QSA Partners have developed a new initiative that urges the Government to introduce variable Extended Producer Responsibility (EPR) fees without delay. This approach aims to address the complexity of the fashion industry more effectively than a one-size-fits-all system, offering a calibrated approach to incentivise sustainable practices.

Supported by the UK Fashion and Textile Association (UKFT), British Fashion Council (BFC), the British Retail Consortium and several luxury, fashion and retail brands, the white paper outlines how a fee could be implemented to drive sustainability practices within the UK fashion and textiles industry. By tailoring fees to specific product attributes, the system can encourage innovation in design and materials, potentially transforming the industry’s approach to sustainability.

Helen Dickinson, Chief Executive at the British Retail Consortium, commented: “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. 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.”

The EPR Sandbox Project

The white paper outlines the EPR Sandbox Project, which demonstrates how a variable fee structure could be applied to clothing within the UK market. This approach allows for a more equitable distribution of responsibility based on actual environmental impact, rewarding companies that invest in sustainable practices.

The project analyses raw sales and product data from six brands of varying size over a 12-month period. Brands involved included: Burberry, John Smedley, M&S, New Look, a global sportswear brand, and a global fashion resale platform.

The study tested different speculative fee structures, including per-item, per-kilogram, and fees based on circular attributes. It also modelled scenarios where organisations could receive income from taking circular actions, such as being paid a cash value for each garment they repair or resell. This flexibility can adapt to new materials and technologies, ensuring that innovative, more sustainable products are fairly assessed.

Data from over 500,000 different garment types, representing hundreds of millions of individual items, was examined, with more than 85 per cent of the data producing reliable results.

The Sandbox Project found that variable fees could be viably applied to complex fashion markets, with participating brands finding the fees simple to integrate into their existing systems.

The proposal suggests that a central fund to promote repair, reuse and recycling could offer financial benefits to producers. The fees collected would also generate funding for circular activities and reduce costs for producers who adopt sustainable practices.

WEFT

In response to the study, QSA Partners have established a new company, WEFT, to continue researching and testing fee structures with guidance from industry, government and other stakeholders.

WEFT intends to delve deeper into the existing data sets, gather new data from a wider range of brands and producers, develop and refine the metrics for scoring products, and create outputs to enable discussions about how a variable fee could be implemented into the UK markets.

Kristina Bull at WEFT commented: “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 approach.”

Sustainability issues in the fashion industry

The release of the initiative calls for the government to introduce an EPR scheme for fashion and textiles immediately. The proposed fees would ensure that producers bear the cost of their products’ end-of-life treatment, rather than passing on the burden to communities and the environment.

Jennifer Decker, Partner at QSA Partners, outlined the importance of government action: “We see this as a rare, once-in-a-generation opportunity to transform the way clothing is designed and produced and the way individuals consume clothing and accessories. The potential impact is immense, and the risks of inaction are equally significant. This is the moment for the government to take decisive leadership.”

The fashion industry remains central to sustainability concerns. As a leading industry in the UK, it currently contributes approximately £62 billion annually to the UK economy. However, an estimated 336,000 tonnes of clothing are sent to landfill or incinerated every year.

The initiative hopes that the introduction of a variable EPR fee would increase the recycling and reuse of products and materials, and reduce unnecessary consumption and the harmful impacts of production. The variable fee system could potentially be communicated to consumers, influencing purchasing decisions and raising awareness about product sustainability.

Commenting on the outcomes of a fee, Adam Mansell, Chief Executive Officer at UKFT, said: “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 penalising those that don’t take their responsibility to the environment seriously. It is the one issue around sustainability that everyone in the supply chain agrees on – legislation is needed to drive progress”.