Published name
1. Do you currently participate in traceability?
1a) What traceability model do you use?
1b) How else do you participate in traceability?
Offer RFiD THREADS® is the world's first smart washable radio frequency digital ID that stays with the product. Circlolink is a Digital Product Passport housed in a single thread connecting to CIRCAA cloud platform. Bulk scans 1000s instantly to add and collect data along the products lifecycle.
2. Do you support the framework adopting a technology-agnostic approach?
2a) Please explain
Use of smart tech and Digital ID will have enormous impact and change the way brands sell products and how customers buy, own and interact with them.
3. Do you support the framework adopting an outcomes-focused approach?
3a) Please explain
Adetex CS have designed CirCloLink and CIRCAA Cloud platform to capture data along the entire product’s lifecycle to offer metrics including LCA, EPR and waste diversion.
4. Should the framework include requirements to share data with government to support reporting, for example progress reporting against national recycling targets?
4a) Please explain
Government needs to monitor change and reporting for payments related to performance and Product Stewardship Schemes.
5. What requirements could be included in the framework to help industry and governments report against targets? For example, what type of traceability information could support reporting?
We offer traceability from fibre to feedstock to ensure bulk scanning of products to meet targets and cases like forever chemicals like on uniforms are kept out of fibre to fibre recycling.
6. If reporting were to be included in the framework, what conditions should be attached?
7. Would you adopt a voluntary framework?
7b) Please explain why
Should be mandatory and legislated eg use of Digital Product Passport (DPP) for the U.S. Digital Care Label and the EU’s Strategy for Sustainable and Circular Textiles.
8. What timeframe would be required for you to implement traceability in your own business?
9. Do you support recycled content traceability being initially voluntary?
9b) Please explain
Transparency is key to encourage customers and show free riders the benefits to compliance.
10. Should recycled content traceability become mandatory for everyone over time?
10b) Please explain
Some products will require virgin materials eg for compliance, safety. But where possible, and most cases yes traceability should be mandatory
11. Should recycled content traceability be mandatory only in specific circumstances or sectors?
11a) In which circumstances or sectors should recycled content traceability be mandatory?
As above
12. Do you support governments requiring consistency or alignment with the framework as a requirement for future initiatives, for example grant funding?
13. Is the proposed objective appropriate for a voluntary approach?
13a) In what way is the proposed objective not appropriate?
Voluntary solutions do not work eg mattress sector for Product Stewardship, Seamless that will never succeed if voluntary
13b) What else should be considered?
Use of RFID Threads to see real-time data.
14. If the proposed framework were mandatory or to become mandatory, would the proposed framework objective still be appropriate?
15. Is the proposed framework sufficient to support collection and sharing of accurate and harmonised recycled content information?
15a) What would you like to see from governments to support this?
Use of a tool as the RFID Thread so minimise errors and free riders.
16. Do you use traceability systems for other parts of your business? For example to trace food or agricultural products.
17. Is it appropriate for traceability to begin at the material recovery step in the supply chain?
17a) Please tell us why not
The RGID Thread is used for new and recovered products. It’s to communicate fibre, chemical composition, materials etc to them recyclers so they have efficient bulk sorting to create safe feedstocks
17b) At which step in the supply chain should recycled content traceability begin?
18. Does the defined scope of recycled material and recycled content cover all types of recycled materials that should be traced?
18a) What other recycled materials should be in the scope?
Use of forever chemicals, dyestuffs, plastics, carcinogenic and endocrine disrupters.
19. Are the supply chain steps shown in Figure 2 and described in Table 1 of the discussion paper sufficient to capture all types of recycled content supply chains (for example, glass, paper, plastics, metals and construction materials)?
19a) What additional steps or descriptions should be included?
Textiles
20. Should imported recycled materials be within scope of the framework once they enter Australia?
20a) Should the framework requirements apply in the same way to imported materials? Please explain
Yes definitely. We need material traceability for safety on chemical compliance.
21. Is the GS1 Global Traceability Standard an appropriate basis for guiding interoperability in recycled content supply chains?
22. What other approaches or guidance should be considered for guiding implementation of interoperability in recycled content supply chains?
Bulk purchase by government of RFID Threads reduces price tonUSD .11 cents per thread to engage many interconnected industries including clothing, footwear, homewares, mattresses and tyres.
23. Would you require further guidance from Australian governments to ensure interoperability of recycled content traceability systems is achieved?
23a) What additional guidance from governments is required?
Now is the time for governments to have a major role in supporting all brands to easily afford Digital Product Passports (DPP) for product Stewardship compliance.
This is a chance to use a smart tool that goes beyond traceability and connects products to circularity.
