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What Extended Producer Responsibility Legislation Means for Traceability

Traceability is a prerequisite for a brand’s commitment to transparency toward the market and its customers who are increasingly demanding product information. But how do you share information that you may not know?

That’s the whole point of traceability.

The sad reality is that traceability and transparency are still not considered a priority, however.

At the brand level, the focus is on creating, sourcing, and selling their products. At the consumer level, let’s be honest, most people base their purchasing decisions on the appearance and price of the product they are considering buying. 

As far as product information is concerned, consumers only have access to the top 10 percent of the iceberg. There is little information on who made the product—possibly on the Tier 1 supplier—but tracing the various stages of processing back to the raw materials becomes very complicated. Knowing under what social and environmental conditions the product was made is even more challenging. This must change.

So, imagine a product that can “talk” by revealing all the information accessible through a QR code. 

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It’s about respecting the consumers’ right to be informed. When information is available, consumers have, in my opinion, a moral duty to inform themselves about the product they are considering buying. The right to information also entails a duty to inform oneself.

For more than 15 years I have been saying we all have the right to know. “Let’s make the products talk.” People thought it was just a catchy tagline, but it wasn’t at all. It was more of a fixed idea. But with a little help from our friend, AI, our application will soon allow products to talk. 

Believe me, when brands large or small realize the importance of being able to better inform their customers, they will make their products speak for themselves. It will only be a matter of time. When the competition incorporates transparency into their business model, brands that were not initially convinced will have no choice but to follow or lose the market. 

That’s why I used to say: “Transparency is the most beautiful color.” 

About Extended Producer Responsibility 

The Extended Producer Responsibility (EPR) system, according to the Organisation for Economic Co-operation and Development (OECD), aims to act on the entire life cycle of products: eco-design of products, prevention of waste, extension of the period of use, and end-of-life management. It is a policy approach in which producers are given significant responsibility—financial and/or physical—for the treatment or disposal of post-consumer products.

The good news is that, in the spirit of the Extended Producer Responsibility schemes, several legislations increase (or will soon increase) this liability, including the Common Agricultural Policy Reform in the EU and the AGEC Decree about anti-waste in France this year, and the Uyghur Forced Labor Prevention Act (UFLPA) in the U.S. in 2022.

For a company, when the cost of recycling fees for its products is higher than the cost of investing in a circular economy approach, the next step becomes obvious.

Everyone is concerned—the brand owner, its suppliers, organizations active in the environmental assessment of the carbon footprint, the water footprint, and of course, the consumer.

EPR legislation goes beyond what used to be called PPP or Public-Private Partnership as, it brings together not only the public and private public sectors, but also civil society, brands, and the consumer of course.

Civil society refers to all the non-governmental associations that act as pressure groups to defend the interests of the individuals and groups it represents. Through its representatives, the activity of its associations, its trade unions, and its consumer groups, it provides the actors and counter-powers independent of the State and the market that are essential to the proper functioning of a democracy. They can, for example, influence the respect of human rights, the transformation of social relations, land use planning choices and all environmental issues.

Legislation is also evolving not only regarding EPR but also for product traceability and supply chain transparency. Since Jan. 1, 2023, a QR code has been compulsory on the clothing labels of high-selling brands in France’s clothing sector. 

For the time being, only brands with an annual turnover of more than 50 million euros ($53 million) are concerned by this new labelling, but it will be mandatory for smaller brands within three years. Among other things, this will make it possible to find out where the raw material comes from and where the product was made. 

Is the QR code a type of product passport? A real guarantee of transparency? 

Since there is no obligation for brands to have their information independently verified, let’s say it’s a start. 

What we need to remember from all this

The traceability of information is a prerequisite for any transparency approach. To monitor these complex processes, the traceability of information and its verification is key.

Transparency will soon no longer be an option but a necessity in an economy based on compliance with existing legislation such as EPR and future legislation.

Data is king. Verification is queen. A fulfilled democracy will always require respect.

I am proudly serving on the Board of Directors of the Transformers Foundation with outstanding members and a free-thinking founder.

The future is bright, that’s for sure. Don’t take my dreams away.


About the author

In 2005, Robin Cornelius founded Product DNA, – strategic advisor’s company specializing in product traceability and supply chain management, as well as supporting brands in a transparent approach. Since its foundation, 20,000 supply chains representing over 200 million items have been traced. Its digital transparency platform,, backed by its in-house developed SaaS, allows companies to better manage their supply chains.

About Transformers Foundation

Transformers Foundation is the unified voice representing the denim industry and its ideas for positive change. It was founded to provide a thus-far missing platform to the jeans and denim supply chain and a central point of contact for consumers, brands, NGOs, and media who want to learn more about ethics and sustainable innovation in the industry.

For further information, please contact Kim van der Weerd at  or Ani Wells at