This is the first post in a short 5‑part series I’m publishing over the next two weeks. The goal is simple: identify the few focus areas that matter most for 2026, then conduct deeper dives so you can prioritise action (without drowning in policy jargon).
It’s the start of 2026, and if you work in fashion retail or brand-side sustainability, you’ve probably got “circular economy” sitting somewhere between essential and too hard to operationalise right now.
Here’s the shift: 2026 is the year Europe moves from strategy and proposals into operational enforcement. Not in a single dramatic moment, but through a steady tightening across four fronts that will be very visible to brands, retailers and consumers:
If you’ve been waiting for “the final rules” before taking action, this is your nudge: in 2026, the gap between good intentions and operational reality will start to cost money.
The context: 2025 created a river of textile waste
A useful way to think about 2025 is this: Europe created a visible river of textile waste—and then had to admit the downstream infrastructure wasn’t yet in place. More collection, more public attention, more pressure… but not enough sorting capacity, not enough high-value reuse pathways, and not enough recycling capability at scale.
When volume rises faster than infrastructure, two things happen quickly:
That’s why 2026 feels different.
What you should do in 2026 (even though big EPR deadlines land later)
Quick reset: EPR (Extended Producer Responsibility) means brands (and sometimes retailers, depending on how a market defines “producer”) help fund and organise the end-of-life management of products after use. In textiles, the big scheme deadlines are generally 2027–2029, depending on country and business size — but waiting until then is how you end up in a rushed, expensive compliance scramble.
In 2026, I’d focus on three practical decisions.
1) Build the “data spine”
This is not glamorous, but it’s where everything else becomes easier (or impossible). You want a consistent way to link each SKU to:
Why it matters: future fees and incentives only work if reporting is consistent — and you’ll be doing it across multiple countries. If your product data is messy, you’ll struggle to (a) report, (b) manage costs, and (c) prove anything you’re saying to consumers.
2) Design the customer return / take‑back experience as if it affects your P&L
Because it does.
In-store drop. Mail-back. Partner drop points. Repair or refurb options. The channel matters less than the outcome: take‑back needs to be easier than disposal, and it needs to be clear enough that customers don’t dump the wrong stuff in the wrong place.
Why it matters: collection volume and contamination drive sorting costs—and sorting costs are one of the fastest ways circularity becomes a budget problem rather than a brand story.
3) Decide your stance on “reuse vs waste” routing (and be ready to stand behind it)
This is the part many programs avoid saying out loud: not everything collected can be reused, and not every “reuse” pathway is credible.
In 2026, enforcement trends and cross‑border controls will push companies to be explicit about:
Why it matters: “We send it somewhere and hope for the best” won’t survive scrutiny — and it won’t survive a customer who asks the obvious follow-up question.
How to talk about it (so ESG, compliance, marketing and sales can move together)
Three principles I’ve seen work across mixed teams:
The bigger implication for major brands and retailers
This is the year circularity stops being a sustainability programme and becomes an operating model:
What’s coming in the rest of this series
Over the next two weeks, I’ll publish four follow-ups: