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  • Writer's pictureKate Hughes


Our client, QSA Partners, is leading an industry-led project to develop a model for Extended Producer Responsibility (EPR) for the fashion industry. The UK government has identified it as a major challenge, as set out in its Policy Paper “Maximising Resources, Minimising Waste”.

Here we talk to Kristina Bull, Partner at QSA Partners, to find out all about sustainability in fashion and the EPR project.

Photo of Kristina Bull, Partner at QSA Partners

First things first…how does a trainee corporate lawyer become a circular business model expert?

I know, it’s not your typical career progression! I was set on becoming a lawyer and worked in a corporate law firm, but after the training process realised a corporate life was not for me and left.

I joined WRAP (Waste Resources Action Programme) in 2005, initially in the legal team. I was still using my legal knowledge, albeit in a better way, more aligned with my values. WRAP’s funding structure meant there were frequent reorganisations and I initially wound up in the Construction team, working to embed procurement requirements for waste reduction across major projects including the 2012 London Olympics.

WRAP was expanding and I had the opportunity to move into a project manager role; working on diverse programmes reducing carbon, waste and water impacts across different sectors. For example, I was part of the team that set up SCAP 2020 (Sustainable Clothing Action Plan, the predecessor to Textiles 2030), a pioneering industry-led action plan bringing together major fashion retailers, including Next, Marks & Spencer, Tesco and New Look, charity retailers and textile recyclers to successfully reduce the impacts of clothing consumed in the UK.

I clearly found my niche working for WRAP; engaging, collaborating and driving positive change across different industries to reduce environmental impacts sustainably, and I loved it! That said, I wanted to do more than WRAP’s charitable status and government funding would allow. So, in 2012 I decided to set up my own consultancy. I did some work for QSA Partners during this time and joined the business as a partner in 2018. The rest, as they say, is history!

What advice would you give to someone looking to get into the sustainability industry?

The industry is diverse. Take QSA Partners – our expertise is circular economy business models. We help businesses make more money from their assets for as long as possible without producing more.

I’d encourage anyone to consider what interests and drives them the most, and then explore opportunities to get involved - whether that’s in their current role, volunteering, or a particular project or field of study.

You are renowned as an apparel durability expert. What is durability, and how can retailers and brands enhance clothing durability?

There are different types of apparel durability:

  • Emotional: this is the illogical aspect as it’s about keeping something because of how it makes us feel, or what it means to us. Items are often used beyond their reasonable life. Outdoor wear is a good example, or your favourite woolly jumper!

  • Design: this is about designing an item to be durable for as long as possible. Naturally, it must be balanced and linked to the garment’s purpose. No one wants Teflon pants!

  • Repairability – this considers the ease of maintenance and minimising repair requirements. For example, poor-quality zips, stitching and even thread used can affect product quality and increase hidden production costs. Returns data is crucial for understanding design faults, financial impact of repairs and cost-benefit analyses.

It’s also important to close the loop on design. For example, I’ve worked with a leading womenswear retailer to provide visibility of design faults and help close the loop by automating its returns process.

Sustainable fashion icon

I’ve done lots of work on durability and one size does not fit all. Returns are a good place to start as the data insights can highlight product design failures, hidden production costs and improvement opportunities.

For example, working with one of the largest online fashion retailers, we established a more expensive thread and hemstitch in a pair of trousers would create savings by reducing returns – people putting their foot through the trousers often catch it on the hem.

You have managed diverse projects for a broad range of businesses. Which one stands out the most, and why?

Whilst they all stand out for different reasons, the one I’m most proud of is helping Farfetch develop its circular strategy, including setting up its take back and resale programme. It is an innovative business and is seen as an industry leader in circularity, along with Selfridges and Zalando. So, it’s rewarding knowing our work is setting the industry standard!

QSA Partners works with some major brands and partners, is a B Corp, and recently celebrated its 10th anniversary. What’s the secret of its success?

We enable businesses to establish new revenue streams from circular business models and take a holistic, commercially driven approach. We’ve brought many different circular business models to the market, across different sectors, including for some of the biggest brands and retailers.

QSA Partners has a guide to help fashion retailers and brands implement a circular business model. What’s the best piece of advice you would give to businesses starting on this journey?

Jigsaw pieces with a icon depicting circularity

To be successful it must be a commercial project and have C-suite buy-in and cross-functional team collaboration and engagement. Businesses need to be open to change.

