Circular Economy Exchange: March 2026 Key Takeaways

The latest Circular Economy Exchange session centred on a draft white paper by Dr Erik Jacobi and Dr Jordon Lazell (University of Essex), exploring how the UK should respond to upcoming EU Digital Product Passport (DPP) requirements.

Compliance is becoming a trade issue

The strongest signal from the session was not sustainability – it was market access.

EU alignment is becoming essential for brands selling into Europe, bringing with it increasing complexity around supply chain data and product-level information.

For most businesses, the question is no longer if DPP matters, but: how to remain compliant without disrupting operations

Avoid overcomplicating the starting point

There was broad agreement that early implementation needs to be pragmatic.

Rather than attempting to define a complete solution upfront, the proposed direction is to:

• establish a baseline framework
• introduce limited, practical data requirements
• expand capability over time

This reflects a clear lesson from previous regulation: overly complex systems slow adoption and create unnecessary friction.

Enforcement is closer than expected

Examples shared during the session suggest that enforcement is already taking shape:

• Non-compliant products have been removed from shelves in France
• Cross-border shipments have been disrupted due to regulatory interpretation
• Larger organisations are likely to face penalties within the next 12–18 months

The shift from guidance to enforcement is already underway.

Data is the real challenge

While much of the conversation around DPP focuses on technology, the session highlighted a more fundamental issue: data* quality and structure

Common challenges include:

• fragmented product information
• lack of standardisation across supply chains
• difficulty verifying claims

The direction of travel is clear:

• greater emphasis on third-party verification
• supplier-level validation to reduce duplication
• shared data models to improve consistency

Without this, even the most advanced systems will struggle to deliver value.

Consumers are ready – execution is the issue

Research shared during the session provided a useful reality check.

Consumers are willing to engage with product-level information, particularly when it is:

• clear
• relevant
• easy to access

Engagement rates are already strong when content is well designed.

The barrier is not adoption – it’s execution.

Commercial reality is driving change

One of the more candid insights from the session was the tension between sustainability and business priorities.

In practice:

• compliance and cost remain the primary drivers
• sustainability strengthens the case, but rarely leads it

For policy and adoption to succeed, this balance needs to be acknowledged.

The full summary is available here.

*Since the last exchange the EU JRC (Joint Research Centre) published the Methodology for defining data requirements for the Digital Product Passport under the ESPR framework.

Join us at the next CEE event:

Location: St. Annes Church [Allen Room 1st floor], 55 Dean Street, London. W1D 6AF

Date: 08th April 2026

Time: 2:00pm- 4:00pm

Topic: Key insights under the banner of Students on Circularity

Lead: Led by Heather Dupay , Fashion, Art & Design Educator, Innovator and Retail Expert at the University of West London

RSVP here.