Independent advisory for fashion brands preparing for ESPR.
We turn Digital Product Passport requirements into practical systems, data, and governance that regulators and buyers can trust.
The era of telling a sustainability story is ending. What replaces it is a legal obligation, a financial exposure, and a systems reset, and most brands are not ready for any of them.
Regulations are stacking up. Investors are demanding evidence of circular intent. Customers are seeking integrity. The brands that get this right treat sustainability as a strategic goal, not a department.
We have mapped 50 regulations that fashion brands need to be aware of and tracking against. The Ecodesign for Sustainable Products Regulation (ESPR) is only one of them, but it is the one that matters most right now. In force since July 2024, ESPR establishes the framework for binding ecodesign requirements across almost every product on the EU market, with textiles a first priority, and mandates the Digital Product Passport, making product-level data a condition of market access. It is the regulation that turns sustainability from a story into a trading requirement, and it is why we start with ESPR readiness when working with brands to understand their product sustainability compliance exposure.
Our philosophy
The circular economy is stuck. The design is the problem.
The circular economy for textiles is stuck. Not because the ambition is wrong, but because the system is poorly designed.
ESPR reshapes the market by changing what organisations must be able to prove. The challenge is no longer only what to say about circularity, but how to prove it through product-level data, systems, and governance.
Digital Product Passports are the data carriers for that shift. They connect each product to structured, machine-readable information on origin, materials, repairability, compliance, and circularity, creating the link between regulation, product design, and downstream recovery.
That means readiness is not just about interpreting policy. It is about building the data infrastructure, traceability logic, and operating model that allow organisations to respond to ESPR with confidence and turn circular ambition into something operational, auditable, and scalable.
That is why our work begins with the system, not the slogan. We look at the economics, infrastructure, data, and governance that circularity depends on, then build from there. Our frameworks are designed to turn complexity into decisions, and decisions into systems that can be implemented, measured, and trusted.
START
START is our framework for ESPR readiness and circular-system implementation. It shows how standards, transparency, accountability, responsibility, and transition fit together so organisations can move from regulatory exposure to practical readiness.
Transition
Transition turns readiness into action. This layer covers adoption strategy, stakeholder engagement, training, and capability building so organisations can implement change with confidence.
Responsibility
Responsibility defines who owns what across the value chain. This layer covers policy advisory, EPR architecture, and governance that can hold up under scrutiny.
Accountability
Accountability makes the system testable. This layer covers MRV, product-level evidence, and auditable impact measurement so organisations can prove what they say.
Transparency
Transparency makes the system visible. This layer covers Digital Product Passport strategy, data architecture, and the product identity needed to connect regulation, product design, and downstream recovery.
Standards
We begin with standards because systems need a clear rulebook before they can be built. This layer covers regulatory gap analysis, product and category prioritisation, and the standards that shape ESPR readiness.
Layer 5
Transition
Transition turns readiness into action. This layer covers adoption strategy, stakeholder engagement, training, and capability building so organisations can implement change with confidence.
Layer 4
Responsibility
Responsibility defines who owns what across the value chain. This layer covers policy advisory, EPR architecture, and governance that can hold up under scrutiny.
Layer 3
Accountability
Accountability makes the system testable. This layer covers MRV, product-level evidence, and auditable impact measurement so organisations can prove what they say.
Layer 2
Transparency
Transparency makes the system visible. This layer covers Digital Product Passport strategy, data architecture, and the product identity needed to connect regulation, product design, and downstream recovery.
Layer 1
Standards
We begin with standards because systems need a clear rulebook before they can be built. This layer covers regulatory gap analysis, product and category prioritisation, and the standards that shape ESPR readiness.
Our approach
The delivery layers of ESPR readiness.
Our services are the delivery layers of ESPR readiness, with START as the structure behind them. We work across all five from regulatory risk mapping to behaviour change because the circular economy doesn't break at one point. It breaks at every point where a layer is missing.
