RESPONSIBILITY · LAYER 4 OF START
Policy and regulatory advisory. We help governments, national programmes and NGOs design the Digital Product Passport frameworks, Extended Producer Responsibility systems and circular policy that actually work — grounded in the real cost of recovery, and built with the people the rules affect, not in isolation from them.
Accountability tells you what things cost. Responsibility is what you do with that knowledge — the frameworks, obligations and partnerships that govern a circular system. And this is where good intentions most often break: policy written before the infrastructure it depends on has been costed. Extended Producer Responsibility schemes set without knowing what textile recovery actually costs downstream. Recycling targets legislated with no financing model for the sorting and fibre-to-fibre processing needed to meet them.
The result is rules that look complete and function poorly — and a receiving end, often in the Global South, that had no seat at the table when they were written. A scheme that doesn't finance the recovery it mandates doesn't only fail morally; it fails fiscally — the targets are missed, the money funds paperwork, and the policy is reopened within a parliament. We believe a circular economy has to be built with those it affects, not applied to them, and that policy cannot be designed until the system beneath it has been costed from collection to recycling. That principle sits behind everything we advise.
Responsibility is where measurement becomes mandate — designed to hold, not to be redrafted.
We do not observe this from the outside. We sit where the standard is written and where the rules land hardest.
UN/CEFACT
A seat on the working group shaping the global transparency standard (UNTP).
Landfills2Landmarks
Vice-Chair of a UN-accredited NGO delivering Extended Producer Responsibility frameworks in Ghana, where the rules land hardest.
UK government
A formal Digital Product Passport legislative architecture, submitted to DSIT, OPSS and the House of Lords.
Accra, 2026
The Landfills2Landmarks Global Summit, bringing the receiving end into the room.
We design the rules, and the relationships, that make a circular system govern — and hold up when the money and the mandate are real.
National Digital Product Passport framework design — We help governments and national programmes design DPP frameworks that align with the EU regime and the emerging global standard without merely importing them — interoperable abroad, workable at home, and grounded in what recovery actually costs. A framework that travels with trade, rather than one that has to be renegotiated at every border.
Extended Producer Responsibility architecture — We design EPR systems from the economics up — what recovery costs, who pays, and how the money reaches the collection, sorting and recycling it is meant to fund — so the scheme finances the outcome it promises rather than the paperwork around it. Schemes that hit their targets are schemes that don't get reopened.
Formal regulatory submissions — We write the evidence-based submissions that put a defensible position in front of government — consultations, position papers and legislative proposals — argued from data and the real mechanics of recovery, not advocacy alone. The kind of submission that earns a hearing, not just a filing reference.
NGO partnership strategy — Policy that ignores the receiving end fails at the receiving end. We design the NGO and Global South partnerships that bring the downstream into the design — so the people who handle the world's discarded textiles help write the rules that govern them, and the scheme works where it actually has to work.
START is a sequence. You cannot set obligations you cannot measure — which is why Responsibility follows Accountability. And responsibility without delivery is only declaration — which is why Transition comes next. This is the layer where measurement becomes mandate: the rules, the financing and the partnerships that decide who is answerable for what, and make the whole system obligatory rather than voluntary.
NEXT LAYER
Rules only matter if people act on them. The final layer turns obligation into practice. That is Transition — adoption, behaviour change and the capability to make it stick.