Future Earth Lab and the United Nations Environment Programme (UNEP) invited LHCA to take part in their consultation on Evaluation of Pathways of the Textile Value Chain towards Sustainability and Circularity.
We responded to the invitation with a willingness to join if we were assured that the consultation would include discussion of fiber neutrality. After careful consideration of the invitation and in the absence of such assurances, we would like to outline our concerns about how this consultation is framed and explain why our participation would not be productive. This is not a letter about market protection. It is a letter about the integrity of a policy framework.
A Question of Scope — and a Deeper Question of Framing
The first and most straightforward point is that leather is not a textile. LHCA represents an industry that processes hides, byproducts of the meat and dairy industries. The hide comes to us because an animal was raised for food. With an estimated 40% of hides going to landfill, a failure our industry is actively working to address, no additional land, water or carbon cost attaches to its existence as a raw material. It is, by definition, a use of something that would otherwise be waste, making it one of the oldest examples of genuine circular material use in human history. An animal is raised for food, and it is our job to ensure nothing is wasted. The hide becomes leather that lasts decades, ages beautifully and at end of life returns to biological cycles. We are, in the truest sense, a circular industry.
But there is a more fundamental reason for our reluctance.
The Problem with Fiber-Neutral Circularity
We are aware of the UNEP textile sustainability roadmap. We have followed its development with interest and respect the intentions behind it. But we have significant reservations about the concept it is built on.
The roadmap uses "circularity" as its unifying framework but treats circularity as fiber-neutral. That is, it does not distinguish in any meaningful policy sense between materials that are circular by nature and materials that are circular only as an ambition.
This distinction matters enormously.
Biogenic circularity, the kind embodied by natural fibers, leather and other materials derived from living systems, is circular in an ecological sense. These materials are part of living carbon cycles. They biodegrade. Even the microfibers they shed during use return to the soil as nutrients. The loop closes naturally, without requiring industrial infrastructure to do so.
Technogenic circularity, the kind claimed by synthetic, petroleum-derived fibers such as polyester and nylon, is categorically different. The carbon locked into these materials was sequestered underground for millions of years. It was never part of the contemporary carbon cycle and it cannot safely re-enter it. The "circular" loop for synthetics closes only through energy-intensive industrial processes that degrade the material with each application. And critically, throughout their useful life, synthetic fibers shed microplastics that do not biodegrade.
Microplastics accumulate in soils, waterways and living organisms, including people. Synthetic microplastics have been detected in human blood, placentas, lung tissue and breast milk. The circularity question for these materials is not merely environmental, it is a public health question that a framework focused on recycling infrastructure is not designed to address.
Recent data suggests that only around 9% of plastic is currently recycled, and less than 2% of the 9.2 billion tons of plastic produced since the mid-twentieth century has been recycled more than once. An estimated 60% is in landfill or scattered throughout the environment. In the textile-specific world the data is even starker: currently less than one percent of polyester fiber is recycled into new textile fiber. The circular future the framework anticipates for synthetic materials does not yet exist and has no confirmed pathway to scale.
The circularity claim for synthetic textiles is aspirational rather than operational. Yet the UNEP framework equates a future in which polyester is recycled routinely with a future built around naturally circular materials. We find this difficult to accept. Not because the people involved are acting in bad faith, but because we believe the framework itself leads them to a conclusion that the evidence does not support.
A Framework That Cannot Ask the Right Question
Our deeper concern is structural. By defining circularity as fiber-neutral, the UNEP framework creates a policy pathway in which the broader question (should biogenic materials be preferred over technogenic ones on circularity grounds?) is simply not asked. The framework asks how synthetics can be recycled more effectively. It does not ask whether continued high-volume production of fossil-based textiles is compatible with genuine circularity at all.
This shapes what the consultation will conclude. A reviewer participating in good faith is being asked to work within a set of assumptions that, in our view, needs to be examined before the analysis begins. We do not think our engagement would change those assumptions. In fact, we think it would lend credibility to conclusions we are not in a position to endorse.
We do not believe Future Earth Lab or UNEP approach this work cynically. But we have observed that the people shaping this consultation come predominantly from an institutional tradition, brand-facing sustainability consultancy, compliance policy and industry coalitions, in which synthetic fiber is treated as a permanent feature of the landscape to be managed more responsibly, not a material category whose fitness for purpose needs to be questioned. That perspective produces genuinely valuable work on supply chain transparency, decarbonisation and recycling infrastructure.
This perspective is less well-equipped to ask whether the materials themselves are compatible with genuine circularity. We think this is a structural limitation of the framework, not a reflection of individual intent. The people involved have long careers in sustainability and genuine commitments to improving industry practice. A well-intentioned process built on the wrong question, however, will produce the wrong answer.
What We Would Welcome
LHCA remains open to dialogue. We would welcome conversations about how genuine circularity, the kind that does not depend on industrial recycling infrastructure that does not yet exist at scale, can be recognised and rewarded. We would welcome engagement on how leather, as a byproduct material with millennia of circular use behind it, fits into a more nuanced sustainability framework. And we would welcome any future consultation process that begins by asking which materials are inherently circular, rather than assuming that all materials can be made circular with sufficient investment.
Until that conversation is possible, we must respectfully decline.