Regulatory compliance
Circular returns are shifting from ESG nice-to-have to compliance must-have.
Five EU regulations coming into force between 2023 and 2027 directly target how fashion retailers handle returns and unsold stock. Forwarding was built with compliance in mind, with the methodology supported by independent research.
Compliance as competitive advantage
The retailers who get this right go first.
Most retailers will treat the 2026 EU regulatory wave as a compliance project: do enough, by the deadline, to avoid penalties. A smaller group will treat it as a commercial opportunity: restructure operations ahead of the deadline so the resulting position becomes the new competitive baseline. The retailers in the second group are the ones working with us now. CSRD reports filed with measurable Scope 3 reduction read differently from CSRD reports filed under deadline pressure. Sustainability claims grounded in ISO-standard per-transaction CO₂ data hold up under Empowering Consumers enforcement in ways that offset-based claims do not. The infrastructure decisions made in the next 12 months determine which group a retailer ends up in.
The regulatory timeline
These are not distant proposals. Three are already in force.
2023
In forceUPV Textiel
Uitgebreide Producerverantwoordelijkheid Textiel · Netherlands
Dutch extended producer responsibility regulation requiring fashion brands selling in the Netherlands to take responsibility for the end-of-life of their textile products. Brands must contribute to collection, sorting, and recycling infrastructure.
How Forwarding helps
Forwarding reduces the volume of items entering the waste stream entirely. Forwarded returns reach a new consumer directly, removing them from the EPR obligation pool. This can materially reduce a brand's EPR contribution costs.
2024
In forceCSRD
Corporate Sustainability Reporting Directive · European Union
Requires large companies (and from 2026, mid-sized companies) to report on their environmental impact across their entire value chain, including returns. Return-related emissions, waste, and product destruction are all in scope.
How Forwarding helps
Forwarding generates measurable, reportable CO₂ savings per transaction, calculated according to ISO standards. Every Forward creates a documented, auditable environmental improvement that can be included directly in CSRD sustainability reports.
2025
In forcePPWR
Packaging and Packaging Waste Regulation · European Union
Sets binding targets for packaging reduction, reuse, and recyclability across the EU. Fashion e-commerce, with its high rate of outbound and return packaging, is directly in scope.
How Forwarding helps
Forwarded returns reuse the original packaging. No new packaging is required for the Forward shipment. The independent research underlying Forwarding explicitly identifies this as a PPWR-compliant practice: C2C shipments do not require new packaging.
2026
Coming 2026GCD
Green Claims Directive · European Union
Bans vague or unsubstantiated environmental claims ('eco-friendly', 'sustainable', 'green') unless backed by independent verification. Offset-based claims (such as planting trees to neutralise emissions) are explicitly prohibited.
How Forwarding helps
Forwarding's CO₂ savings are operational and measurable, not offset-based. Each Forward eliminates a transport leg and reuses packaging. The savings are calculated per transaction and verifiable. This is exactly the kind of substantiated, operational environmental claim the GCD is designed to protect. Vague sustainability claims are out; Forwarding's reporting is in.
2027
Coming 2027CDDDD
Corporate Due Diligence Directive · European Union
Requires large companies to identify, prevent, and address adverse environmental and human rights impacts across their entire supply chain, including reverse supply chains (returns). Destruction of returned goods is explicitly flagged as a practice under scrutiny.
How Forwarding helps
By rerouting returns to new buyers rather than warehouses, Forwarding eliminates the 'return to destruction' pathway entirely for Forwarded items. This directly addresses the type of supply chain harm the CDDDD targets.
Defensible methodology, documented in independent research.
“The C2C returns program complies with various European Union (EU) directives and laws, such as the Corporate Sustainability Reporting Directive (CSRD), Packaging and Packaging Waste Directive (PPWD), and Green Claims Directive (GCD).”
The research validating the Forwarding algorithm was written in collaboration with Vrije Universiteit Amsterdam and Erasmus University Rotterdam, independently reviewed before publication. For compliance officers, this means the methodology is documented and reproducible: the compliance assessment is part of the published research itself, not a post-hoc marketing addition, and it holds up under CSRD and ESPR audit.
Read the full paper →Concrete outputs for your sustainability report.
Per-transaction CO₂ savings
Every Forward generates a CO₂ saving figure, calculated in kilograms, per item, based on eliminated transport legs and avoided packaging production. ISO-standard methodology. Exportable for CSRD reporting.
Aggregate savings dashboard
Your dashboard shows total CO₂ saved, total Forwards completed, and total packaging avoided across any time period. Ready to copy into your sustainability report.
Verified, not estimated
Savings are calculated from actual transaction data: actual distances, actual items, actual shipments. Not modelled averages. Not offset certificates. Operational data.
Substantiated claims
Every environmental claim you make about Forwarding is backed by transaction data and independently validated methodology. GCD-compliant by design, no greenwashing risk.
Common compliance questions
Does Forwarding count toward our CSRD scope 3 emissions reduction?
Yes. Scope 3 emissions include value chain activities, and returns are part of the reverse supply chain. CO₂ eliminated through Forwarding (avoided transport, avoided packaging production) can be reported as a Scope 3 reduction. We recommend validating the specific reporting methodology with your auditor, but the underlying data is transaction-level and auditable.
Can we use Forwarding's CO₂ savings in our Green Claims?
Yes, and this is a key advantage. The GCD requires environmental claims to be substantiated by specific, verifiable data. Forwarding's savings are calculated per transaction from actual logistics data, not estimated or offset. This is the type of claim the GCD was written to protect, as opposed to vague claims like 'sustainable returns' without underlying evidence.
Does Forwarding help with the PPWR packaging targets?
Yes. Every Forwarded return reuses the original packaging: no new polybag, no new box. This directly reduces the volume of new packaging entering the chain. The independent research underlying Forwarding explicitly identifies this as compliant with the PPWD, which has since been succeeded by the PPWR.
We are subject to UPV Textiel in the Netherlands. Does Forwarding reduce our EPR obligation?
Forwarding reduces the volume of items that enter the waste or donation stream by rerouting them to new buyers. Items that reach a second consumer via Forwarding do not become EPR-reportable waste. The exact impact on your EPR contribution calculation depends on your specific EPR scheme administrator (we recommend confirming with them), but the directional impact is a reduction.
Is Forwarding compliant with GDPR?
Yes. Buyer and seller addresses are never shared with each other. Shipping labels are generated anonymously: the sender sees only the carrier drop-off point, and the buyer receives the parcel without sender identification. We have a GDPR-compliant data processing agreement (AVG verwerkersovereenkomst) in place covering all sub-processors.
Talk to us about your compliance requirements.
Every retailer's regulatory situation is different. Book a call and we'll walk through how Forwarding applies to your specific CSRD reporting scope, EPR obligations, or Green Claims strategy.