This small single RFID Thread is an affordable solution for all designers; from students, SMEs to multinationals to help them increase their ROI and bulk scan returns to resell, rent, repair, redesign.
It also links them to the resource recovery sector. They can efficiently bulk scan to sort and ensure safe feedstocks; removing say, uniforms with forever chemicals so they’re not recycled.
Each RFID Thread has a unique QR code to help brands sell products and communicate and interact with consumers.
Brands also receive unprecedented real-time data when its scanned as it moves through its lifecycle offering metrics on longevity, LCA and EPR offering transparent provenance and “waste” diversion data for governments.
Contact Alison Jose regarding
Circlolink. Digital Products Passport via RFiD THREADS®
24. Could your business currently achieve one-up, one-down traceability?
25. Is it appropriate to start with ‘one-up-one-down’ traceability?
26. Would 4 years be enough time for industry to adapt to full traceability?
27. Would 4 years be sufficient if the framework were mandatory?
28. Would the key data elements provide enough information and assurance about recycled content to encourage its use over virgin materials?
29. Is the ISO definition for recycled content (ISO 14021:2016) appropriate to define the data point that is captured once recycled material is used to create a new product?
29a) What other definitions should be considered?
It should include original source data, chemical additives,
30. Is the information proposed to be shared across the supply chain (Table 2) commercially sensitive? If so, please identify each specific data element and explain why it would be commercially sensitive.
No. Requires full transparency.
31. Should the key data elements described in table 4 of the discussion paper also be required for imported recycled materials?
31a) Please explain
It’s essential to have accurate materials and chemicals to ensure safe feedstocks and Standards compliance eg WELL Standard
32. If you use a traceability system for a reason other than tracing recycled content (such as modern slavery reporting), could it be expanded to include the data elements in Table 4 of the discussion paper?
33. Is the guidance on key data elements sufficient to support accurate and harmonised recycled content information?
34. Do you use recycled content in your business?
34a) What information do you most want to know about the recycled content you use?
35. Are you an end-user of recycled-content goods?
35a) What information do you most want to know about those goods?
36. Are you an Australian business that uses recycled materials?
36a) How do you determine the recycled content in products made with those materials?
GRS Standard
37. Are the four proposed chain of custody approaches appropriate to determine the recycled content in goods?
37a) Please tell us why the proposed approaches are not appropriate and what approaches would you suggest?
The RFID thread will capture data like blockchain but without the continuous expenses.
38. What other approaches could be considered to determine the recycled content of goods?
Increases B2B collaboration. Bulk scanning creates efficient new ROI circular economy business models to link brands with the resource recovery sector.
The smart thread retains and collects data along its lifecycle offering brands an increased ROI through returns, resale, rent, repair before going on to recycle, remanufacture and regenerate to repurpose.
RFiD THREADS® connects products to the CIRCAA cloud platform for new and recovered products; garments, footwear, mattresses, tyres etc.
B2C CONNECTIVITY
Provides real-time product data to fast track efficient 'waste' flows, provide metrics for change, minimise emissions and pollution and support supply chains from farmers to feedstock.
A unique QR Code for B2C for engagement and education. Connects Product Stewardship Schemes to holistic circular solutions and rewards eco-leadership during the transition to circularity.
39. Should the framework define the mass balance accounting period, allocation of attributes, credit units and other mass balance requirements?
39a) What should be the minimum requirements?
Verifiable and published Certification
40. Could the framework help to harmonise existing chain of custody certification schemes?
40a) What would harmonisation look like?
B2B bulk commercial scanning for efficient SCM, returns and authentication. Increases brands ROI for resale, repair, rent plus textile waste sorting, recycling and landfill diversion.
B2B bulk commercial scanning to connect various industries along a lifecycle.
Facilitates efficient returns and authentication, increased ROI for resell, repair, rent plus 'waste' sorting, valorisation, safe feedstocks for fibre to fibre manufacturing and landfill diversion.
41. Is it sufficient to trace the origin of domestic recycled content to the jurisdiction of origin?
41a) Please tell us why it is not practical and what level of origin should be traced?
Can be traced from fibre or original source.
42. Is it sufficient to trace imported recycled content back to the country of origin?
43. What challenges might be involved in tracing imported recycled content further than the country of origin? (for example, city of origin)
Supporting the country to purchase RFID threads at same equitable price by bulk manufacturing order. This engages the brands with their manufacturing better as well.
44. How else could the origin of imported recycled content be traced?
B2B digital ID used to trace, verify, link to your SCM to track inventory, retail & returns, resell, rent, repair, reuse, redesign, remake, recycle, remanufacture and regenerate to repurpose. Collect unprecedented data from fibre to a circular economy.
