Part 4 of 5: What matters most for Europe’s circular economy in 2026
In Parts 1, 2 and 3, we looked at the macro shift into enforcement — the data spine and customer participation that make circular systems work.
This post is about the moment of decision most brands avoid saying out loud:
What happens to a product after take-back — and who decides if it’s reusable or waste?
Why routing matters more in 2026
In 2025, Europe saw rising textile collection volumes.
But behind the scenes, too many systems relied on a shrug:
“We send it somewhere, and hope for the best.”
In 2026, that’s no longer viable. Cross-border controls are tightening.
Regulators are asking more complicated questions.
And customers are starting to ask the most obvious one:
Where does it actually go?
The shift: Enforcement is moving upstream
This year, we’ll see more attention on the actual routing of collected products.
That means being explicit about:
- What qualifies as reuse
- What requires repair or refurbishment?
- What becomes waste
- Where it’s sent — and with what evidence
Why? Because the EU is closing the loophole that allows “reusable” claims to mask the export of unusable textile waste, especially to the Global South.
Three decisions brands need to make in 2026:
- What’s your reuse criteria?
What qualifies a returned product for resale or donation?
Is it based on:
- Condition?
- Brand policy?
- Third-party grading?
This needs to be codified—not case by case.
Because when reuse is subjective, credibility collapses.
Tip: Align with partners on standard grading criteria (e.g., A/B/C condition, resale vs. donation vs. repair).
- Who makes the routing call?
Is it:
- Store staff?
- A refurb partner?
- A sorting facility?
If you don’t define the decision-makers and their criteria, you’ll struggle to:
- Prove compliance
- Optimise routing
- Understand real reuse rates
In 2026, regulators will start asking who decides — not just what happens.
- What proof backs your claim?
Whether for a green claim, EPR report, or customs checkpoint, you'll need to show:
- What was routed
- To where
- For what purpose
- Under what standard
That means evidence:
- Item-level or batch-level data
- Partner documentation
- Photos or grading logs
- Chain of custody for exported material
No more plausible deniability.
From hopeful to defensible: building a credible routing system
What this looks like in practice:
- Clear internal routing decision trees
- Partner SLAs with grading criteria + documentation
- Minimum data capture at handover points
- Export due diligence based on OECD rules and Basel clarity
This isn’t just about avoiding fines.
It’s about building system credibility — with regulators, partners, and customers.
The brand opportunity: Own the story, not just the compliance
2026 isn’t just a risk — it’s a reset moment.
Brands that lead here can show:
- Circularity at work
- Responsible treatment of collected items
- Real volumes diverted from landfill
- Avoidance of harmful downstream impacts
But it only works if the reuse vs. Waste line is tangible—and visible.
Coming next: Part 4 — How to future-proof your circular offer
In the final post, we’ll examine what happens as schemes mature, claims tighten, and product rules expand.
What can you build now to avoid compliance chaos later?
Circularity, Made Simple.
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