Policy Advisory
Independent policy advisory on ESPR, Digital Product Passports, textile Extended Producer Responsibility, UK secondary legislation under the Product Regulation and Metrology Act 2025, and the international standards landscape, methodology that holds up under regulatory and investor scrutiny.
We hold a contributor seat on the UN/CEFACT UNTP Supply Chain Working Group, engage actively with UK policy development through Defra, OPSS, DSIT and the House of Lords, and operate across the EU, UK and West African policy environments shaping product regulation through to 2030.
Book a 30-minute call →The Product Regulation and Metrology Act 2025 received Royal Assent on 21 July 2025 and entered into force the same day. It is the enabling framework for the UK's approach to product regulation after Brexit. It does not, on its own, set out detailed Digital Product Passport obligations, it creates the powers through which those obligations will be introduced.
The substance will arrive through secondary legislation, statutory instruments that define scope, data fields, timelines and enforcement for the UK market. Three substantive workstreams are currently in development across textiles, consumer connectable products and construction products. Organisations that understand the architecture now are positioned to shape and prepare for the detail as it lands.
PRMA 2025 creates the powers under which UK Digital Product Passport requirements will be introduced. The Act itself is technical rather than substantive, it sits on the shelf until secondary legislation activates each category.
The detail arrives through statutory instruments. Defra leads on textile policy and the textile statutory instrument, with the Office for Product Safety and Standards (OPSS) acting as the enforcement authority. The Department for Science, Innovation and Technology (DSIT) leads on the separate workstream for consumer connectable products and digital product security.
UK brands selling into the EU face both regimes. The UK regime is expected to broadly mirror EU ESPR for interoperability, but with divergence on data sovereignty, hosting requirements and waste infrastructure treatment. Compliance must be built to satisfy each in parallel, designed for the broader of the two requirements.
We have been actively engaged with the UK pipeline through formal submissions to Defra, OPSS and the House of Lords on UK DPP legislative architecture, and through ongoing engagement with parliamentary committees as the secondary legislation develops.
The EU Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, is binding law with economy-wide scope. It establishes the Digital Product Passport as a mandatory instrument across most categories of physical goods sold into the EU market.
We build compliance infrastructure aligned to the UN Transparency Protocol (UNTP), so that the data records you create are interoperable, verifiable and resilient across both the EU and UK regimes, rather than locked to a single jurisdiction or vendor.
ESPR (Regulation 2024/1781) is directly applicable EU law. The framework regulation entered into force in July 2024. The substantive obligations come from delegated acts, secondary legislation the Commission writes for each product category one at a time. The textile delegated act is in the first wave and currently being drafted.
Machine-readable, verifiable product data records will be mandatory across most categories sold in the EU. The data must be queryable, updatable and accessible through a standardised protocol. The standards landscape is converging on UNTP for the protocol, GS1 Digital Link for the identifier and W3C Verifiable Credentials for signed and verifiable claims.
We build to the UN Transparency Protocol so data records remain interoperable, verifiable and future-proof across jurisdictions. Most DPP platforms marketed in 2024 and 2025 are not yet aligned with UNTP, by the time the textile delegated act adopts, those that aren't will be unusable.
A separate but converging regulatory front is reshaping how products enter the EU and UK markets, and how ESPR obligations attach to them.
The EU is removing the €150 customs duty de minimis threshold from 1 July 2026, accelerating the timeline originally set under the Customs Union reform package. The current threshold lets low-value parcels enter the EU without customs duties and with reduced regulatory checking, a route used at scale by direct-to-consumer platforms shipping from outside the EU. Once removed, every parcel entering the EU becomes a regulated import, subject to customs, VAT and increasingly to product-level compliance verification including ESPR Digital Product Passport requirements.
The UK is moving in parallel, with removal of the £135 de minimis threshold scheduled for March 2029, the same direction of travel, on a longer timeline.
The implication for product-led businesses is significant. The de minimis loophole has been the primary route by which non-EU and non-UK sellers, particularly fast fashion marketplaces operating from outside Europe, have avoided product regulation obligations. Closing it changes the competitive landscape. Brands that have built compliance infrastructure will be advantaged; sellers that relied on de minimis to bypass regulation will face the full obligation stack at the same moment ESPR and UK DPP take effect.
We advise on the strategic and operational implications of de minimis reform, including scenario planning for the post-2026 customs environment, supply chain restructuring options, and the alignment between de minimis closure and the textile delegated act timeline.
Textile EPR is moving faster than ESPR and is already creating obligations on the ground. The EU mandated textile EPR at union level through the revised Waste Framework Directive. Member states are transposing and operationalising schemes on different timelines. EPR fees are payable by producers, defined as brands, retailers and importers placing textile products on the market, and fund the collection, sorting, reuse and recycling of post-consumer textile waste.
