What We Heard at the Innovation Forum: EPR, DPP, and the Compliance Infrastructure Gap

Our team attended the Innovation Forum in Amsterdam. These are the signals that matter for sustainability and compliance teams.

DPP, EPR, and ESPR are one system

This was the clearest and most consequential message from the Forum. The EU has deliberately designed Digital Product Passport, Extended Producer Responsibility, and the Ecodesign for Sustainable Products Regulation as a single interconnected compliance system. The data collected for DPP feeds EPR reporting. Eco-design requirements under ESPR define what DPP must document.

Brands building separate compliance streams for each are duplicating infrastructure and missing the integration point — which means more cost, more overhead, and a harder pivot when requirements tighten.

A first draft of DPP data points is expected from the EU within weeks, giving teams the first concrete picture of exactly what data will be required. A security of supply regulation list will also be published by end of June, clarifying which product categories and materials fall under new traceability requirements. The EU is also building public datasets to help smaller brands meet DPP requirements — worth tracking as a compliance resource.

The Commission’s framing positions DPP as a tool for European competitiveness and internal market coherence, not solely as an environmental instrument. That framing matters for how compliance teams make the case internally.

EPR deadlines are closer than they appear

Extended Producer Responsibility becomes mandatory across the EU on 1 January 2028. That date sounds distant. The operational data infrastructure required to comply takes years to build, and most brands are already behind.

Global brands are currently filing 25 or more separate EPR reports per year, across jurisdictions with different data formats, different targets, and different deadlines. The Netherlands currently operates the most advanced textile EPR scheme in Europe and is being used as the reference model for harmonisation. The Circular Economy Act, when it arrives, is designed to align EPR schemes across member states — reducing that fragmentation over time.

One distinction that is frequently misunderstood: the EU’s ban on destruction of unsold goods covers recycling. The Commission’s position, confirmed at the Forum by Matjaz Malgaj of DG Environment, is that recycling overproduced goods falls within scope. The regulatory goal is upstream prevention — producing less in the first place.

Textile-to-textile recycling is being explicitly differentiated from other recycling categories under ESPR and will likely be scored more favourably under eco-modulation, making it the commercially preferred end-of-life route. This distinction matters for brands making end-of-life claims or planning product take-back programmes.

Regulatory postponements were flagged at the Forum as a structural problem. Every delay removes the incentive for early investment and creates a cycle of last-minute compliance work that costs more and delivers less. Teams that treat postponements as runway are building in risk.

The audit model is under pressure

The conversation on audit and supplier dynamics was the most candid of the Forum. The market is moving from audit-as-control toward audit-as-collaboration.

The blunt signal from the floor: document fabrication is widespread precisely because suppliers feel surveilled, not supported. That dynamic does not get fixed by more audits. It gets fixed by changing the relationship between brands and their supply base.

A structural tension runs deeper. Suppliers serving multiple brands are navigating contradictory instructions from the same organisations — purchasing teams demanding lower costs while sustainability teams demand higher investment. Speakers identified this as the single biggest obstacle to real compliance progress. Resolving it requires alignment at the brand level, not at the supplier level.

Extreme heat in factories is also an emerging issue that most current audit standards do not yet cover. Factories in key sourcing countries were not built for current temperatures, cooling infrastructure is outdated, and suppliers are being asked to choose between worker health upgrades and brand compliance costs. Audit frameworks that do not account for this are measuring an incomplete picture.

Fibre claims face a harder standard

The Commission made clear that material origin alone does not establish sustainability. Natural fibres carry environmental trade-offs — cotton can carry high chemical loads and significant water intensity. A formal lifecycle-based taxonomy for fibres is in development, and brands making material sustainability claims should expect this to become the regulatory benchmark.

The Commission also confirmed that synthetic fibres are being factored into eco-modulation design as a structural driver of overproduction. Brands whose sustainability communications rely primarily on material origin claims will need to recalibrate as the taxonomy takes effect.

The regulatory environment is becoming more integrated, more data-intensive, and less forgiving of fragmented approaches.