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Who we help · Government

Textile EPR and Digital Product Passport Policy Advisory for Governments

Producer responsibility that finances the recovery it promises.

We advise governments, agencies and national programmes on the design, costing and verification of producer responsibility and product data regimes — for textiles, and for the export corridors most schemes ignore. Cost the system, then design the instrument.

UN Transparency Protocol (UNTP)UK PRMA 2025 submissionsBasel ConventionEU ESPR

Textile EPR scheme design built from the cost of recovery

Extended Producer Responsibility is now law or in draft across more than sixty countries and close to four hundred policies. Most textile schemes are designed from the obligation downwards, so fees are set before anyone has costed collection, sorting and fibre-to-fibre processing. The result looks complete and functions poorly.

Designing a scheme

Cost-of-recovery modelling across collection, sorting, reuse, recycling and residual disposal. Producer definitions, scope thresholds, fee base design, eco-modulation criteria that can be independently verified, and an options appraisal of what each choice costs to administer and what it delivers.

Implementing or reforming one

Whether the money is reaching the infrastructure it was raised to build, whether modulation criteria produce the behaviour intended, and whether reported data can be verified rather than accepted on declaration.

Export corridors most schemes omit

Where second-hand textiles are exported, obligation and material part company. We research classification integrity, mass balance across sorting and re-export nodes, and how liability and finance can travel downstream. The UK is among the largest exporters of used textiles to West Africa.

National Digital Product Passport frameworks and data sovereignty

Every government designing a Digital Product Passport regime is choosing an architecture, whether or not the choice is made deliberately. Two national models are emerging.

The European model: distributed

The passport is held and issued by the economic operator, with a registry pointing to it and verification distributed across the value chain.

China's model: centralised

In March 2026 China set up its first national DPP standardisation working group, secretariat hosted by GS1 China with forty-three members. The CAICT framework has three layers — national registry, industry registries and enterprise systems — with textiles and lithium-ion batteries as priority sectors.

Why it is a live decision

China has proposed mutual recognition with the EU system, and a China-proposed standard on digital product carbon footprint has been approved by the IEC. Your architecture decides who holds the registry, where product data resides, and whether exporters face one compliance burden or two.

What we do. Architecture options and their data sovereignty implications, alignment with the European regime, the emerging Chinese system and the UN Transparency Protocol, sector sequencing, and calibration to the data domestic industry can realistically produce — interoperable abroad and workable at home.

Second-hand textile policy research and evidence appraisal

Policy is only as good as the evidence beneath it. From 27 September 2026 a brand cannot make an unsubstantiated environmental claim to an EU consumer; we apply the same standard to the evidence beneath regulation.

Kantamanto, Accra

Second-hand textile traceability in one of the largest second-hand clothing markets in the world, with standing relationships with market leadership, the Ghana Used Clothing Dealers Association and traders.

Kakuma, Kenya

Advising BALWA Africa Enterprise, a tailoring and skills enterprise in Kakuma refugee camp, on its project structure and funding case — the livelihood end of the same trade.

Evidence appraisal

Before a fee, target, ban or classification is fixed in law, we trace its figures to primary source: methodology, system boundary, functional unit and uncertainty range.

Consignment-level field research

What imported consignments actually contain — grade, composition, rewearability, residual fraction — designed with local academic and trade partners.

Life cycle and carbon review

ISO 14067, PAS 2050 and ISO 14064, applied to whether an eco-modulation criterion is methodologically supportable — including the cross-fibre comparisons LCA cannot carry.

Trade flow and classification

Customs data, tariff classification integrity and mass balance, showing where declared classification and composition diverge and what it costs in duty and disposal.

Comparative regulatory research

DPP and EPR frameworks across the EU, UK, China and West Africa: what was legislated, what it cost to administer and what it achieved.

Impact measurement

The Human Impact Equivalence Framework® quantifies programme outcomes in impacted lives, for funders who need a defensible measure of what changed.

UK policy submissions and international standards work

  • Working to the UN Transparency Protocol, the global standard governments will be asked to align to
  • Formal UK policy positions submitted to Defra, DBT, DSIT, OPSS and the House of Lords on Digital Product Passport and product regulation architecture under the Product Regulation and Metrology Act 2025
  • A Second-Hand Textiles position paper delivered to UK Government, and a UK–Ghana used-textiles framework referencing the Basel Convention
  • Moderator of the textile Extended Producer Responsibility and market protection roundtable at the Landfills2Landmarks Summit, Accra, May 2026
  • A consultant bench covering carbon markets and Article 6 mechanisms, MRV design, ISO 14067 and PAS 2050 footprinting, ISO 14064 accounting, textile-to-textile recycling and Ghanaian second-hand textile market research

Who we work with. Environment ministries and agencies, regulators, municipal waste authorities, producer responsibility organisations, standards bodies, and donor-funded programmes — the FCDO, UNCTAD and development finance institutions. Our cross-border textiles work sits in the territory the FCDO-funded Sustainable Manufacturing and Environmental Pollution Programme has been building evidence in since 2019.

EPR scoping studies, options appraisals and consultation responses

Most engagements begin with a scoping study or a costed options appraisal that establishes what the system costs before anyone commits to an instrument. From there we support drafting, consultation responses, position papers, technical annexes and the verification architecture that makes a scheme enforceable. Field research is delivered with local academic and trade partners in-country.