RFiD THREADS® has the potential to transform the way we produce, consume and dispose of clothing, textiles and textile based products by engaging and empowering a collaborative network of resource recovery providers.
Integrate a smart tech circular tool to connect to material streams for textiles, clothing and products. Brands link their products to their supply chain management system for returns then engage customers for resale, rent, repair, redesign, remake, reuse then recycle for safe secondary market feedstocks.
Slip RFiD THREADS® into both new and quality recovered garments and products. UHF readers scan hundreds at a time to create efficient supply chain management systems for brands, manufacturers and a circular resource recovery industry.
Brands and manufacturers implement circular design strategies, provide jobs, increase financial sustainability and receive unprecedented data and metrics for change.
45. Are you an Australian business involved in processing or using recycled materials?
45a) How do you determine the quality of materials you use and supply?
Certification
46. Does the proposed definition of ‘chemicals of concern’ include or exclude substances it shouldn’t?
47. Does the proposed guidance contradict or duplicate existing practices, such as industry guidance, state, territory or international requirements?
48. Are the standards identified in Table 8 of the discussion paper sufficient to guide implementation of recycled content traceability?
48b) Please explain
49. Which of these standards do you use in your business?
50. How could we align the proposed framework with the standards to provide helpful guidance?
Create a separate Circularity Standard with publishable ratings. That’s also separate from Modern Slavery and Living Wage.
51. Should any other international traceability requirements or standards be considered under the proposed framework?
51a) Which international traceability requirements or standards should be considered?
U.S. Digital Care Label and the EU’s Strategy for Sustainable and Circular Textiles.
52. Do you currently verify domestic recycled content information you receive through the supply chain?
53. Do you currently verify imported recycled content information you receive through the supply chain?
53a) How do you verify this information?
GRS Certification
54. Is it sufficient for verifiers to meet the ISO standard relating to verification bodies (ISO/IEC 17029:2019)?
55. What other approaches could be used to provide assurance of the recycled content information?
Use of CirCloLink and CIRCAA cloud platform
56. What additional stakeholder responsibilities should be considered?
RFiD THREADS® allows retailers, manufacturers, infrastructure, machinery and the resource recovery industry to collectively transition to a holistic aggregation system.
It captures data at every step, enriching information systems and unlocking the key for predictive marketing, automated resource recovery sorting, collaborative responsibility, impact measurement including climate emissions reduction plus connects SDGs and an Extended Producer Responsibility scheme (EPR).
57. What opportunities are available or could be considered to encourage stakeholders along the recycled content supply chain to use the proposed framework?
Reward brands for longevity & circular design strategies
Link fashion and products via an interconnected resource recovery network.
RFiD THREADS® will increase a brands ROI, mitigate emissions and pollution, promote regenerative biodiversity and link the value chain.
58. Would any additional stakeholders have a role in implementing the framework?
58a) Please provide details
Adetex CS to work with government
59. Would the proposed guiding principles provide sufficient guidance to support implementation of the proposed framework?
59a) What other principles should be considered?
Each RFID thread produces a unique barcode and QR code for B2C communication to show circularity, transparency and brands 'eco' status.
Collects & adds garment data along the lifecycle however is not like NFC that connects to customer's personal data.
60. Do you think the benefits of traceability outweigh the costs of implementation for your business?
61. What additional guidance would you require from governments to support your implementation of the framework?
BULK 100+m order
To achieve national and international inclusive, equitable and financially sustainable collaborative solutions we propose for a consortium to underwrite the cost of a bulk production of 100+million threads and roll-out over 2 years.
100% of the cost is return through thread sales plus an acknowledgement of the "sponsor" by each brand on each product’s swing tag and marketing.
We envisage a consortium of government, industry and philanthropists to facilitate a bulk manufacturing order to enable a mass roll-out, allow us to offer the threads at the same equitable cost to all designers; from students through to multi-national brands.
A government order may enable a crossover of many industries' Product Stewardship Schemes to include fashion, uniforms, homewares, footwear, mattresses, accessories, etc.
62. Are the proposed indicators of performance sufficient to measure the success of the framework?
62a) What other indicators should be considered?
Collection of real-time data including mitigation and sequestration
63. How could the Commonwealth collect data to monitor and evaluate the proposed framework?
Yes by using Adetex CS solution and development of CIRCAA cloud platform
64. Would 3 years of implementing the framework provide sufficient information to support the first review?
65. Do you anticipate any changes to the operating or business environment that might have a substantial impact on implementation and review of the framework?
65a) Please explain.
Minister Plibersek to condem the inaction of the mattress, clothing and tyre product stewardship schemes and make them mandatory however brands will be unable to comply and will send businesses out of business.