Standards: Compliance alignment and risk mapping
We assess where your products sit against current and incoming regulation: Ecodesign for Sustainable Products Regulation, Extended Producer Responsibility, Digital Product Passport mandates, carbon disclosure, and map the gaps. What are you exposed to, what's coming, and what needs to change before it arrives.
Transparency: Digital product identity
We design digital product identity strategies and develop Digital Product Passport roll-out for priority product categories, so organisations know which products to passport first, what data to capture, and how to sequence compliance across their range.
Accountability: Impact measurement and MRV
We measure what matters: emissions, resource use, human impact. We build the monitoring, reporting, and verification systems that make those numbers defensible. True MRV, not estimated. Auditable, not aspirational.
Responsibility: Policy, regulatory advisory, and NGO partnerships
We advise governments, national programmes, and NGOs on the design of Digital Product Passport frameworks, Extended Producer Responsibility systems, and circular economy policy, grounded in the real cost of recovery, not designed in isolation from it.
Transition: Adoption and behaviour change
We design the strategies that move industries and communities from circular intent to circular practice. Training, stakeholder engagement, awareness, and the research that underpins it. Because infrastructure nobody uses isn't infrastructure.
How we work
Advisory
Strategic guidance, regulatory analysis, policy submissions, and framework design. For organisations that need expert input alongside their own teams.
Delivery
Hands-on implementation of Digital Product Passport strategies, compliance programmes, impact measurement systems, and adoption plans. We build it with you, not just advise on it.
Partnerships
Long-term collaboration with governments, NGOs, and national programmes on circular economy infrastructure, evidence building, and policy development. We work as a partner, not a supplier.
Who we've worked with
ESPR Readiness Assessment
Start with the Assessment.
A fixed-fee, ten-working-day diagnostic. We score your brand across eight readiness domains drawn from our 814-field register, map your exposure by product category against ESPR Wave 1 and Wave 2 timelines, and deliver a board-ready report your leadership can act on.
One fixed fee. One report. One debrief call. The fastest way to know exactly where you stand.
Every assessment is benchmarked against 50 fashion and textile regulations across 14 jurisdictions — from ESPR and the Digital Product Passport to PFAS bans, EPR schemes and green claims enforcement.
ESPR Services
From exposure to readiness.
In four stages.
Every engagement starts with the Assessment. Where gaps are found, the four-stage Symolem Programme — a structured 13-week engagement — closes them. Each stage builds on the last, moving your business from regulatory uncertainty to a verified, defensible compliance position.
ESPR is the anchor — the regulation every fashion business selling into the EU must prepare for first. But it doesn't arrive alone. We track 50 fashion and textile regulations across 14 jurisdictions — PFAS bans, EPR schemes, green claims enforcement, forced labour rules, waste export controls — so our clients see the whole board, not just the biggest piece.
ESPR Gap Analysis & Compliance Roadmap
We map your brand's current position against ESPR obligations, identify your highest-risk gaps, and build a prioritised compliance roadmap with clear milestones to 2028.
Digital Product Passport Readiness
We assess your data infrastructure, identify the 814+ DPP data fields you'll need to populate, map your supply chain data gaps, and define the technical architecture your brand requires.
Supply Chain Transparency & ESPR Data
Multi-tier supplier mapping, circularity audit, and Scope 3 product-level calculation to build the evidence base your DPP will require under ESPR Regulation 2024/1781. We also analyse any DPP providers you are currently working with, verifying their outputs against EU law, because compliance that cannot be independently verified is not compliance at all.
Regulatory Impact Measurement, HIE®
Using our proprietary Human Impact Equivalence Framework™, we translate your ESPR compliance data into structured, auditable impact evidence, quantified to the standard that regulators, investors, and institutional counterparties require. Not beyond what the law asks. Precisely what it demands.
Assessments are scored on a structured 100-point methodology, designed for consistency and comparability.
Let's talk about your impact.
Whether you are navigating regulatory change, measuring real-world impact, or building methodology that holds up under scrutiny. A 30-minute conversation is the place to start.