Ep. 153: How to prepare for incoming ESPR

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Ep. 153: How to prepare for incoming ESPR

WTiN speaks with Aimee Campanella, development director for textile EPR at Reconomy about incoming ban of the destruction of unsold apparel clothing accessories and footwear on 19 July 2026.

WTiN: Hello, and welcome to WTiN's podcast, all about the regulations and legislation the textile and apparel industry needs to know. I'm Abi, WTiN's features editor, and your podcast host. In this series, we speak to the experts who are navigating and aiding navigation in this complex arena. From digital product passports and ESPR to exports and international trade. Brands and manufacturers have a lot to keep on top of. So each month we speak to the experts about what the textile industry should be focusing on and the tools available to them.

In this episode I'm joined by Aimee Campanella, Development Director for Textile EPR at Reconomy. In this episode we speak about the EU's ecodesign for sustainable products regulation, which includes a landmark ban on the destruction of unsold apparel clothing accessories, and footwear to reduce textile waste and carbon emissions. This ban is coming into place on the 19th of July 2026. Amy speaks through what brands and manufacturers need to know and how they can prepare for this regulation. We also touch upon extended producer responsibility and how Reconomy can support textile businesses as they navigate this complex compliance landscape.

Hi, Amy. Thank you so much for coming on WTiN's Textile Innovation Podcast today. Please can you tell me about your background in textiles and your work at Reconomy?

Campanella: Hi Abigail, thank you so much for having me. It's a pleasure to be here. I specialise in extended producer responsibility or EPR with a focus on textiles. So my work, it sits at the intersection of regulation and practical implementation helping brands understand what's coming and importantly, what they need to do about it. I've been with Reconomy for just over eight years, starting out in our recycling division. We have three divisions, recycling, compliance and reuse. And then I've moved into textile EPR in our comply division in the last couple of years.

So that journey has given me a really practical view on the waste and resource space, not just the policy side. Before I joined Reconomy though, I actually worked for a textile collector and sorter based in Bristol, where I currently live. That was a real eye opener for me. I went from being a typical high street shopper to seeing firsthand the sheer volume of clothing, shoes, and accessories being discarded, and also the value that still exists in those materials. And that's really where my passion for second hand fashion began. And it's something I still prioritise personally. I am a big fan of charity shops as well as vintage. The business I worked for back then was a small family run operation, and unfortunately, it's no longer trading. So this is something we're seeing across the sector globally. And that's one of the reasons why I'm so passionate about EPR and textiles. If it's done properly, it has the potential to support these essential parts of the value chain, not just to survive, but to thrive. So we can keep more textiles in use, through reuse and then recycle what we can't. So now a big part of my role Is translating all of that complexity into something actionable for businesses.

There is a lot of noise in this space. So helping organisations prioritise and move forward with confidence is absolutely key.

WTiN: Now that's so true. We're just seeing it ourselves. I feel like it's a bit crazy out there. So many different things coming in. So with that in mind, what you've just said, how does Reconomy support the textile industry throughout its compliance journey.

Campanella: For Reconomy, we are supporting the full compliance journey end to end. We are a one stop shop for environmental legislation like EPR. It starts with horizon scanning and interpretation. So, helping businesses understand what complex regulations mean in practice, both today and as they evolve. From there, we support with registration, reporting, and general ongoing compliance obligations across multiple jurisdictions. And material streams. But increasingly the focus is going beyond compliance alone. So we're working with brands to develop and operationalise circular models. So think take back, repair, resale, donation, and recycling, reflecting the direction regulation is moving in. Ultimately, what this is about, it's Combining regulatory expertise with practical delivery. We help businesses not only meet their current obligations, but prepare for what's coming next, testing and scaling circular approaches ahead of EPR implementation across the EU. And then in doing so, they can strengthen their sustainability strategy while also responding to the growing expectations around circularity.

