Who we help · Government
Extended Producer Responsibility that finances the recovery it promises, and Digital Product Passport frameworks that work at home as well as abroad. 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.
Extended Producer Responsibility is now law or in draft across more than sixty countries and close to four hundred discrete policies. Very few textile schemes are designed from the cost of recovery upwards. They are designed from the obligation downwards — a registration duty, a fee, a target — and the money is set before anyone has established what collection, sorting and fibre-to-fibre processing actually cost.
The result is a scheme that looks complete and functions poorly. Fees too low to finance the infrastructure the targets require. Eco-modulation criteria set on data producers cannot supply and regulators cannot verify. And an obligation that stops at the national border, while the material does not — leaving the receiving country carrying a waste burden it was never funded to manage, under a framework it had no part in writing.
We do this work the other way round. Cost the system, then design the instrument.
Most textile Extended Producer Responsibility schemes are designed before anyone has established what recovery costs. We do the research that comes first.
Producer responsibility schemes that work are built from the economics of recovery upwards. The schemes that fail are built from the obligation downwards, with the numbers set before the system beneath them has been costed. We work with governments at both stages.
Designing a scheme. Cost-of-recovery modelling across collection, sorting, reuse, recycling and residual disposal. Producer definitions, scope thresholds and fee base design. Eco-modulation criteria built on metrics that can be substantiated and independently verified. Registration, reporting and verification architecture. Options appraisal setting out what each design choice costs to administer and what it delivers.
Implementing or reforming one. Where a scheme is already in force, we assess whether the money is reaching the infrastructure it was raised to build, whether the modulation criteria are producing the behaviour intended, and whether reported data can actually be verified rather than accepted on declaration.
The part most frameworks omit. Where second-hand and residual textiles are exported, obligation and material part company. Goods travel under worn-clothing classification when a fraction is waste, destination customs recover the wrong duty, and no producer responsibility follows the product to the point of actual disposal. We research classification integrity, mass balance across sorting and re-export nodes, and the mechanisms by which liability and finance can travel downstream with the material. The United Kingdom is among the largest exporters of used textiles to West Africa: designing producer responsibility that works at the receiving end is a UK policy question as much as a Ghanaian one.
Every government designing a Digital Product Passport regime is choosing an architecture, whether or not the choice is made deliberately.
The Digital Product Passport is no longer a European instrument. Two national models are now emerging, built on different assumptions about who holds product data.
The European model is 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 is centralised. In March 2026 China established its first national standardisation working group for Digital Product Passports, with the secretariat hosted by GS1 China and forty-three members drawn from market regulation, commerce, customs, information and communications technology, textiles, batteries and automotive. The framework developed under the China Academy of Information and Communications Technology sets out three layers — a national registry, industry registries and enterprise systems — with textiles and lithium-ion batteries as priority sectors and a battery passport pilot already running. Where the European approach leaves verified product data under manufacturer control, the Chinese approach centres on state-administered platforms.
Two developments make this a live question rather than a comparative curiosity. China has proposed negotiating mutual recognition between the European and Chinese systems, so that passports issued under either would be accepted by the other. And a China-proposed international standard on digital product carbon footprint has been approved by the International Electrotechnical Commission. The standards layer beneath both systems is being set now.
For any other government, that produces a decision with consequences well beyond compliance. Which architecture you align to determines who holds the registry, where product data resides, whether your exporters face one compliance burden or two, and how much sovereignty you retain over the data your industries generate.
What we do. We advise on national Digital Product Passport framework design — 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. The objective is interoperable abroad and workable at home, rather than a framework imported wholesale from either direction.
We hold a seat on the UN/CEFACT UN Transparency Protocol Supply Chain Working Group, where the interoperability layer between these systems is being negotiated.
Policy is only as good as the evidence beneath it — and most textile policy rests on figures nobody has traced to source.
