9. Policy and Regulation

KEY STAKEHOLDERS
LEAD
ENABLERS
KEY SYNERGY TOPICS
  • CIRCULAR DESIGN
  • CONSUMER EMPOWERMENT
  • CIRCULAR AND SHARING BUSINESS MODELS
  • DEMAND FOR RECYCLED AND RENEWABLE FIBRES
  • POST-USE ECOSYSTEM
  • SORTATION AND RECYCLING
  • INNOVATION INVESTMENT

The UK government needs to actively consult on and introduce effective extended producer responsibility (EPR) legislation. As well as exploring the options, it must support the transition to a circular fashion ecosystem, including offering preferential incentives and developing standards for labels and feedstock. The UK Government will play a critical role in propelling the move to a circular fashion ecosystem. To support this transition, it must consult on and implement policy and regulation to incentivise responsible business behaviours and practices. This is important to ensure that ‘first adopters’ in the circular economy are not penalisedwith relatively higher costs in developing solutions and technologies than ‘late adopters’, who may gain commercial advantage by holding out to change until costs have dropped.

Potential policy and legislative levers include EPR; preferential tariffs; tax breaks; a carbon tax; grants for circular small and medium enterprises; requirements for reused or recycled content in products; sustainability considerations when negotiating new Free Trade Agreements, and the establishment of standards and certification for the industry in areas like labelling and feedstock. These options subscribe to the fundamental principle that policy and regulation must take into account the environmental and social costs of producing goods alongside considering traditional economic costs. This principle was also emphasised by several of the stakeholders consulted for this report.

GWEN CUNNINGHAM

TEXTILES LEAD, CIRCLE ECONOMY

“Policymakers have a key role to play in incentivising service based business models, extended producer responsibility is absolutely part of the solution.”

Recommendations
  • Introducing an EPR scheme: Government to implement an industry-led approach to Extended Producer Responsibility (EPR) legislation, that clearly incentivises brands, designers and retailers to go beyond the minimum standards for circular design and adopt circular business models. This EPR scheme should ensure that a guaranteed percentage of funds raised is invested into recycling infrastructure and repair services, thereby increasing the industry’s investment potential and the potential profit margin achieved from recycled products.
  • Developing feedstock and label standards: Government to develop a) feedstock standards for the textiles recycling industry and b) label standards for ensuring accurate and standardised information for textile reprocessors, manufacturers, and consumers. Such standards should be included as part of an Extended Producer Responsibility scheme. As part of this standards development, definitions and processes for textile and non-textile recycling inputs should be standardised and clearer definitions of waste should be developed. Appropriate clothing design and the development of intelligent labels and product passports will be critical to ensuring optimised sorting downstream, requiring designers, logistics providers and digital innovators to be included in the development of standards and supporting technologies.
  • Mainstreaming metrics for societal prosperity: Institutions, industry bodies and third sector to convene a multi-stakeholder initiative to mainstream within the UK fashion ecosystem:
    1. alternative metrics for measuring business success; and
    2. alternative metrics for evaluating societal prosperity

This should include industry-wide training to ensure finance departments understand and appreciate metrics that go beyond the traditional financial models.

BERNIE THOMAS

CIRCULAR ECONOMY AND SUSTAINABILITY MANAGER, THE SALVATION ARMY TRADING COMPANY LTD (SATCOL)

“There is limited incentive for producers to be stewards for the items they place on the market, over the full life cycle, so EPR is necessary”

CASE STUDY

Amsterdam City Doughnut

RELEVANT ACTION AREAS
  • POLICY AND REGULATION

Launched in 2020, the Amsterdam City Doughnut (ACD) is inspired by, and in partnership with, Kate Raworth’s (2017)69 ‘Doughnut Economics’ book and theory of change that challenges ‘growth’ as a progress indicator for our society and economy. ACD is the outcome of the partnership of Kate Raworth, with Circle Economy and C40 network of cities, and is motivated by the need to create ecologically safe and socially just cities. The tool is used to foster big-picture thinking, and cross-departmental collaboration within the City and with a wider network of city changemakers, to create the city’s transformation. Many cities around the world are currently applying the tool and its methodology to design holistic circular strategies and innovative metrics to measure their successes. While the ACD encompasses a number of different industries, including housing and transport, it is also promoting access to, instead of ownership of, consumer goods, as well as extending the life cycle of fashion and textiles by adopting the waste hierarchy of reducing, reusing and recycling. The ACD exemplifies the power of government and policy makers in promoting and incentivising environmentally positive actions within the fashion industry at scale, as well as the importance of transitioning in a co-creative and participatory way.

CASE STUDY

French EPR Scheme

RELEVANT ACTION AREAS
  • POLICY AND REGULATION

The French Extended Producer Responsibility (EPR) policy came into effect on 1 January 2007 and since then, all legal entities putting new textiles and clothing onto the French market (such as garments, footwear and household linens for residential use) are held responsible for the recycling or proper disposal of their products70. As the first country to adopt an Extended Producer Responsibility (EPR) scheme, France has had remarkable success. The EPR for Textiles, Footwear and Linen (Eco-organisme du Textiles, du Linge et de la Chaussure) has 29 associate members that represent the whole textiles value chain, including general large retailers (e.g., Carrefour), fashion retailers (e.g., Galeries Lafayette), direct sales and mail/online retailers (e.g. Groupe 3SI), manufacturers and wholesalers (e.g. LVMH), and apparel industry associations. This network group has driven and accelerated innovation, and made circular principles more mainstream within France, overall contributing to a threefold increase in the collection and recycling rates of post-consumer textiles since 200671. Its success demonstrates how effective government participation can be in supporting and regulating circular activities.

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