A coalition of nearly 70 fashion businesses asked governments last month to change the tax treatment of resale and repair. Lower the VAT on a second-hand sale. Cut the labour tax on a repair. The logic is sound. A financial lever, pointed at a business, to make the better outcome the cheaper one.
Two other product categories are dealing with the same problem, and all three want to keep products out of landfill. That is the only thing the three have in common.
Look at what the law is chasing in each case. For vapes, it is the product itself, what gets sold and who uses it, so the headline response was to ban a format. For batteries, it is a hazard, the fires that start when a lithium cell is crushed in a bin lorry, so the response is safety warnings and rising alarm. For textiles, it is a cost, a collection sector warning it will collapse and leave councils to pick up the bill. Three different motivators, three different instruments, three different vocabularies, moving at three different speeds. Each conversation is so absorbed in what makes its own product distinct that the one thing all three depend on has fallen out of the design entirely.
That thing is a person, at home, deciding whether to bring something back. The same person in all three cases. And almost none of the schemes being built right now are designed to make that decision easy, or to give the person any reason to make it. There is a proven playbook for exactly this, for changing what an ordinary person does with an everyday object, and across these three categories it is barely being used.
We already know the playbook works, because we run it on drinks bottles. You pay a small deposit when you buy, you get it back when you return the empty. It is proven, it is routine, and most people do not think about it twice. It is also, in policy terms, a form of the same producer responsibility that funds everything else.
So here is the question this piece is really about. The producers are about to pay for the collection infrastructure either way, through fees that land in the shelf price the customer pays. If the customer funds it regardless, why is almost no scheme handing a small piece of it back at the point of return, the one move we already know changes behaviour? Every category has a blueprint for the product and the producer. None has one for the person, the right mix of a reason to bring something back and somewhere easy to bring it. That is the gap, and the bottle deposit is the proof it can be filled.
Three categories, three laws, one missing actor
Look at how differently we treat three products that all end the same way, as something a person has to decide what to do with.
For vapes, the law went after the sale. The United Kingdom banned single-use vapes in June 2025. France and Belgium moved earlier. The motivating concern is the product and its user, nicotine and youth uptake, so the instrument took one format off the shelf.
For batteries, the motivator is fire. There is no ban and no single moment, just a rising count of blazes. UK fire brigades attended 1,760 lithium-ion battery fires in 2025, a 147% rise in three years, roughly one every five hours. Many of those batteries are hidden inside vapes and other electricals, which is the quiet irony of treating the two as separate problems. The battery in the vape is the same battery that starts the fire. The European Union has a Battery Regulation with collection targets, but the public conversation is about safety, not circularity.
For textiles, the motivator is cost. There is no UK scheme yet, just an industry asking for one. WRAP and the UK Textiles Pact published a ten-point blueprint in January 2026 warning that without a producer-funded scheme the used-textiles sector will collapse and the bill will land on councils, rising toward £200 million a year by 2035. The European Union has already mandated textile producer responsibility across all member states, with operational schemes required by 2028.
A product, a fire, a balance sheet. Each motivator pulls toward a different instrument, and each instrument is aimed at a different actor. None of them is aimed at the person who decides whether the product comes back at all.
A product, a fire, a balance sheet. Each instrument is aimed at a different actor. None is aimed at the person who decides whether the product comes back at all.
The ban was never the whole problem
It pays to be precise about what the vape ban actually did, because the shorthand misleads.
The ban took one format off the shelf, the single-use disposable. It did not, and could not, address the wider question of what happens to a vape at the end of its life, any vape. Rechargeable and refillable devices are still sold, still contain a lithium cell, and still end up in a drawer and then a bin. The disposal problem is not a disposable problem. It is a battery-in-a-device problem, and it covers every vape on the market and every one already sold.
It is the clearest small example of the whole pattern. A device labelled "reusable" is a design category. It is a producer-side word. It tells you how the product was made and what it is theoretically capable of. It tells you nothing about what the person does with it. A reusable vape thrown in the kitchen bin is, at the end of its life, the same lithium cell in the same waste stream as the disposable one we banned. The label changed. The behaviour did not. Naming a product after the outcome you would prefer does not produce the outcome. Only the person at the bin does that, and no design word reaches them.
So the instrument was aimed at the point of sale, and at one product format, while the problem lives at the end of life, across all formats. That mismatch is the whole of it. Prohibition can change what is sold. It does almost nothing about what is already in homes, or about whether bringing any of it back is easy.
The vape ban is still the cleanest proof we have
For all that, vapes give us something rare. A clean before-and-after on a single instrument.
The ban worked on its own terms. Material Focus, the recycling not-for-profit, found that the number of vapes thrown away each week fell by 23% after the ban, from 8.2 million to 6.3 million. Take the win. Removing the worst format reduced how many entered the system.