WTiN: With just thinking about what you've said, what are maybe some of the risks that are associated with compliance for the textile industry and how do you help brands and manufacturers to mitigate them?

Campanella: So for risks, the biggest risk right now really is misunderstanding what's coming next and then that potentially leading to noncompliance Many businesses underestimate how quickly requirements are evolving or assume they only apply in certain markets. In reality, if you're selling into the EU, obligations are immediate and they're also far reaching. And beyond that, there are a few other key risks we consistently see.

Firstly, data gaps. Without accurate product Weights and composition data, reporting submissions can be incorrect, and this can lead to miscalculated fees and, again, potentially noncompliance. There is a lot of fragmentation across markets. Requirements differ by country, which makes it easy to misinterpret obligations or apply the wrong approach. And then there's financial and reputational exposure. Noncompliance can result in fines, but also reputational damage if it's seen by the public if it becomes Public. So we help brands mitigate these risks in a few practical ways. Firstly, what we do is we carry out detailed obligation assessments. This is giving businesses a clear view of what applies in each market and what they need to do and when. Second, we address the data challenge directly. We combine a large product database with supplier engagement and inhouse data capture, such as weighing days using calibrated equipment and then we build accurate audit ready datasets. This feeds into our reporting framework Sets. This feeds into our reporting framework across materials and jurisdictions, making the process much more streamlined for clients.

Third, we bring local expertise. We have decades of experience supporting EPR across Europe and close relationships with environmental ministries. We really do stay aligned with fast moving developments in key markets and are able to share those insights with our customer base. And then, last but by no means least, we focus on putting Practical scalable systems in place so businesses aren't reacting at the last minute but are set up to manage compliance confidently as requirements expand.

WTiN: That leads me really nicely on to what we want to talk about today. With the upcoming EU regulations under the Eco Design, the sustainable products regulation, which comes into effect very soon on the 19th of July. Could you please unpack these for us and explain where we currently are in terms of this incoming regulation?

Campanella: Not long to go now, just over a month until the 19th of July, and the ban on the destruction of unsold goods commences for large enterprises. So, under ESPR, the Eco Design for Sustainable Product Regulation, there are four key pillars: there are eco design requirements, digital product passports, green public procurement, and, as I just mentioned, most immediately, the ban on the destruction of unsold goods. And again, this is going to apply to large enterprises. From the 19th of July, 2026, and it covers apparel, textile accessories, and footwear. So, in practice, this means these businesses, these large enterprises, can no longer destroy unsold products, whether that's through landfill, incineration, or recycling. Yes, even recycling. Recycling is included because these products are expected to remain at their highest value in line with the waste hierarchy.

Instead, companies are expected to prioritise circular routes. So, think repair, refurbishment, resale, and donation. There are thirteen. 13 defined exemptions where destruction is permitted, such as where products are damaged, unsafe, legally restricted, or like genuinely unsuitable for reuse. However, businesses must evidence this and retain that justification for using these exemptions. And alongside this ban, there is also a new reporting requirement, which is already in motion. And this is where things have gotten a little bit confusing. Reporting for large enterprises, it effectively started last year, covering the first full financial year after July 2024 when ESPR commenced. So that means companies begin publishing this data in 2026. But then, what we had the delegated acts for back in February of 2026 is the actual reporting format. So, from February 2027, reporting will need to follow that standardised EU template outlined in the implementing act. And this will extend to medium sized enterprises, but not until 2030.

Was that clear, Abigail? Because I feel like that is a really confusing part for a lot of businesses, is what's happened around the reporting side of things.

WTiN: Are you able to go into any more detail for us on what some of those requirements may be?

