SFA Open Letter to the EU Council | Herder Perspective on PEF

Subject: Herder Perspective on the Product Environmental Footprint (PEF)

Date: 13th June 2024

Dear Council of the European Union,

I am writing to you not only as the CEO and Founder of the Sustainable Fibre Alliance (SFA) but also on behalf of the millions of herders and herding communities in Mongolia, China, Afghanistan and across the world. We are deeply concerned about the European Council’s movement towards the Green Claims Directive (GCD) and its references to the Product Environmental Footprint (PEF).

The introduction of the PEF legislation and methodology will undoubtedly lead to a rise in greenwashing claims within the fashion industry, as the lack of carbon acknowledgement alongside no social, cultural or biodiversity elements, does not accurately reflect the differences between plastic-derived fibres and natural fibres.

Natural fibres are an important source of income for the world and its millions of Indigenous communities, for example, one-third of Mongolia’s population depends on their livestock, which makes up 80% of a herder’s income. It is this livestock sector in Mongolia that provides food security for the entire population and therefore classes cashmere as a strategic commodity for Mongolia. However, this income would likely diminish if the PEF legislation were to come into effect, and the collateral damage to herders would be catastrophic, as the majority would become impoverished, leading to the end of an indigenous way of life and nomadic culture.

Altansukh Tumee, a cashmere herder and leader of the Bayntol cooperative in Mongolia, said during the Growers Perspective session at the Natural Fibre Connect (NFC) 2023 conference, that “Overcoming these climate issues and keeping animal husbandry sustainable, we have several programmes and financial programmes on this. But since the cashmere alone makes up almost 70% of households’ income, with this income we have to do everything, like paying our children’s school fees and all other things…the Mongolian Government issued soft loans, but because of this shortage of properties to provide as a collateral, we are not able to get that additional funding to improve our livelihoods and to spend the money on livestock husbandry.”

During the Growers Perspective session at NFC, Frances van Hasselt, a mohair grower and designer in South Africa, also said “The biggest problem that we face…is the price volatility at land-level. We are doing all this stuff, we’re getting the standards, and we are 100% supported. But what is unsustainable is that in the mohair industry, from one sale to the next, you do not know what you are going to get for your mohair.”

This new legislation would also see the diminishing of the natural fibre sector over time with a huge decrease of pastoralists and stewards looking after the world’s rangelands. Mongolia has one of the largest intact rangeland habitats in the world, with a unique array of native wildlife. Collectively, these regions are home to a wide range of internationally important animals and plants, many of which are endemic and globally threatened.

Jock Menzies, a wool grower in Australia, said during the same NFC session that “A lot of our neighbours are all getting sold up to cattle farmers that are not continuing to grow wool because the economics are not there for us to continue…We need to make this a lot better because, otherwise, if we are not able to be sustainable we are obviously not going to be able to supply the wool…but also we won’t have the situation where we can do all of the good things to the environment on our land as well. A good farmer plants trees and looks after his environment but if we are not able to do that, because we are not getting paid enough, then that is the first thing that suffers, which is not what we want for the planet.”

If the European Council votes to include the PEF methodology on the 17th of June 2024, the Green Claims Directive will have a significant impact on the survival of many Indigenous communities that depend on livestock herding globally, marginalizing pastoralist practices, and will instead accelerate the growth of fast fashion.

On behalf of cashmere herding communities across Mongolia, China and Afghanistan, we urge the EU to reconsider the use of the current PEF and PEFCR methodology and ensure that this policy truly reflects the impact of the natural fibre sector.

The SFA have joined together with a global collective of herders, farmers and supporters to sign the open letter to the Council of the European Union to ensure the voices of those at the grassroots-level are heard. View the open letter here.

Una Jones


21 June 2024