Now look at what the ban did not touch. Six point three million vapes are still thrown away every week. It did nothing about the device already owned, and nothing about whether returning it is easy.
It is not easy. In the same research, of the people who tried to recycle a vape, 43% could not find a drop-off point at a supermarket, and 63% could not find one at a convenience store, even though retailers selling vapes are legally required to provide one. The instrument was pointed at the shelf. The problem was in the home, and on the way back to the shop.
The ban acted on the sale. The decision that determines whether the product is recovered happens in a kitchen, weeks later, and we built almost nothing for it.
The waste industry has already worked out the answer
The timing is worth paying attention to. The people who handle the consequences have stopped waiting for the policy debate to catch up.
In the first week of June 2026, Biffa and the Environmental Services Association, between them representing much of the UK waste sector, called for a mandatory deposit on vapes. Pay a deposit when you buy the device, get it back when you return it for recycling. Biffa put the figure at £5. Their own research found that 85% of consumers would be motivated to return a device if a deposit scheme were in place, against fewer than four in ten who currently take one back. They pointed, explicitly, to the drinks-container scheme as the model.
The detail worth dwelling on is who is asking. The companies calling for a deposit are not the producers and not the retailers. They are the firms holding the bag at the end, putting out the fires, pulling devices off conveyor belts by hand. They have looked at the problem from the only vantage point that sees all of it, and they have arrived at the same instrument we already use for bottles. Not a better ban. Not a bigger fine. A small, recoverable amount in the customer's hand.
We solved this for bottles, and one country proves it twice over
Drinks containers are the one product where the person at the centre is designed for, explicitly, and have been for decades in dozens of countries. You pay a small deposit at the till and reclaim it when you bring the empty back. The United Kingdom's own scheme is confirmed for October 2027: twenty pence per container, refunded at a machine or a counter.
Germany has run one since 2003, and it offers something close to a controlled experiment. Same country, same shops, same people. The figure usually quoted is the return rate for single-use deposit bottles, the share of deposit-bearing containers brought back, and the German statistical office and environmental bodies put it consistently in the high nineties, 97.7% in 2024. The deposit is 25 cents, and retailers are legally required to take the empties back.
Now hold everything constant and remove the deposit. The same Germany, collecting its electrical and electronic waste, where there is no deposit, collected just 29.5% in 2023, well under a third, against a 65% target it is supposed to hit. And the rate has been falling, not because less is collected in absolute terms, the tonnage is roughly flat, but because far more electronics are sold each year than come back. Return rate and collection rate are measured slightly differently, but in plain terms both answer the same question: of what was put on the market, how much came back. Same citizens, same civic habits, same retail network. Deposit bottles come back in the high nineties. Old electronics come back at under a third. The largest single variable between the two is whether there is a coin riding on the return.
That is not a German story. It is a human one that Germany happens to measure cleanly. People who would never read a sustainability report will carry a bag of empties back to a machine for a few cents. Some people collect other people's empties as a supplementary income. The mechanism does not require anyone to care about the planet. It makes the right action worth a small, certain something, and the return rate follows.
Germany returns deposit bottles in the high nineties and collects under a third of its old electronics. Same country, same people. The largest difference between the two is whether there is a coin on the return.
The objection answers itself
The obvious reply is that bottles are simple and everything else is not. A bottle is cheap, uniform, and bought every week. A vape, a jacket, and a flat battery are none of those things. So a deposit fits bottles and not the rest.
It does not hold up.
Start with the money. A drinks bottle is worth almost nothing as material once it is empty, a fraction of a cent of recyclate, and yet a deposit several times that value drives it back at 97%. The things we are not putting deposits on are worth far more. A vape and a flat battery contain lithium and copper, materials that recovery actually wants. If a meaningful deposit makes economic sense on a near-worthless bottle, it makes more sense, not less, on a device with valuable material inside. The recovered material helps pay for the scheme. The economics argue for a deposit on electronics more strongly than they ever did for bottles.
Then variety. The claim that other products are too diverse for a return scheme does not survive contact with how these systems already work. A reverse vending machine reads thousands of bottle and can formats without blinking. France runs more than twenty producer responsibility schemes and prices fine-grained differences across electronics, textiles, and furniture, down to repairability and durability of individual product types. The machinery to handle variety at scale already exists and is in daily use. Variety is a solved problem.
Then the one real barrier, the one that actually held the model back. A bottle works because a machine can read its barcode, identify the exact item, and tie the refund to it. The system knows what came back. Nothing else had that. A worn shoe, a dead vape, a flat battery carries no barcode and fits no vending machine, so there was no way to know what had been returned or whose it was, and without that you cannot run a deposit on it. For years that was a genuine obstacle, not an excuse.
