EPR Is Not a Cost Centre: It's the Early-Stage Commercial Restructuring of the Fashion Industry

Policy rarely transforms an industry immediately. It first establishes rules and responsibilities. Businesses then develop the systems, relationships and capabilities required to respond. Infrastructure emerges, data becomes available, incentives are refined and commercial strategies begin to adapt. This is the stage fashion is entering now.

The market infrastructure for textile EPR is still developing. Data systems are incomplete. Reuse, resale, repair, collection, sorting and recycling networks vary across jurisdictions. Responsibilities are spread across brands, retailers, consumers, charities, traders, repairers, recyclers, producer-responsibility organisations and waste operators. Read the Commission's recommendations on EPR scheme design.

The fact that the system is incomplete does not mean EPR is only compliance. It means the commercial restructuring is underway.

The EU Waste Framework Directive establishes the wider framework for waste prevention and management, including the waste hierarchy and the polluter-pays principle. Article 4 of Directive 2008/98/EC prioritises prevention and preparation for reuse before recycling, recovery and disposal. See the EU waste hierarchy explained.

Businesses are therefore being required to account for parts of the product lifecycle that were previously outside their core commercial model. They are beginning to ask what happens after the first user, where products retain value and why some garments become waste earlier than necessary.

This is where our Chain of Custody programme becomes commercially important. The programme creates the structure needed to follow a product, its materials and its supporting evidence through relevant stages of the value chain. It helps connect what the business says about a product with what can be demonstrated about that product in practice.

Without this connection, evidence remains fragmented. Material information may sit with suppliers. Durability testing may sit with product teams. EPR data may sit with compliance functions. Resale information may sit with traders or external platforms.

Our Chain of Custody programme brings these strands together into a usable evidence file. It is not simply a document-management exercise. It is an information system for understanding the commercial life of a product.

ESPR operates primarily upstream by focusing attention on the product itself. The Regulation provides a framework for ecodesign requirements relating to durability, reliability, reusability, repairability, upgradability, recyclability, resource efficiency and product information. Intertek's ESPR overview and the International Energy Agency's record of the EU Ecodesign Regulation summarise the framework.

It also requires relevant digital product-passport data to be accurate, complete and up to date. This reinforces the importance of maintaining reliable product information throughout the value chain. For fashion businesses, this creates a need for evidence behind product claims.

A company may state that a garment is durable, repairable or made from a particular composition. Those claims may be supported by technical specifications, supplier declarations, laboratory testing and design documentation. But a product claim is not the same as evidence of real-life performance.

A garment can be designed to last without retaining structural integrity through repeated use. It can be made from a specified material but perform poorly under actual washing, wearing, climatic or maintenance conditions. It can be technically repairable but too expensive to repair. It can survive physically while losing its desirability and resale value.

Our Chain of Custody programme helps build an ESPR evidence file that focuses on real-life structural integrity retention alongside the evidence supporting material-composition claims. That may include information about whether seams remain secure, fastenings continue to function, fabric retains strength, shape is maintained and the garment remains suitable for continued use or another owner. The purpose is not to claim that one observation proves universal durability. It is to create traceable, structured evidence that allows durability claims to be tested, supported and improved.

Material composition is not merely a label claim. It can influence durability, repairability, recyclability, sorting, resale value and end-of-life treatment. ESPR identifies material composition, material homogeneity and the use of coding standards for components and materials as relevant to designing products for recycling and improving access to product information.

This matters because material information can become disconnected from a product as it moves through production, distribution, resale, repair, export and waste-management systems. If the material identity is lost, later actors may struggle to determine how the product should be repaired, reused, sorted or processed.

The evidence file should therefore support: the identity of the product; the declared fibre and material composition; the source and status of supporting documentation; the relationship between material composition and product performance; and the availability of information to relevant downstream actors. This creates a stronger foundation for both ESPR product-information requirements and EPR lifecycle management.

EPR asks what happens after the product enters the market. Does it reach a second user? Can it be repaired? Does it retain value? Does it enter a resale pathway? What condition does it reach the second-hand market in? Why does it leave circulation?

The second-hand market is therefore not simply an optional marketing channel. It is an evidence layer. The trader knows which garments sell. The reseller knows which brands retain value. The repairer knows which products fail. The warehouse operator knows what arrives in usable condition. The buyer reveals what they are willing to purchase and at what price. The European Environmental Bureau's report on driving a circular economy for textiles through EPR makes the case for connecting resale data to producer responsibility.

Our Chain of Custody programme helps organise this market intelligence and connect it to product identity, material composition and original durability claims. This allows a business to compare what the product was designed to do with what happened to the product in real life. That comparison is commercially valuable.

Our Chain of Custody evidence file can help connect the different information required to support an EPR and eco-modulation strategy. It may include:

• Product identity and classification.
• Material composition and supporting documentation.
• Supplier and production information.
• Construction and durability characteristics.
• Product placement on the market.
• Real-life structural integrity.
• Condition after use.
• Repair requirements.
• Resale-market presence.
• Second-user demand.
• Resale price and value retention.
• Reuse outcomes.
• Failure modes and disposal pathways.

The EU's revised waste rules provide an important policy direction for textiles. The relevant EUR-Lex text requires producer-responsibility systems for textiles to support longer product lifetimes and the reuse of used textile products assessed as fit for reuse. It also links fee modulation to relevant ecodesign criteria and measurement methodologies. Read the HTML version of Directive (EU) 2025/1892.

Depending on the applicable jurisdiction and producer-responsibility scheme, a stronger evidence base may support an eco-modulation strategy and potential fee reductions. The specific criteria and eligibility requirements will vary, so evidence must be aligned with the relevant rules. The Ecologic Institute's analysis of EPR and eco-modulation of fees and the Commission's impact assessment on textile EPR and eco-modulation set out the variables.

The Chain of Custody programme does not guarantee a fee reduction. Its purpose is to help businesses build the traceable evidence required to assess eligibility, support claims and make better commercial decisions.

A business may discover that one product category retains value while another loses it immediately after first use. It may find that a particular seam, fastening or fabric construction repeatedly causes garments to leave circulation. It may identify markets where products are in demand but lack reliable resale or repair pathways.

These findings can influence: product development; material selection; quality standards; product volumes; repair services; resale partnerships; inventory decisions; market entry; waste-prevention strategy; and capital allocation.

That is the commercial restructuring EPR is beginning to create. The model is shifting:

The Chain of Custody programme sits at the centre of this shift. It helps preserve the connection between the product, the evidence behind its claims and the outcomes observed after sale.

EPR should not simply make fashion better at paying for waste. It should make fashion better at understanding why products lose value and how that value can be retained. ESPR strengthens the evidence behind material, durability and design claims. EPR increases responsibility for what happens after products are placed on the market. Eco-modulation introduces potential financial differentiation based on relevant environmental performance. The Chain of Custody programme connects these developments through traceable commercial evidence.

Our programme is designed to help you:

• Build a structured EPR and eco-modulation evidence file.
• Support material-composition and durability claims.
• Assess real-life structural integrity retention.
• Understand resale, repair and reuse outcomes.
• Identify how commercially durable your products really are.
• Use market intelligence to inform product and investment decisions.
• Develop a business strategy that reduces avoidable textile waste.

This is not CSR. It is not merely compliance. It is commercial restructuring in its early stages — and the Chain of Custody programme provides the evidence infrastructure needed to turn that restructuring into real commercial results.