PARIS — The European Union‘s circular fashion sector could generate more than 104 billion euros in annual revenue and create 88,000-plus jobs by 2030, according to the “State and Prospects of Circular Fashion in Europe” study from the KPMG and Fédération de la Mode Circulaire, as policymakers and industry players increasingly turn to regulation to accelerate the transition away from linear fashion models.
Presented at the FMC’s Circular Fashion Day conference, the report comes at a time when the European apparel sector is challenged. Consumer demand remains subdued, while manufacturers continue to grapple with high operating costs, shrinking industrial capacity and growing competition from lower-cost imports.
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“Energy costs are structurally high in Europe, and it’s a competitive disadvantage with competing countries, notably Asian,” said KMPG senior manager, circular economy Mina Bishop. She also noted that there are structural concerns about the region’s industrial competitiveness.
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“We are not helped either by the decline of our industrial capabilities, with average 50 percent reduction in employment in textile and apparel in Europe,” she said.
The study found that circularity is increasingly being driven by regulation rather than voluntary sustainability commitments. New European measures, including extended producer responsibility (EPR), digital product passports (DPPs), textile waste collection requirements and potential VAT incentives for repair and resale, are now shaping the economics of fashion production and consumption more than market forces.
“We need harmonized regulation to give clarity for companies, confidence for investors and fairness in competition,” said KPMG director of sustainability strategy and green transition Stephanie Taupin.
Among the policies examined, EPR is emerging as one of the most significant. By requiring brands and retailers to finance the collection, sorting and treatment of products at the end of their life, EPR effectively turns waste management into an operating cost.
“End of life becomes a cost of doing business,” Taupin said. “As payments are linked to volumes placed on the market, EPR becomes a recurring cost line by making brands pay for end of life. It creates a financial incentive to reduce those costs by reducing volumes, improve durability, certify materials, increase recyclability, etc. You look at distribution, high volumes become more costly, right, because indeed more carbon to put on the market equals more carbons to collect.”
The policy should gradually challenge the economics of ultra-fast fashion models built around high volumes and short product usage times.
However, the study also noted that EPR alone will not solve structural challenges. Collection and sorting systems are improving, but profitable downstream recycling infrastructure remains underdeveloped, and the economics of textile-to-textile recycling continue to be fragile.
The report examined digital product passports, noting that much of the industry is not well-prepared as the requirements are expected to be rolled out in 2028.
“The DPP is first and foremost an internal data project,” Bishop said. But the report showed that 31 percent of companies preparing for implementation identified data collection as their biggest obstacle.
Brands are still struggling to gather reliable information across their supply chains, while uncertainty remains around the precise data requirements that will ultimately be mandated. Those are expected to be formally unveiled this fall.
The report’s third focus area is lowering the VAT — similar to sales tax in the U.S. — for resale and repair, which could lower prices for consumers and improve margins for circular businesses.
A reduction in the tax rate could not only strengthen demand but also push brands and independent operators to invest in repair networks and resale infrastructure.
The study suggested that creating a harmonized Circular VAT across the EU could become one of the most powerful demand-side levers available to policymakers and move circular fashion from the sustainability niche into a commercially viable mainstream market.
This would also impact consumer behavior and purchasing decisions.
“Behavior follows price signals,” said Bishop, noting that sustainability alone is unlikely to drive widespread adoption of circular business models if consumers continue to face strong economic incentives to buy low-cost, ultra-fast fashion items.
“Today it’s not really an obvious solution to repair your garment when you can buy a new one for a lower price than repairing the one you have,” she said. “Circular VAT would be a clear incentive to make their price lower if the reduction is passed on to the consumer.”