That is no longer true, and we can say so with some confidence, because we have done it. In the in-store running-shoe take-back programmes we support, the item is identified at the point of return by technology we built that recognises the shoe itself, no barcode, no vending machine. The customer submits their email and receives a reward. That is the whole consumer-facing loop a deposit depends on, the item recognised, the person captured, the incentive paid, running on a product that has none of the features a bottle has. The thing everyone assumed made bottles a special case has been built for something that is not a bottle.
So the barrier is not the economics, and it is not the complexity, and it is no longer the identification. The European Union has even commissioned formal study of return schemes for phones, tablets, and other small electronics, and still the default has been to reach for producer fees instead. What is left is habit, the habit of pointing every new instrument at the producer, long after the reason for doing so has gone.
There is a deeper point in this. The usual criticism of European schemes is that they are too complex, too many categories, too many rules, too much fragmentation. That criticism is fair. But the response to producer-side complexity has been to add more producer-side complexity. The thing that would actually cut across all of it is the opposite, one simple mechanism that asks the same plain thing of the same person regardless of what they are holding. The more elaborate the producer machinery becomes, the stronger the case for a single, human-centred layer that works the same way for a bottle, a vape, a battery, and a jacket. Complexity at one end is the argument for simplicity at the other.
Why this is the same money, not a new cost
The technical point matters here, because it is where the objection usually comes. A deposit scheme is not a different species from the producer fees the other categories are reaching for. The OECD classes a deposit refund as a form of extended producer responsibility, because the producer funds it. The UK drinks scheme is producer-funded, with retailers reimbursed for hosting return points. It is the same money as an EPR fee. The only difference is where it goes. An EPR fee disappears upstream into a compliance organisation and the customer never sees it. A deposit takes a slice of that same producer money and routes it through the customer's own hand and back again.
The reply we hear is that these are different things, a consumer deposit and a producer fee. They are not, in any way that matters. A producer fee does not vanish into thin air. It lands in the shelf price, and the customer carries it home without noticing. The customer pays for end-of-life either way. The only honest question is whether the system hands a piece of it back in a way that makes them act, or keeps all of it where they will never feel it.
The customer pays for end-of-life either way. It lands in the shelf price, quietly. The only question is whether the system hands a piece back in a way that makes them act.
We already accept tuned incentives. We just point them all at the producer.
There is a part of this the regulators have already conceded, which makes the omission stranger.
Across the EU, the UK, and a growing list of US states, EPR fees are no longer flat. They are modulated. Packaging that is easy to recycle pays a lower fee, packaging that is hard to recycle pays more, and the rules increasingly extend the same bonus-and-penalty logic to durability, reparability, and recycled content. It is called eco-modulation, and it is now the central financial mechanism in modern producer responsibility. The principle behind it is not controversial. You can tune a financial lever to reward better behaviour.
So we have accepted, in law, that a fee should flex according to how good the outcome is. We have simply pointed every one of those tuned levers at the producer's design desk. We modulate the fee for the company that designs the package well. We modulate nothing for the person who returns it well.
That gap matters beyond fairness. You can only tune a lever if you can measure what it did. Eco-modulation works because a producer's design choices are measurable, the material, the recyclability, the recycled content are all there to be checked. The trouble is that almost everything downstream is measured by weight. Tonnes collected. Mass recovered. Weight tells you how much material moved. It tells you nothing about who moved it, whether they came back, what they brought, or whether the lever you pulled had any effect on the person at all.
A deposit is different in kind, not just in amount. It creates a discrete moment of return, and as the shoe programmes show, at that moment you can know the item, you can know who brought it, and you can know that a person chose to bring it back rather than bin it. That is the difference between counting the weight in a bin and understanding the behaviour that filled it. And once you can see the behaviour, you can do for the consumer what eco-modulation already does for the producer: design the incentive, watch what happens, and tune it. Weight-based collection can never improve itself, because it cannot see its own cause. A return you can attribute to a person and a product is the only version that learns.
That is the real prize, and it is bigger than any single deposit scheme. It is the feedback loop the entire system is currently missing.
That is the difference between counting the weight in a bin and understanding the behaviour that filled it.
The part that has to be said out loud: somebody has to actually pay in
There is a fair objection to all of this, and the responsible producers are the ones who will raise it first. A deposit funded by producer responsibility only works if the producers actually pay in. A large share of them do not.
Take vapes. UK enforcement seized 1.26 million illicit vaping products in 2025, more than two a minute, and over 4.9 million across three years. That is only the fraction that was caught. Every one of those devices carries the same lithium cell into the same waste stream and the same bin lorry, and the importer who brought it in has paid nothing toward handling it. The compliant producer, the one who registers, joins the scheme, and funds the take-back, is left covering the consequences of the one who did not.
