Industry leaders collaborated on a white paper urging the UK government to make moves and implement variable extended producer responsibility (EPR) fees immediately to support sustainability and establish a circular economy in the region’s fashion industry.

Unveiled at the UK Fashion and Textile Association (UKFT)’s Sustainability Conference in London, the EPR Sandbox presents a “once-in-a-generation” opportunity to incentivize sustainability and secure funding for circular infrastructure, according to its creators.

Developed by QSA Partners—a B Corp focused on developing and implementing circular business models—with support from the British Fashion Council (BFC), the British Retail Consortium and the UKFT as well as several brands and retailers and co-funding from Innovate UK, the paper calls for immediate government intervention, which it says is pivotal to building a “viable” and equitable EPR textile scheme in the United Kingdom.  

“This white paper presents a compelling vision for variable EPR fees, with strong industry backing, thorough research and rigorous testing,” Kristina Bull, partner at QSA Partners and co-author of the paper, said. “Establishing a variable fee system is essential for the UK to fulfill 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.”

The project’s primary goals were to analyze existing, extensive producer data sets to enable circular eco-modulation and identify data gaps, per the paper. Data from over 500,000 types of garments—covering hundreds of millions of individual items—was dissected. Per the UKFT, the project analyzed “extensive producer data” to support this concept of penalizing producers for using decidedly-bad materials. The group said it achieved “accurate results” for over 85 percent of the data.

“An EPR fee scheme based on eco-modulation would level the playing field by rewarding positive action for those designing for end-of-life and penalizing those who don’t take their responsibility to the environment seriously,” said Adam Mansell, CEO of the UKFT. “It is the one issue around sustainability that everyone in the supply chain agrees on: legislation is needed to drive progress.”

With participation from Burberry, Marks & Spencer, New Look and John Smedley as well as a global sportswear brand and a leading online resale platform, the “ambitious initiative” set out to demonstrate how an individualized, intelligent fee could be applied to clothing in the UK market.

“John Smedley is a manufacturer, M&S and New Look are high-street, Burberry covers luxury and then the sportswear brand, we were keen to get them on-board because of their product fiber mix,” Bull told Sourcing Journal, noting the resale player explored how EPR would impact the secondhand space. “We were quite intentional with the brand mix that we had.”

The project identified four key findings: data integration, variable fee models, circularity incentives and market impact.

“The fashion industry thrives on creativity and passion for change, so it’s only natural that the BFC was a key partner in the creation of the Fashion Sandbox. We fully support this work; our industry needs strong support from the government,” said Caroline Rush, chief executive of the British Fashion Council. “As we face some of the most challenging market conditions in recent memory, we recognize our responsibility in driving a sustainable future, but the journey requires collective effort—we cannot do it alone.”

Brands typically hold product and sales data in separate systems which complicates the connection of these data sets. The project, therefore, developed methods to match product identity, sales and weight data to enable accurate analysis.

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 incentivizes accurate reporting and greener product design.

“The EPR Sandbox project has enabled a steering committee from various sectors within the textile industry to create a process for EPR that is fair to all involved,” Tim Clark, technical director at John Smedley, said. “Everyone needs to become aware of the EPR process and help us shape the future for product end-of-life and beyond.”

The third finding proposed a central fund to promote repair, reuse and recycling, as consultation from the participating brands confirmed that this approach could offer financial benefits to producers engaging in these activities.

“In 2008, we were the first UK retailer to launch a clothes recycling scheme, and this year we launched a clothing repair service,” Katharine Beacham, head of sustainability in clothing and home at Marks & Spencer, said. “We are proud to be a part of the Fashion Extended Producer Responsibility Sandbox project and support steps to scaling textile recycling in the UK but want to work with government so that it drives tangible change. A successful EPR scheme must incentivize good business, encourage circular design and invest in UK recycling infrastructure if we are to achieve positive change.”

Data modeling showed that scaling up the variable fees to the UK market could generate substantial funding for circular activities and reduce provider costs when they adopt circular design principles.

“At Burberry, we are working to support a more circular economy through our aftercare services and circular business models; these services help our customers keep their luxury products in use for longer,” said Sumit Dargad, vice president of quality and engineering, supply chain, at Burberry. “By contributing to this industry-led EPR Sandbox project, our aim is to positively influence the future of the fashion industry in adopting more circular practices.”

Based on these findings—and in an attempt to expand on the initial project’s success—a new, independent company was established to manage the sandbox system and conduct further data analysis. Dubbed WEFT, the entity exists to improve data robustness, develop open standard formats for data input and explore the application of this approach to other markets—including the European Union and the United States.

“While our point-of-proof is in the UK, that’s absolutely not to say that it is only for the UK,” Bull said. “We want this to be the global variable EPR system that anybody can put into, and you can say what your obligation is anywhere in the world.”

WEFT serves as an independent mechanism for developing fee structures and tests those structures out with the guidance and input of the industry, government and other relevant stakeholders. To become a globally practicable system, the flexibility of the startup’s model doesn’t fix all nations into the same scoring method; different countries can emphasize attributes relevant to their region.

“A successful textiles EPR scheme will deliver a more sustainable fashion industry in the UK, encouraging green growth through the onshoring of textile recycling, and will help the UK to meet its climate goals,” Helen Dickinson, chief executive of the British Retail Consortium, said. “The Sandbox is a crucial piece of research into the practical implementation of UK textiles EPR scheme fees, and we urge [the] government to consider the findings.”