From Compliance Burden to Competitive Edge: What Eco-Modulation Could Mean for Your Brand

At the dawn of HappyPorch Radio’s 10th season, it feels like a moment worth pausing to acknowledge. Ten seasons of conversations that now orbit the intersection of technology and the circular economy, and if this latest episode is any indication, the questions are only getting more interesting.

This season is called "Technology Isn't Magic", a deliberately grounded provocation. It's about what actually happens when circular economy ideas meet the messy reality of real businesses, real data, and real people. No silver bullets. No shortcuts. Just the honest, often complicated work of figuring out what's possible.

This episode embodies that spirit completely.

EPR: A Tax, or an Opportunity?

When most brands hear the phrase Extended Producer Responsibility (EPR), they reach for the word compliance. Another regulatory burden. Another cost of doing business in an increasingly scrutinised world.

Gerrard Fisher, co-founder of WEFT, thinks that framing is both understandable and wrong. And we think he's onto something important.

EPR, at its core, is a straightforward idea: the people who put products into the world should bear some of the cost of what happens to those products at the end of their lives. Right now, much of that cost lands on local authorities, taxpayers, and overstretched waste systems. EPR is an attempt to redirect it to the right place.

The concept is already well-established in electronics, batteries, and packaging. You might already be paying a small fraction toward future recycling every time you buy a sandwich at the supermarket. Now it's moving into textiles: clothing, home linens, workwear, footwear. Products that are, as Gerrard puts it, "very complex to deal with at the end of life."

The timing matters. Global clothing consumption has roughly doubled since 2020. The value of collected secondhand clothing has fallen sharply because there's simply so much of it. Charity collection banks are disappearing from street corners because the economics no longer work. The system is under real strain, and the funding to fix it has to come from somewhere.

What WEFT is working on is making sure that when EPR for textiles arrives in earnest, it doesn't just become a blunt tax. Designed well, it could become something far more useful.

What Is Eco-Modulation, and Why Does It Matter?

Eco-modulation is the idea that EPR fees shouldn't be flat. A cotton T-shirt with no synthetic prints, highly recyclable and destined for mechanical recycling, shouldn't carry the same charge as a complex garment blended with elastane, coated in vinyl, and practically impossible to recycle. One costs more to deal with at end of life. One creates more systemic burden. The fee should reflect that.

One challenge has always been the data. Previous attempts to build individualised product-level pricing (going back as far as the original Waste Electronics Regulations in 2005) ran into the sheer complexity of assigning scores to millions of distinct products across thousands of brands, each with their own categorisation systems and data formats.

WEFT's argument is that this problem is now solvable. The data most brands already hold about their products is sufficient to begin meaningful scoring. Using incomplete data now is better than doing nothing, as long as it's treated as a step towards improving that data over time.

A garment's material composition, cotton versus poly-cotton versus polyamide, tells you a great deal about its recyclability. And crucially, that information doesn't have to be forced into someone else's taxonomy. WEFT works in a brand's own language. 

"Every brand has its own menswear, womenswear, tops, bottoms, sportswear categories," Gerrard explains. "We can match that language. And then it does two things for them. First of all it's like a complete circular map of all their products, which are the best, which are the worst, and why. But then secondly, you can start to project that onto this sort of eco-score or eco-modulated fee and show them how their well-performing products could have a much lower charge when they go onto the market."

The data also surfaces unexpected insights. One brand WEFT worked with discovered that their denim and basic cotton pieces, the products most people assume are the problem, were already scoring well on recyclability because of their relatively pure fibre content. The real challenges lay in more complex, multi-material products that had flown completely under the radar of their sustainability conversations. That kind of clarity is genuinely hard to get any other way. 

What Customers Would Actually Notice

Perhaps the most striking finding from WEFT's research concerns not brands or policymakers, but shoppers.

Much of the policy debate around EPR has centred on keeping fees low enough not to affect consumer behaviour, with figures in the range of a few pence per garment being floated in various European markets. WEFT set out to test whether those numbers reflected what shoppers actually experience.

The results were surprising. When asked directly, British clothing shoppers said they wouldn't even notice 50 pence being added to the price of a garment, across the full spectrum of price points from budget to premium. WEFT then tested charge levels from 10 pence up to £2.30, measuring how different amounts affected purchase choices between products at different price points.

EPR charges up to 50 pence had almost no effect on what people chose to buy. Above that threshold, something changed. Shoppers began to factor the charge into their decisions and, fascinatingly, some would choose a more expensive item with a lower eco-charge over a cheaper item with a higher one.

"Once it goes above 50 pence," Gerrard notes, "they start to notice it and they start to select other products with a lower charge, even if that item is more expensive, they'll go for the one with a lower charge preferentially. Because price is the top motivator in selection."

This suggests the gap between what policy discussions assume consumers will tolerate and what they'd actually accept is quite substantial. A well-designed eco-modulation system, visible on the price tag, could meaningfully shift market dynamics. Not through heavy-handed regulation, but through a transparent price signal that lets customers make genuinely informed choices.

Three in four survey respondents grasped the concept immediately after reading a short explanation. Eight in ten said they'd want to see it on the price ticket. Even heavy shoppers, the ones buying ten items a week, said they'd welcome the information, even if it didn't always change their decision.

Independent, verifiable, and linked to a real cost: that's a very different thing from a voluntary green claim on a hangtag.

The Strategic Picture Brands Are Missing

There's a version of the EPR story where brands wait for legislation to be finalised, then scramble to understand what it will cost them. WEFT is making the case for a different version, and we find it compelling.