Campanella: Sure, of course, yeah. So businesses will need to publicly disclose on an annual basis the number and weight of unsold products they discard, the reasons for doing so, including any of the 13 exemptions used, and where those products end up, whether that's reuse, recycling, or disposal. They'll also need to outline the measures they're taking to prevent destruction going forward. So, importantly, supporting documentation must be retained for five years and provided to authorities on request. So, this isn't just a transparency exercise, it's also about auditability. And the intention behind all this is to address the widespread destruction of unsold goods across the EU and shift the industry towards keeping products in use for longer. So, in terms of where we are now, this is an early but important step. The immediate scope Is quite targeted, but it's clear it's clearly signals the direction of travel. And over time, we expect ESPR to expand significantly, bringing in broader product categories and additional requirements like digital product passport and eco design criteria. So, the ban on destruction of unsold goods is the first major milestone, but it's part of a much bigger shift on how products are designed, managed, and valued across their entire life cycle.

WTiN: Thank you so much, Amy, for explaining. That does make sense, and it's going to be an interesting thing to navigate going forward for the industry.

Campanella: Absolutely. Yeah.

WTiN: I feel like you've touched upon this already, but I'm going to ask it anyway.  With what is coming into effect on the 19th of July, how will this affect businesses in the UK and the EU in particular?

Campanella: For EU based businesses, this is a direct legal obligation. So, They need to be compliant from day one. If you're a large enterprise dealing with apparel, textile accessories, or footwear, you can no longer destroy unsold goods after the 19th of July 2026, unless a valid exemption can be evidenced. Now, for UK businesses, the impact is just as significant if you are a UK business selling into the EU. And this is where we're still seeing some confusion. Brands assume that the regulation doesn't apply because they're based in the UK, but in reality, if you're a UK business and you're placing products on the EU market direct to consumers, it absolutely does. In practical terms, this means businesses need to rethink how they manage unsold stock. Products that are fit for reuse cannot simply be written off, they need to be redirected into circular channels. So that could include refurbishing returns for resale, selling end of line stock through alternative channels, or working with partners to enable donation or other reuse channels. So, but more broadly, the impact goes beyond compliance. It's really raising the bar across the industry. Even where businesses aren't directly in scope, it's creating a clear benchmark for best practice, shaping expectations from customers, investors, and ultimately, influencing the direction of future you policy. So, while the legal obligation may start with the EU, the commercial and operational implications are much, much wider.

WTiN: That makes complete sense. I mean, the UK, obviously, so many products go to the EU market. And just leading on from there, when this comes in, obviously we're a few weeks out yet, but what do you believe brands and manufacturers need to prioritise? And how would you advise them to get a head start on this or handle it as it comes in?

Campanella: So there are a few key priorities for brands and manufacturers right now. I'd say first, the first thing is understanding exposure. Where products are being placed on the EU market, what falls within scope, and how products are flowing through the supply chain. That includes looking at distribution models and where stock is actually held, because that directly impacts how unsold goods need to be managed. Second is thinking much more proactively about stock and returns. It's not just about excess inventory sitting in warehouses, returns are also considered unsold goods. So businesses need to put in place strategies that reduce the likelihood of products becoming unsold in the first place and make sure that there are clear routes to market if they do so. That could include improving product data and sizing guidance to reduce return rates, reviewing return policies, and having alternative resale or redistribution channels in place for end of line or return stock. But at the same time, better forecasting and inventory management can significantly reduce overproduction and obsolescence.

Now, if I were to simplify it, I guess it comes down to three priorities understand your exposure, where you're placing products on the EU market, and what's in scope, get your data in order, volume types, and visibility over what happens to unsold stock, and define a strategy early, how you'll handle resale, donation, repair, reuse, and any other flow. So, yeah, my advice would be not to treat this just as a tick box compliant exercise. The organisations that move early and take a more strategic operational approach, not just to compliance, but to circularity, will be in a much stronger position, both from a risk and commercial perspective.

WTiN: Thanks so much, Amy. That's really Great to break it down into those sections. And I feel like hearing so much more these days that data is integral to moving forward. When you speak to companies, what's the main concerns that the industry maybe has when it comes to compliance and this regulation? I know you've just said that how they can handle it, if we could take a step back and look at what that concern is to what that concern is to them. Like, yeah, if that makes sense.

Campanella: Yeah, crystal clear. So, the main concerns that we're hearing from the industry tend to center around complexity, cost, and uncertainty. Operationally, one of the biggest Challenges is how complex product returns and stock flows already are. Returns often pass through multiple locations and can take weeks to process, which significantly reduces their resale value, particularly for seasonal products or products from value retailers. That creates both a cost burden and a compliance risk if those products can't be redirected into a suitable circular route. There is also the challenge of product diversity. And forecasting. The industry is built around a high volume of styles, sizes, and seasonal ranges, and that makes it difficult to accurately predict demand. That often leads to overproduction or obsolete stock, which is exactly what these regulations are trying to address. But then, on top of that, brands are rethinking about issues like protecting brand value and IP, particularly when exploring resale, redistribution, or donation channels. So it's understandable that at first glance, this can feel really overwhelming. And the way to make it manageable is just to break it down into structured steps. And what we typically advise clients to do is start with a gap analysis, understanding what's already in place and where the risks are or gaps it and prioritise the high risks areas first whether that's key markets, product categories or parts of the supply chain, and then build out a phased roadmap. Rather than trying to solve everything at once, focus on practical incremental improvements. And once businesses take that approach, it becomes much more manageable. And importantly, it allows them to move from reacting to the regulation to proactively shaping how they manage stock returns and circularity too.

WTiN: That all sounds great obviously such a thing to aspire to in the industry. And obviously right at the beginning you broke down the ESPR regulations and explained what's coming in. Ultimately, this is quite a big question, what do you envisage the long term impact of ESPR regulation being?

Campanella: So the big dream and the long Term is for ESPR to be a real catalyst for systemic change across the industry. And ESPR goes beyond textiles too, but for our podcast today, we'll focus solely on textiles. At a high level, it's a central part of the EU's wider push towards a circular economy. It's designed to improve the sustainability, durability, and circularity of products placed on the market, but its impact goes far beyond individual requirements. So, what we'll see is a fundamental shift in how Products are designed, produced, and managed throughout their lifecycle. Businesses will need to move away from a linear take make waste model towards one where products are designed for durability, reuse, and recyclability from the outset. And it's also going to drive a much higher level of transparency. Tools like the digital product passport will require businesses to have far better visibility over their materials, and that will ultimately reshape how those supply chains operate. And then from a market perspective Will help create greater consistency across the EU, reducing fragmentation between member states while also creating new opportunities in areas like repair, resale, remanufacturing, recycling.

So, there's a strong economic as well as environmental dimension to this. Ultimately, I think the biggest shift is that compliance itself won't be the differentiator anymore. Almost all businesses will have to meet these requirements. What will set them apart? Part is how effectively they respond. Those that embed circularity in their operating Model early will be much better positioned, both from a resilience perspective and in terms of long term competitiveness.

WTiN: Thank you so much, Amy. And I love the fact that you've touched upon different regulations that are coming in, such as digital product passports. And right at the beginning, you know, you mentioned obviously your area of focus is on extended producer responsibility. With this in mind, are there any other regulations that You believe the industry needs to be focusing on now?

Campanella: Well, Abigail, as you mentioned it, and it is my focus area textile EPR is probably the most important area businesses should be forward planning right now. So while ESPR is setting the direction, textile EPR will drive the operational and financial reality for the industry. We already have four countries with established textile EPR systems France, the Netherlands, Hungary, and Latvia. But what's really significant is the EUI directive, which requires all member states to implement textile EPR legislation by June 2027, that's one year from now, and then be fully operational by April 2028. And we're already seeing momentum build. Countries like Italy and Spain have draft decrees, while Germany and Ireland have published frameworks, and this is not limited to the EU. Markets like Norway and even California are moving in the same direction. However, at an EU level because this is a directive and not a regulation, each member state will implement it in their own way. So while it's a push towards harmonisation, national variations will remain, particularly around fee structures, reporting requirements, and operating models. So this creates a level of complexity that businesses really need to start preparing for now.

