Sustainably-Sourced Renewable Materials: Why They Deserve A Clear Place In EU Sustainability Policy

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Picture of Analoli Del Cueto Menendez

Analoli Del Cueto Menendez

Analoli Del Cueto Menendez is a Junior Public Affairs Consultant specialising in EU eco-design, waste management, and chemicals. She supports clients in navigating EU legislation to advance their sustainability goals.Get to know Ohana’s complete team of expert consultants.

As EU sustainability policy for textiles continues to take shape – from the high-impact Ecodesign for Sustainable Products Regulation (ESPR) to the recently published EU Bioeconomy Strategy– textiles have consistently been prioritised as a key sector in which sustainability policy is clearly warranted to achieve circularity. However, attention so far has largely focused on recycled content, recyclability, and waste reduction. 

Yet one important element of the transition is still not fully visible in EU policy frameworks: sustainably-sourced renewable materials (SSRM).

This is not because SSRM are marginal or contested. On the contrary, they are already widely used, researched and promoted by the textile industry and civil society actors. What is missing is not relevance, but explicit recognition and clear articulation in EU policy instruments to support them. This crucial dimension was brought into the discussion at the 2025 edition of the EU Green Week and across related policy discussions, highlighting the importance of placing circularity at the heart of Europe’s economic transition. This remains highly relevant given the theme of the 2026 edition, Investing in a Nature-Positive Economy, where the concept of SSRM remains clearly aligned with the EU’s sustainability objectives.

In this article, we take a closer look at what SSRM are, where they currently sit in the EU policy landscape, why they matter for sustainability and circularity goals, and how industry and civil society are already working to advance their recognition, even as policy frameworks continue to evolve. 

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What Are Sustainably-Sourced Renewable Materials, And Where Do They Stand In EU Policy?

At a high level, sustainably-sourced renewable materials are defined as those which are continually replenished at a rate equal to or greater than their rate of depletion, and which deliver reduced impacts and increased benefits for climate, nature, people, and animals. Examples include cotton, wool, or leather produced in regenerative, organic, or agroecological systems.

The concept of SSRM sits at the intersection of several EU objectives:

  • climate mitigation and adaptation
  • protection of biodiversity and soil health
  • resilient and diversified value chains
  • a functioning and credible circular economy

Despite this alignment, SSRMs remain largely implicit in key legislative and strategic files.

Under the ESPR and textile ecodesign work, policy discussions have tended to prioritise recyclability and recycled content. While essential, this focus risks overlooking the fact that recycled inputs alone cannot meet current or future material demand, given existing infrastructure and technological constraints. Moreover, Article 5 of the ESPR, read in conjunction with Annex I, explicitly foresees ecodesign requirements related to the “use of sustainable renewable materials”.

Similarly, the EU bioeconomy strategy and related initiatives refer broadly to renewable resources as ‘bio-based fibres’; however, this terminology lacks an established definition and often fails to specify sustainability criteria, sourcing conditions, or material-specific impacts. This can create confusion for companies and investors, and may mislead consumers as the claim ‘bio-based’ does not necessarily indicate any linked sustainability. 

What is striking is that, even though SSRM are compatible with EU sustainability objectives, they are largely absent from the way these objectives are currently operationalised in legislation. Neither the ongoing work on the Eco-design framework nor the recently adopted EU bioeconomy strategy explicitly recognises sustainably sourced renewable materials as a distinct category, nor do they provide clear criteria or incentives for their uptake.

This lack of visibility matters. Without clearer recognition, SSRM risk being overlooked in implementation, investment decisions and future standard-setting, despite their relevance for climate, biodiversity, circularity and resilient value chains.

At the same time, this absence should not be read as a closed door. Key policy files are still evolving, and there remains scope to better integrate SSRM through clearer definitions, evidence-based criteria and alignment with existing sustainability tools. Realising this potential will require continued engagement, collaboration and a shared effort to articulate why SSRM matter, and how they can be credibly embedded in EU legislation.

Why SSRM Matter: A More Complete Understanding Of Impact

Overlooking sustainable-sourced renewable materials can create imbalanced incentives that shift environmental pressures rather than reduce them, for instance by discouraging responsible cultivation practices or over-relying on certain inputs. 

In this context, traditional life-cycle assessment (LCA) remains a vital tool, but it does not always capture the full environmental and social implications of material choices across different systems.