Download the guide here.

Tell us more about the project QSA Partners is leading to develop a model for Extended Producer Responsibility (EPR) for the fashion industry.

It’s been a few years in the making so we’re super excited about it!

We’ve seen from other EPR systems, in different sectors and countries, they’re not fit for purpose. They are fixed at a point in time, are inflexible and don’t evolve with technological advances.

Take the WEEE regulations as an example. They were launched in 2007 (the same year as the iPhone) and primarily focused on white goods. Yet there are billions of smartphones in the world today – weighing very little, costing more, and using more valuable, rare metals compared to white goods. And, while the right to repair exists now, mobile companies were not required to provide repairs previously because mobile phones are not white goods.

Then there’s the packaging EPR scheme. It’s been hugely challenging and there was no real opportunity for industry to fully inform or engage with how it would work in practice. Yet packaging is only the piece protecting the product. EPR for textiles is about the product, and that is far more complex.

The point is, whilst regulations are designed to do the right thing, there are unintended consequences and we’re on a mission to avoid this in textiles. SHEIN is another example because it didn’t exist ten years ago. It’s now the world’s largest producer of apparel. We want a system that is flexible and moves with industry, not in spite of it.

Defra first announced the Government’s intention to consult on an EPR system for textiles back in 2018! Since 2020 we’ve been working to bring the industry together, so it understands the potential impacts of such a scheme and works together to ensure it is:

  • fair and balanced

  • drives the desired behaviours, and;

  • is adaptive so remains fit for purpose in a fast-changing industry.

With funding from Innovate UK’s “Circular Economy for SMEs” initiative, QSA Partners has created the EPR project with various partners (including the UK Fashion and Textile Association, the British Fashion Council, the University of Exeter, and support from the British Retail Consortium). The purpose is to lay the ground for an ERP system that will give all supply chain players incentives to ensure clothes and other textile products can be reused, refurbished, and resold.

Photo of a clothes shop window

Six large brands/retailers (including Marks & Spencer, New Look and John Smedley) are participating in the first phase to establish what data brands own and have access to that could inform an EPR system. Data is being collected and modelled to understand the impact of different levers that encourage less waste and greater collection and re-circulation of products and materials (eg. organic materials, circular fashion models, recyclability).

Datitude, as our data partner, is instrumental in this. One of the key deliverables is a data sandbox to serve as a platform for analysis and data sharing across the industry – an open, transparent system for all stakeholders.

Personally, I don’t want to see a single bit of data! Seriously though, the volumes and types of data we’re dealing with are vast, and the complex modelling requirements need to use diverse metrics and weighted criteria. The outputs need to be presented in a clear format with insights easily understood by non-data users. That’s Datitude’s expertise.

Aside from EPR, what other regulations should retailers be preparing for?

Ecodesign for sustainable products, including digital product passports.

Sign "Being naked is the #1 most sustainable option, we're #2" over a rail of preloved clothes

As consumers what are the most important behaviours we can adopt?

Remember the most sustainable piece of clothing is already in your wardrobe. If you need to buy something, buy pre-loved.

What do you enjoy doing in your spare time?

I’m a big open-water swimming fan, even if I don’t spend that much time in the water in winter! And I still play hockey after 20+ years. I kept playing originally so I could play with my daughter, sadly she hates it.

And finally, we always like to do a quick fire round:

Photo of a lake and mountains
  • Plane, train or automobile? Train.

  • Mac or PC? Mac.

  • Tea or coffee? Tea, although I drink coffee when out (as long as it’s not instant!) as I’m fussier about how tea is made.

  • Swim, run or cycle? Swim. I need to dust down my lockdown bike, no doubt like many others?!

  • City break, beach or lakes and mountains? Everyone loves a beach holiday, don’t they? That said we have the best memories from our holiday in Austria so lakes and mountains pip it.


Our thanks go to Kristina for taking the time to talk to us. We'll be introducing her to another of our clients - Bird and Blend, as we think she will love their teas!

Datitude is proud to have been chosen to be part of this important project. If you’d like to find out more about the EPR project, including the possibility of participating, or circular economy business models, email Kristina at You can also find out more on their website.

For expert insight and guidance on creating your own circular fashion business model, download QSA Partners' guide here.

To understand more about Datitude’s data expertise or its managed data platform and services, call us on +44 (0)20 3003 5000 or email

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