The brands most likely to benefit from eco-modulation are the ones designing better products now. The data work required to understand those products' circular credentials doesn't need to wait for any government announcement. The analysis that tells you your eco-modulation score also tells you which product lines are most worth redesigning, which materials are worth prioritising, and where your supply chain has the most room to improve.

As Gerrard put it succinctly in a WEFT blog post: "Many brands are focused on next week's figures rather than the strategic picture." For those willing to take the longer view, though, the case is clear. A brand with 10 or 20 million pounds of potential EPR liability in four years has a very real financial interest in understanding that number today, and in understanding how to bring it down.

The system WEFT is building also has implications beyond the individual brand. Aggregated, anonymised product data creates a picture of national textile flows: how much pure cotton, how much polyamide, how much blended fabric is entering the market. That's the kind of information needed to make sensible decisions about recycling infrastructure, which facilities to build, which processes to invest in, which materials to prioritise for collection and sorting.

"The same data can serve lots of different purposes," Gerrard observes. And right now, most of it is sitting untouched in brand systems.

Building the Tool: An Honest Account of AI Coding 

Here's where the story gets personal, and we think genuinely instructive for any small team trying to build something new.

WEFT's product centres on a dynamic data visualisation: a bubble chart in which each product in a brand's portfolio appears as a point in space, its position and size indicating where it sits on the circularity spectrum. Brands can filter by category, toggle different scoring dimensions, and watch their portfolio rearrange itself in real time. The aim is to make complex, multi-dimensional data immediately legible.

Getting from spreadsheet outputs to that kind of interactive tool is not trivial. Professional development takes time and money that early-stage startups rarely have in abundance. So Gerrard did what an increasing number of non-technical founders are doing: he opened an AI coding tool and started asking questions.

"It's like searching a room with a torch," he reflects. "You're trying to find something, but you're only looking at a little bit of the problem at a time."

The process got them somewhere. A working prototype, good enough to demonstrate the concept to potential clients, to get real reactions, to understand what actually mattered in the interface. As a validation tool, it served its purpose well.

But it had a ceiling. "I had no idea what the code was doing," Gerrard says plainly. "It got to the point where, if I tried to change anything, it stopped doing stuff properly. Under the bonnet, it's really not put together very well." The code was doing several things in several different places; fixing one would break another. The tool they used couldn't even label its own sections to explain what each part did.

This is the honest reality of what's sometimes called "vibe coding": using AI to build functional software through iteration rather than deep understanding of the code. The output can be impressive. But it can also be, as Gerrard puts it with characteristic directness, "a clapped out old banger."

That's when WEFT came to us.

Knowing When to Call in the Professionals

What we find most instructive about this handoff isn't that the AI approach failed for him. It's that it succeeded at exactly the right thing, for exactly the right duration, and that Gerrard recognised the boundary.

The prototype had proved the concept. It had helped crystallise the specification. Rather than arriving at HappyPorch with a vague idea, WEFT arrived with something that looked and felt like the destination, just fragile, unmaintainable, and not ready for clients. "You are refining rather than speculating on what the design is," Gerrard observes. "Refining, talking about colour decisions and layouts and things. But actually the underlying functionality is what's really important."

Working together, we rebuilt the tool as a hostable, maintainable, extensible version of the same visualisation, one that can be updated as the methodology evolves, shared with clients, and iterated on without the risk of everything breaking at once. The distinction matters: a proof of concept has very different requirements from a production tool, and conflating the two is a common and costly mistake.

Reflecting on the process, Gerrard's main note to his past self would be to research dedicated coding AI tools more carefully before starting, understanding which tools are best suited to which kinds of development tasks, and how to prompt for cleaner, better-documented output. The exploration itself, though, he wouldn't undo. "Learning what did and didn't work was actually quite useful knowledge for us."

For circular economy startups navigating similar decisions, we'd echo that sentiment and add one thing: the goal of the prototype stage isn't a finished product. It's learning. AI coding tools are genuinely powerful accelerators for that. But they don't always replace the expertise needed to build something solid and lasting. The art is in knowing when you've extracted the value from the prototype stage, and when it's time to invest in the real thing.

What's Next

WEFT is now moving toward adding cost projections directly into the tool, converting eco-modulation scores into pounds and pence (or euros, or dollars), so brands can see order-of-magnitude impacts in terms that finance teams can act on. The difference between a projected liability of 20 million and 15 million may be a very different kind of conversation from a circularity score on a dashboard.

On the policy front, the UK's Circular Economy Taskforce review (originally expected in September 2025) remains outstanding as of March 2026. The Netherlands is moving toward eco-modulation implementation soon. California's textiles EPR scheme is targeting 2030. The regulatory environment is moving, even when it moves slowly.

For any brand selling into European markets, Australia, or California, or simply waiting on the UK announcement: the time to understand this is before the legislation lands, not after. The data work takes time. The design conversations take time. The brands that engage now are the ones most likely to have a voice in how these systems get shaped, and most likely to benefit when they do.

We'd encourage you to reach out to WEFT directly if any of this resonates. And if you're at a similar stage to where Gerrard was with his prototype, wondering whether to keep iterating on your own or bring in development support, we're always happy to have that conversation too.  

WEFT helps brands explore the circularity of their products and understand the potential impact of eco-modulation on future EPR fees. Find their research, methodology, and contact details at weft.org.uk.

HappyPorch Radio is our circular economy technology podcast, now in its tenth season. New episodes, full transcripts, and show notes at happyporchradio.com.