As Beth Jensen, Chief Impact Officer at Textile Exchange, highlighted during Ohana’s EU Green Week partner event in 2025:

“Sustainably-sourced renewable materials are key to advancing a circular textile economy and show how EU policy, including SSRM as an information ecodesign requirement, can drive uptake across the value chain. While recycled content is essential, it cannot meet demand alone; with fibre production still significantly fossil-based and textile-to-textile recycled fibres below 1% of total global production volumes, recognising SSRM is essential to achieving true circularity while supporting sustainable production and livelihoods.”

This perspective underscores the need for policy frameworks that avoid rigid material lists, instead favouring criteria-based approaches supported by credible standards, traceability systems and assurance schemes, including tools such as the Digital Product Passport.

Industry is Moving, Even if Policy is Slower

Much of the current momentum on SSRM is being driven by industry and civil society organisations themselves, NGOs, industry and partners to advance recognition of SSRM in policy and practice.

Although SSRM are not yet clearly embedded in EU legislation, they are far from absent in practice.

At Ohana’s Green Week 2025 partner event on Advancing sustainable materials in EU textile ecodesign, industry representatives, NGOs and experts converged on a shared conclusion: a sustainable textile ecosystem requires both recycled and sustainably-sourced renewable materials.

Several themes emerged repeatedly:

  1. Supply constraints matter. Textile-to-textile recycling infrastructures, while essential, are not yet able to deliver sufficient volumes or quality to meet industry needs on its own. Sustainably-sourced renewable materials therefore play a complementary role in maintaining material availability and system resilience.
  2. Regulatory clarity is critical. Ben Pearson, Senior Manager Government Affairs EMEA at VF Corporation, emphasised that progress depends on multiple factors advancing together:

“The JRC Third Milestone Study recommendations on recycled content are encouraging, but it is equally important to establish a definition for sustainably-sourced renewable materials for inclusion in the ESPR textiles delegated act. Focusing too narrowly on recycled content may cause us to overlook significant opportunities to reduce the industry’s environmental footprint through the use of responsibly sourced natural materials.”

  1. Collaboration: Organisations are actively working to strengthen the evidence base, develop shared definitions and engage policymakers – even if much of this work happens outside public view due to advocacy and legal constraints.

Inspiration From Practice, Not Prescriptions

Taken together, these initiatives tell a clear story: SSRM are not a forgotten topic. They are being actively shaped by actors across the value chain, even as policy frameworks need to adapt to this rapid progress.

Rather than prescribing a single solution, these examples illustrate different ways organisations are engaging:

  • contributing data and research to inform policy development
  • participating in technical and multi-stakeholder dialogues
  • piloting traceability and verification systems
  • advocating for balanced frameworks that recognise material diversity

They also highlight an important reality of EU policymaking: change often happens incrementally, as evidence accumulates and concepts mature across multiple files.

For SSRM, this means that recognition is still possible, particularly as ecodesign requirements, EPR and eco-modulation rules continue to evolve.

The value of these examples lies not in providing a checklist or a single model to follow, but in demonstrating that the topic of SSRM is very much alive. A wide range of actors, from NGOs and brands, to multi-stakeholder initiatives, are already engaging with the challenge, often through technical work, coalition-building and evidence generation that remains largely invisible outside specialist circles. Understanding what others are doing can help organisations reflect on how they might engage, collaborate or contribute in ways that align with their own role and expertise.

Looking Ahead

Sustainably-sourced renewable materials are closely aligned with the EU’s long-term sustainability objectives, yet their role remains under-articulated in current policy frameworks. This is less a failure than a signal that the agenda is still taking shape.

What is often missing is visibility: many stakeholders are unaware of how much work is already underway, or where the remaining opportunities for engagement lie.

Bringing policy, practice and evidence closer together will be essential if SSRM are to be assessed fairly and integrated coherently into the EU’s textile sustainability framework.

At Ohana, we see our role as helping make these connections clearer – translating complex policy debates, amplifying grounded initiatives, and supporting constructive dialogue between institutions, industry and civil society – so that emerging concepts like SSRM can move from the margins into effective, workable policy solutions.

If you would like to explore how SSRM fit into your organisation’s policy, sustainability or advocacy priorities, get in touch with our experts at Ohana to continue the conversation.

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