We are already in the market. Symolem works on second-hand textile traceability in Kantamanto, Accra — one of the largest second-hand clothing markets in the world, and the single most contested site in the global debate about textile waste. That means standing relationships with market leadership, the Ghana Used Clothing Dealers Association and the traders who handle the material, direct operational knowledge of how bales move, are graded, sold and disposed of, and an established route to primary data. Research in this market fails on access and on response bias. We do not arrive as outsiders asking to be let in.
And at the livelihood end of the same trade. Symolem advises BALWA Africa Enterprise, a tailoring and skills enterprise in Kakuma refugee camp in Turkana County, north-west Kenya — structuring the project and its funding case so it can secure the equipment and capacity it needs to grow. Kenya is the largest importer of second-hand clothing on the continent, and repair, alteration and remaking are how reuse actually happens there. Work of this kind tells us what the downstream of the trade looks like from inside it, not from a customs dataset.
Evidence appraisal before an instrument is set. Before a fee, a target, a ban or a classification is fixed in law, we trace the figures it rests on to primary source and set out what each one can and cannot support — the methodology used, the system boundary, the functional unit, the uncertainty range, and whether the metric is an accounting quantity being presented as an impact. From 27 September 2026 a brand cannot make an unsubstantiated environmental claim to a consumer in the European Union. The same standard is not yet applied to the evidence base beneath the regulation itself. We apply it.
Market composition and consignment-level field research. Structured field research in destination markets, designed with local academic and trade partners, on what imported consignments actually contain — grade, composition, rewearability, residual fraction — and what happens to each fraction downstream. Where existing studies produce a contested aggregate, we build the method so that classification is evidenced per consignment and can be independently checked, rather than argued at national level.
Life cycle and carbon evidence review. Product carbon footprinting to ISO 14067 and PAS 2050 and greenhouse gas accounting to ISO 14064, applied to the specific question of whether a proposed eco-modulation criterion is methodologically supportable. This includes being explicit about the comparisons life cycle assessment cannot carry — cross-fibre comparison in particular, where differing boundaries, functional units and biogenic carbon treatment make headline comparison invalid, however widely it is repeated.
Trade flow and classification analysis. Customs data, tariff classification integrity and mass balance across sorting and re-export nodes — establishing where declared classification and actual composition diverge, and what that costs the receiving jurisdiction in foregone duty and unfunded disposal.
Comparative regulatory research. What other jurisdictions legislated, what it cost to administer, and what it actually achieved. Digital Product Passport and Extended Producer Responsibility frameworks across the European Union, the United Kingdom, China and West Africa, tracked as they develop rather than reconstructed afterwards.
Impact measurement. Where a programme needs to evidence outcomes rather than activity, we apply the Human Impact Equivalence Framework® — our methodology for quantifying results in impacted lives, designed for funders and programmes that need a defensible measure of what changed.
Formal submissions and consultation response. We write the evidence base that puts a defensible position in front of government: consultation responses, position papers, legislative architecture proposals and technical annexes, argued from data and the mechanics of recovery rather than advocacy alone.
How the research is delivered. Scoping studies, costed options appraisals, technical annexes, consultation responses and peer-reviewable method notes. Where field research is required we deliver it with local academic and trade partners in-country, and in Ghana we bring existing market access and working relationships to the design — so primary data is collected by people the market will speak to honestly.
National environment ministries and agencies. Regulators establishing producer responsibility or Digital Product Passport regimes. Municipal and metropolitan waste authorities. Producer responsibility organisations and compliance schemes. Standards bodies and multilateral working groups. And donor-funded research and technical assistance programmes — the FCDO, UNCTAD, development finance institutions, and the programme managers who procure on their behalf. Our cross-border textiles work sits directly in the territory the FCDO-funded Sustainable Manufacturing and Environmental Pollution Programme has been building evidence in since 2019.
Most begin with a scoping study or a costed options appraisal — a short, defined piece of work that establishes what the system costs before anyone commits to an instrument. From there we support drafting, stakeholder consultation, and the verification architecture that makes the scheme enforceable.