The EU mandated textile EPR at union level through the revised Waste Framework Directive. Member states are transposing and operationalising schemes on different timelines. EPR fees are payable by producers, defined as brands, retailers and importers placing textile products on the market, and fund the collection, sorting, reuse and recycling of post-consumer textile waste.
Fee structures vary by member state but follow a common direction: eco-modulation of fees based on product design, durability, recyclability and verifiable supply chain data. Better-performing products pay lower fees; worse-performing products pay significantly more. The eco-modulation criteria are converging on the same data fields that ESPR Digital Product Passports will require, which means brands that build DPP infrastructure are simultaneously building the data they need to minimise EPR fees.
France leads with Re_fashion, operational since 2007 and progressively eco-modulating fees. The Netherlands and Sweden are operational. Italy and Spain are in implementation with draft decrees under consultation. Germany is in consultation and framework development. The UK is consulting on its own textile EPR framework through Defra, with operational targeting later in the decade.
We advise on textile EPR exposure across multiple jurisdictions, the alignment between EPR data requirements and ESPR DPP requirements, and the eco-modulation strategies that minimise fee exposure while building toward broader compliance.
Most policy advisories stop at the EU and UK borders. The product regulation landscape extends meaningfully beyond, and Ghana is one of the most strategically important policy environments for the post-consumer textile economy.
The Ghana Carbon Market Office sits within the Environmental Protection Agency (EPA), which operates under the Ministry of Environment, Science, Technology and Innovation (MESTI). The Office is responsible for Ghana's implementation of Article 6 of the Paris Agreement, the framework that allows internationally transferred mitigation outcomes (ITMOs) to count toward national climate targets across borders.
Ghana signed one of the first bilateral Article 6.2 agreements with Switzerland on 24 November 2020. Ghana is actively building the methodology and registry infrastructure for ITMO transfers across multiple sectors.
For the textile economy this is significant. Roughly 15 million garments arrive at Kantamanto Market in Accra every week through the secondhand clothing corridor from Europe. A substantial proportion ends up in landfill, in coastal waterways, or burned, generating methane and carbon emissions that are not currently attributed to the originating brands in Europe. The intersection of:
This intersection is one of the most underdeveloped policy intersections in the global product regulation landscape. It is also one of the most consequential. The brand that voluntarily routes EPR fees into verified Article 6 methane abatement projects in Ghana, generating ITMOs that count toward its Scope 3 footprint, is operating ahead of the regulatory architecture rather than behind it.
We are engaged with this intersection through related governance roles, including the Vice-Chair seat at Landfills2Landmarks Foundation, a UN-accredited NGO working on the textile waste corridor and post-consumer textile circular economy in Ghana.
We advise on the strategic implications of Article 6 frameworks for Global South partners, the operational alignment between EPR fee deployment and ITMO generation, and the regulatory positioning available to brands engaging with the textile waste corridor on credible terms.
Voluntary carbon markets are not formally regulated, but the integrity frameworks shaping them have effectively regulatory force. Buyers' claims about carbon credits are now scrutinised under the Integrity Council for the Voluntary Carbon Market (IC-VCM) Core Carbon Principles, the Voluntary Carbon Markets Integrity Initiative (VCMI) Claims Code, the SBTi guidance on beyond-value-chain mitigation, and the GHG Protocol Land Sector and Removals Guidance.
Each of these frameworks is being actively revised. Organisations that built credit portfolios under the 2020 to 2023 integrity assumptions are finding those credits revalued, retired, or excluded from new claims frameworks. We advise on the current state of the integrity landscape, the implications for existing credit positions, and the strategic decisions about credit selection and claim framing under the next generation of frameworks.
Policy advisory is not a one-off report. It is an ongoing relationship that tracks legislation as it develops and turns it into defensible decisions for your organisation.
Regulatory readiness reviews, horizon scanning across multiple jurisdictions, and strategic positioning on ESPR, DPP, textile EPR, de minimis reform, Article 6 frameworks and adjacent regulatory developments. Quarterly or monthly retainers are common; project-based engagements are available for specific decisions.
Drafting and review of consultation responses, evidence submissions, position papers and parliamentary briefings for UK and EU standard-setting bodies, regulators and parliamentary committees. We have made formal submissions to Defra, OPSS, the House of Lords and DSIT on UK DPP legislative architecture, and engage with EU Commission consultations through industry and standards-body channels.
Board-level and cross-functional briefings that translate emerging legislation into concrete, defensible operational decisions. Sessions are tailored to the audience, senior leadership, sustainability and compliance teams, procurement and sourcing, and investor or board engagement.
Most organisations are reading the regulation too late. We help you understand where you stand on ESPR, Digital Product Passports, textile EPR, de minimis reform and UK secondary legislation, and what to do next.
Book a 30-minute call →Or get in touch directly, info@symolem.com