Earlier this year, we published an article about a ground-breaking, industry-led EPR Sandbox project to develop a model for Extended Producer Responsibility (EPR) for the fashion industry. The project aimed to demonstrate how individualised, intelligent fees for contributing to the cost of collecting and recycling textiles could be calculated and applied to clothing in the UK.
When the first phase of the project concluded in April 2024, it not only proved it’s possible to analyse and compare vast and extensive data sets from multiple brands in a consistent way. It has also shown an intelligent EPR fee based on eco-modulation is viable and could revolutionise fashion sustainability.
Here we provide an overview of the project, a summary of the key findings and what's next, including the opportunity for more brands and retailers to get involved in developing an EPR system that works with, and for, the industry.
Extended Producer Responsibility in a Nutshell
EPR regulations make companies responsible for the full costs of managing the waste of the products they put on the market, including at the post-consumer stage.
Many governments favour EPR as part of a wider approach towards more circular economies and are extending the scope of these regulations. Whilst there are already almost 400 EPR schemes in place globally covering a range of product types (source: Ellen Macarthur Foundation), EPR for clothing and textiles currently only exists in a few countries. That is set to change as governments have their sights firmly set on this sector.
EPR schemes are notoriously challenging to get right. Typically, they are based on collective producer responsibility with costs applied proportionate to market size, and often passed onto the consumer! In addition, revenue generated by the schemes is not invested back into the industry. And they can be administratively complex and time-consuming. One company seeking to change this is QSA Partners.
About the EPR Sandbox Project (Phase 1)
QSA Partners supports businesses to implement circular economy business models which are better for customers and commercial performance, and better for the planet. It’s on a mission to drive systemic change in circularity and the EPR Sandbox Project is its brainchild.
Led by QSA Partners with the help of UK Fashion & Textiles Association (UKFT), British Fashion Council (BFC) and British Retail Consortium (BRC) and support from Innovate UK’s National Interdisciplinary Circular Economy Research programme (NICER), the project has brought together major industry trade organisations, brands, retailers and academic experts to address key data challenges and explore the impact of circular eco-modulation.
The project’s primary goals were to identify how vast data sets from multiple brands could be analysed and compared in a consistent way and demonstrate how an individualised, intelligent fee could be applied to clothing in the UK market.
Participants in the first phase included global luxury brand Burberry, Marks & Spencer, New Look, John Smedley, a global sportswear brand and a leading online resale platform.
As the project’s data partner, Datitude built the data model; enabling large volumes of market data (product, sales and weight) from multiple brands to be integrated, transformed and analysed in a data sandbox environment. This included testing different fee structures, including per item, per kilogram, and fees based on circular attributes, encouraging sustainable design.
Data from over 500,000 garment types, spanning over 250 million products, were processed and analysed, focusing on circular attributes including:
Composition - composition factors such as recycled content, design for recycling (mono-material and suited to common fibre-to-fibre recycling processes), and natural fibre content
Repair - number of garment repairs
Reuse - the number of items resold after first use (excluding returned new items).
Key Findings of the EPR Sandbox Project
The EPR Sandbox Project has shown that variable fee scoring can be achieved, and then could be used to drive improvements in circularity in the textiles and fashion industry. In summary, the key findings are:
i) Data Challenges and Solutions
Brands typically hold product and sales data in separate systems, complicating the connection of these data sets. The project developed methods to match product identity, sales and weight data, enabling accurate analysis.
ii) Variable Fee System
Different fee models were tested, including per-item, per-kilogram, and varied per-garment fees based on circular attributes. The project found that a fee system rewarding the reporting of individual item weights and circular attributes incentivises accurate reporting and better product design.
iii) Circularity Incentives
The proposal of a central fund to incentivise circular activities, such as repair, reuse, and recycling, with the potential for producers to benefit from payments for participating in these activities. From consultation with the participating brands, it is clear this approach to analysis has value in understanding the potential future options for EPR fees, understanding the circularity of their existing products on sale and how they can be improved through better design.
iv) Industry Impact
Data modelling showed that scaling up the variable fees to the UK market could yield significant funding for circular activities, with potential savings on producer obligations if, or when, they adopt circular design principles.
The full details of the EPR Sandbox Project can be found in the EPR Variable Fee White Paper, authored and researched by QSA Partners. Published in September, it calls on the UK Government to create an industry-led variable EPR textile scheme that works for all.
"This White Paper presents a compelling vision for variable EPR fees, with strong industry backing, thorough research, and rigorous testing. Establishing a variable fee system is essential for the UK to fulfil its responsibility in managing the end-of-life impact of fashion and textile products. We must not turn a blind eye; we call on the Government to consider the evidence, listen to industry voices, and endorse this White Paper." Kristina Bull, WEFT
What’s Next for the EPR Sandbox Project?
This ground-breaking initiative represents a significant step towards achieving a more sustainable, circular economy for the UK textiles and fashion industry. But the work has only just begun, and there’s a call for more brands to get involved.
The next phase involves scaling up the approach, engaging more brands, and refining the system to support a balanced and fair EPR framework.
It paves the way to develop an EPR system that works with, and for, industry - to reward positive circular behaviours and penalise activities that are detrimental to the planet. It also has the potential to drive radical improvement in sustainability impacts and harmonise reporting across many nations into a single simple reporting system – with the system providing each nation with a bespoke set of incentivised fees in line with its preferred policy objectives.
To expand on the success of the initial project, a new independent company WEFT has been created by QSA Partners to manage the sandbox system. WEFT will focus on improving data robustness, developing open standard formats for data input, and exploring the application of this approach to other markets, including the EU and USA.
To find out more or get involved, email Kristina Bull or Gerrard Fisher at WEFT: hello@weft.org.uk.
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