practices, leading to a more sustainable future for both the environment and the businesses. Furthermore, small to medium businesses often serve as incubators for innovation and new ideas, which can drive progress and growth in the circular economy. By making it easier for these businesses to participate, the ReMade in Australia brand can help to drive this progress and growth, leading to a more circular and sustainable future for all.

In terms of possible costs to use the brand, what other factors should the department consider?

To encourage the adoption of the ReMade in Australia brand and support the transition to a circular economy, it’s important for the department to consider the potential impact on small businesses. Small businesses should not face any added financial burden when using the brand, as promoting sustainability is not only good for the environment but also for their long-term viability. The intersection between capitalism and environmental sustainability must be taken into account, and the latter should be prioritized. To achieve this, small businesses should be provided with incentives such as subsidies or tax benefits, rather than a tiered licensing fee structure, which would align with the goal of promoting a circular economy.

From an economic standpoint, waste to landfills creates large negative externalities. A 2012 study showed that Australian businesses spend $1.4 billion annually to send $26.5 billion worth of materials to landfill, indicating an imperfect market that justifies government intervention, including incentives like subsidies or waived licensing fees.

Section 4: A possible ReMade partners program

How should ReMade Suppliers be recognised and promoted to brand users if a partners program were established?

If a partners program were established for the ReMade in Australia brand, suppliers could be recognized and promoted in various ways, including

Listing on the ReMade in Australia official website as a recognized supplier
Access to marketing and promotional materials, such as logos and banners, to showcase their partnership with the brand
Opportunities to participate in joint events and initiatives, such as trade shows and sustainability campaigns
Inclusion in press releases and other forms of media coverage related to the brand
Opportunities to collaborate with other ReMade partners on research, innovation, and product development projects
Tax benefits and other financial incentives to support their sustainable business practices.

What output standards do brand users want their recycled content inputs to meet?

From the perspective of those working in the textile/garment industries, brand users would want their recycled content inputs to meet high standards for quality and sustainability. This may include

Technical standards for the processing of recycled materials to ensure the end product is of high quality, durable, and suitable for its intended purpose.
Environmental standards for the sustainability of the material sourcing and processing practices, including the use of non-toxic and biodegradable inputs.
Standards for the traceability and transparency of the supply chain, including information about the source and quality of the recycled inputs.
Standards for the end-of-life management of the products made with recycled inputs, including recycling or composting options.

Overall, brand users in the textile/garment industries would want to ensure that their recycled content inputs meet high standards to provide confidence to their customers that their products are made sustainably and responsibly.

Are there other industry-led activities with an alignment to a potential partners program?

The ReMade in Australia brand could benefit from collaborating with existing initiatives and organizations in the garment and textile industry that promote sustainability and circular economy principles. This includes partnering with organizations such as the Global Recycling Foundation, the Sustainable Apparel Coalition, and the Zero Waste Fashion Initiative.

In addition, the industry could work with trade associations, academic institutions, and research organizations to advance best practices and innovative solutions in recycled content production. By utilizing these existing networks, the ReMade in Australia brand could maximize its impact and drive change across the entire supply chain.

A survey showed that 3 in 5 Australians find it challenging to make sustainable purchases due to unclear and confusing information. To address this challenge, the government could launch an official online marketplace for products made from recycled materials. The platform would provide Material Passport data for each product, easy comparison between products, features that support trust and prevent scams and a partner program marketplace for trading recycled content.

The online platform would also collect and provide data at the individual, business, and organizational levels to track progress against sustainability goals and provide insights for policy development, program evaluation, and commercial opportunities. The platform should be Australian-made and operated and could be leased by the government as the official marketplace for ReMade products. To ensure transparency and accountability, the platform could be periodically opened for retendering.