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Part 2 of 5: What matters most for Europe’s circular economy in 2026

In Part 1, I said 2026 is the year Europe’s textile circular economy gets real.
Not as a single law or deadline — but as a system tightening around product design, marketing claims, end-of-life responsibility, and cross-border controls.

This post is about the quiet infrastructure move that makes everything else work:
The product data spine.

Circularity doesn’t scale without structured product data

Every take-back bin, resale platform, EPR scheme, and recycling facility has one thing in common: they rely on accurate, usable product-level data.

In 2026, these shift from compliance afterthoughts to core enablers.

Because without structured product data:

  • You can’t report accurately
  • You can’t manage costs across countries
  • You can’t prove your claims
  • And you can’t route products post-use

What is a “product data spine”?

It’s the consistent set of attributes that link each SKU to its:

  • Material composition (ideally with % detail)
  • Weight
  • Product category
  • Durability or repair features (e.g. components, fastenings, repairability notes)
  • Country of sale

That’s your spine.
Everything else — from fees to resale eligibility to end-of-life routing — connects to it.

Why this matters in 2026

  1. EPR fees will need structured reporting

Europe’s national schemes will begin to diverge in how they calculate EPR fees — some by weight, others by material class, some with bonus/malus based on design.

The only way to keep cost control (and credibility) is with a data spine that makes:

  • Reporting easy
  • Fee modelling transparent
  • Downstream systems compatible

If you don’t build this now, you’ll be chasing retroactive fixes in 2027–2029 — when the real cost kicks in.

  1. Incentives depend on a traceable design

Want to unlock fee reductions or reuse bonuses?
You’ll need to prove design features like:

  • Durability
  • Recyclability
  • Repairability

That data can’t live in PDFs or across 12 supplier spreadsheets.
It needs to link to SKUs and be structured enough to move through systems.

  1. Without the spine, circular claims fall apart.

The marketing environment is tightening — and “circular” claims are under objective scrutiny.

Whether you’re making a resale, repair, or recycling claim, the questions will come:

  • What product?
  • What materials?
  • What treatment?
  • What outcome?

Without the data spine, these questions are hard to answer — let alone verify.

What to do now: 3 steps to build your data spine

Step 1: Define your minimum viable attributes

Start small but standard. Decide what your system needs at a minimum:

  • Material composition
  • Weight
  • Product category (mapped to EPR or waste codes)
  • Durability/repair features
  • Country of sale

Build this into your product master data model — not a separate ESG tracker.

Step 2: Map ownership across teams

Who enters what, and when?

  • Product design: materials and repairability
  • Buying: country-specific tagging
  • Tech: how data is stored and passed through
  • Sustainability/compliance: schema and reporting

Without clarity on ownership, spines break down before they connect.

Step 3: Make it usable downstream

This is where many brands fall short.

You don’t just want a database. You want a data spine that powers systems:

  • EPR reporting
  • Take-back eligibility
  • Reuse vs waste routing
  • Customer-facing apps or receipts

If the data doesn’t move, the system doesn’t work.

Remember: Data is the compliance currency of circularity.

Product-level data will become the way brands:

  • Manage circular costs
  • Earn incentives
  • Prove claims
  • And future-proof retail systems

This is infrastructure. And 2026 is the time to build it — before enforcement catches up.

Coming next: Part 3 — Take-back customers actually use

We’ll go deeper into the customer side of circularity: how to make take-back so easy, clear, and credible that participation rises and contamination drops.

Circularity, Made Simple.

Tim Lee
Post by Tim Lee
Jan 7, 2026 8:30:00 AM
Tim Lee founded Utilitarian to solve a challenge he saw again and again — brands and retailers wanting to meet their sustainability goals, but missing the connection with the customers who could help them get there. Starting in Australia and now based in the Netherlands, Tim has spent years learning how to make the “right thing” the easy thing, building systems that turn product returns into loyalty, measurable impact, and real data. He’s passionate about working with the system, not against it, and believes the circular economy only works when everyone — customers, brands, and the planet — wins.