Circularity by Design: A new EPR fee framework for high- performance textiles and circular business models

Main Presenter:    Milena Amaral 

Co-Authors:                                                  

The textile industry stands at a decisive moment. European policy frameworks, the Ecodesign for Sustainable Products Regulation, mandatory Extended Producer Responsibility for textiles, and the Digital Product Passport, are converging to reshape how products are designed, produced, and managed at end of life. Yet current EPR fee structures offer significant room for deeper integration with circular economy objectives: they cover collection and recycling costs but treat all products equally, regardless of durability, material complexity, or recyclability. They do not reward high-performance design, finance innovation, or prevent the rebound effects that undermine environmental gains.
This presentation introduces the Trusted Eco-Modulation Equation, a fee structure engineered for impact. Under development within the TRUSTex project (GA #101181901), this framework translates circular economy principles into economic signals driving upstream design decisions. The equation comprises six integrated building blocks: (i) baseline cost recovery ensuring stable system financing; (ii) innovation and infrastructure financing through surcharges linked to product attributes and environmental impact coefficients; (iii) circular design incentives rewarding durability, repairability, mono-materials, and safer chemistries; (iv) a volume safeguard preventing rebound effects when sales growth outpaces lifetime extension; (v) social value and planetary boundary adjustments aligning fees with environmental limits and just transition goals; and (vi) governance mechanisms ensuring transparency, auditability, and adaptive recalibration.
The framework is designed for high-performance textiles with circularity in mind. It recognises that regenerative materials, design for disassembly, and fibre-to-fibre recyclability represent genuine value that fee structures should acknowledge. Producers investing in circular business models and take-back systems receive tangible economic recognition through reduced fees, while products hindering circularity contribute more to system costs.
Critically, the equation incorporates place-based realities. End-of-life management differs across regions in infrastructure capacity, labour conditions, and environmental pressures. Fees are paid where products are placed on market, but impact modelling reflects actual treatment conditions wherever textiles are managed, preventing burden-shifting to regions without adequate processing capacity.
For industry, the strategic case is clear. Eco-modulation transforms EPR from compliance cost into competitive advantage, rewarding circular design, financing innovation, and generating auditable impact data that green bond frameworks demand. The Trusted Eco-Modulation Equation aligns with the Clean Industrial Deal’s vision: a European textile sector that is decarbonised, resource-efficient, and globally competitive, while delivering measurable social outcomes including job creation, skills development, and fair working conditions throughout the value chain. This framework bridges regulation, competitiveness, and value creation, positioning industry to lead the transition toward regenerative and equitable systems.

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