And the most important first step is understanding where you're placing products on the market because obligations will apply on a country by country basis. And importantly, there is no minimum threshold for tech selling PR, so all businesses are in scope, even if you just sell one product direct to a consumer in a jurisdiction within the EU. From there, it's about building the foundations early. That includes getting visibility over product weights and material composition, as fees are very likely to be based on weight, and starting to model the potential cost implications across the different markets. And there's also a real opportunity at this stage to engage in the policy development process. Businesses can do that either through industry associations or by working with producer responsibility organisations like our Redress Producer Responsibility organisations, which we have across Europe, including Italy, Germany, Austria, Poland, and Romania. And who knows, maybe someday in the UK when textile EPR is implemented here, we're already actively involved in shaping how these systems are going to be implemented. So the message is, don't wait. Textile EPR isn't a distant requirement. It's already happening in four countries and the decisions being made now really are going to shape how these systems operate in years, for years to come.

WTiN: Thank you, that's great. Like we've I must say it's something that I am hearing a lot about when we are speaking with our members and with the industry. But just to round this up my final question is, and I feel you've given us so many fantastic pointers already, but in your opinion how can textile businesses futureproof their products and supply chains?

Campanella: Futureproofing It really is proofing, it really comes down to designing for where regulation is going, not where it is today. So, under ESPR, we're starting to see a much broader set of eco design requirements come into play. These will increasingly focus on things like durability, repairability, recyclability, and overall environmental footprint of products. So, in practice, that means businesses will need to think much more holistically about product design from materials and construction through to end of life. And what's particularly important is how this links to textile EPR. As eco design requirements become more defined through delegated acts, they are very likely to shape eco modulation criteria. In other words, products that are more durable, easier to recycle, or made with recycled content will likely attract lower EPR fees, while those that hinder the recycling process, such as multi material blends or certain embellishments like sequins, could be penalised.

And we've already seen versions of this in France where eco modulation has included incentives for durability and recycled content alongside penalties for features that disrupt the recycling process. And while that system in France is currently under review, it's currently the only system we have for eco modulation for textiles, and it gives a good indication of the direction other member states may follow. So, from a practical perspective, this means businesses need to start building in the right foundations now, particularly around data and design. That includes having Clear visibility over product composition, material use and weight, as well as embedding design principles that support circularity just from the start. And this is where tools like our Insight Platform come in. Our Insight Platform, it allows businesses to analyze product composition, recyclability, and EPR cost exposure across multiple markets in one place. So combining large scale product data with regulatory insight. It helps teams model design changes, forecast EPR fees, and identify opportunities to improve both sustainability performance and cost outcomes. But taking a step back the priorities for businesses are quite simple build strong data and traceability across your supply chain, design for durability, repairability, and recyclability.

Keep an eye out for those delegated acts and what that design criteria is going to be. Plan for EPR cost impact early. These fees are going to be huge, and particularly as eco modulation develops, so you can see where to take advantage of the bonus malice system. And then, yeah, embed circularity into operating models, not just as add ons. Ultimately, the businesses that are going to be best positioned are those that are aligning product design, data, and compliance from the start. So they're not just meeting requirements, but actively benefiting from them.

WTiN: Thank you so much, Amy. Thank you so much for joining me on WTN's textile podcast.

Campanella: My pleasure.

WTiN: It's been incredibly insightful. I feel you've given us so many things to think about and so many solutions. And I will be linking to Reconomy and different resources that you've mentioned in the article.

Campanella: Great. Thank you. It's been a real pleasure. Thank you for having me on the .

WTiN: Thank you listening. If you have any questions or want to learn more, you can follow us on LinkedIn at World Textile Information Network or you can contact me directly at content at wtin.com If you are interested in sponsoring an episode of the podcast, please email sales at wtin.com Thank you and we'll see you next time.