Textiles face the same shape of problem through a different door. The European Commission estimates around 4.6 billion low-value parcels entered the EU in 2024, more than 90% of them from China, much of it ultra-cheap apparel shipped direct to the consumer below the duty threshold. That is precisely why the EU is removing the de minimis exemption and adding a per-parcel customs charge from July 2026, citing unfair competition, safety, and environmental concerns in the same breath. The clothing arrives outside the regulated system, and the garment still ends up in the same bin, the same charity sorting room, the same council waste stream that a producer-funded scheme is meant to pay for.
This is the free-rider problem, and it is real. A consumer deposit does not solve it on its own. It has to sit alongside closing the import gap, so that the responsible, regulated actors who fund the system are not quietly subsidising the ones who never pay in. Owning that is part of making the argument honestly.
And it is worth noticing why bottles barely suffer from this. A drinks bottle is sold by a regulated producer, through regulated retail, in the country where it is consumed. Nobody mails you a duty-free can of cola direct from a factory overseas. The channel is closed, which is a large part of why the deposit can reach 97% in the first place. The most reliable way to make sure a returned t-shirt was captured as cleanly as a drinks bottle would be to sell the t-shirt inside the bottle. That is absurd, of course. The point underneath the absurdity is not. The bottle's 97% is not a property of bottles. It is a property of a closed, regulated channel with a coin on the return, and no other category gets that channel handed to it for free.
A thought experiment, and a precedent that makes it less absurd than it sounds
The fastest way to see where the accountability gap sits is to run a thought experiment. Imagine we routinely inspected general waste, and when a product turned up where it should not, we traced it to the producer and charged them for it. Pick through a week of bin lorries, find the vapes and the batteries and the textiles, send the bill to whoever put them on the market.
Customer engagement programmes would appear overnight. Every producer would suddenly have an urgent, direct, financial reason to make sure their product came back, and to help the customer do it. The reward schemes, the visible return points, the clear instructions, all the things that are treated as optional today would become commercial necessities by the end of the quarter. The behaviour we have spent years trying to coax out of the system would arrive in weeks, because for the first time the producer would be on the hook for the end-state of their product rather than just the moment of sale.
We are not going to inspect every bin. It is operationally impossible and we are not seriously proposing it. But the principle is no longer hypothetical. From 19 July 2026, the EU prohibits large companies from destroying unsold apparel and footwear, with mandatory disclosure of what they discard and penalties for non-compliance, and the Commission has said it intends to extend the ban to further categories. We have already decided, in law, that a producer can be held accountable for the end-state of a product, that they must disclose what they throw away, and that destroying it carries a cost.
We have simply applied that principle to the product that never sold, and not to the product that sold and was never brought back. The unsold jacket in a warehouse is now the producer's responsibility. The sold jacket in a bin is nobody's. The second stream is vastly larger than the first. The thought experiment is only shocking because we have decided to look at one end of the shelf and not the other.
Back to the letter we started with
Which brings us back to the fashion coalition and their tax proposal.
Lowering the VAT on resale and cutting the labour tax on repair is the same kind of move as a deposit. A financial lever, aimed at a human being, to make the better behaviour the easier or cheaper one. The coalition aimed that lever at the resale operator and the repair shop. The Battery Regulation and the textile blueprint aim their levers at the producer. The vape ban aimed its lever at the retailer's shelf.
Every actor in the chain is being nudged, taxed, funded, or restricted into better behaviour. The producer, the recycler, the resale platform, the repair shop, the retailer. We have built financial instruments for all of them.
The one actor we have not built a financial instrument for is the person who decides whether any of it begins. The customer who walks the thing back, or does not. We have a proven, accepted, decades-old tool for exactly that decision. We use it for bottles, and they come back in the high nineties. We have somehow concluded it does not apply to anything else.
That conclusion was never argued. It was never even questioned, because each category was too busy with its own product to notice the others had the same hole.
What we are actually asking for
To be clear, this is not an argument that every product needs a 25-cent deposit copied from the drinks aisle. The quantum and the mechanism will differ by category. A dead vape, a worn jacket, and a flat battery are not the same problem in detail.
The argument is for a blueprint for consumer engagement. It comes down to two things designed together. Incentive, a reason for the person to bring the thing back, the coin on the return. And access, somewhere to bring it that is as easy to find as the shop they bought it from, the thing the vape research showed was missing for half the people who tried. Get those two right, designed by all the actors at once rather than each in its own silo, and you have the piece every category has skipped.
Because we have blueprints for everything else. We have eco-modulation, collection targets, recyclability grades, and tax levers, all of them aimed at the producer, the recycler, the resale platform, the shelf. Nobody has written the one for the person at home, even though that person decides whether any of the rest of it gets the chance to work.
The deposit is the best evidence we have that such a blueprint is possible. It is the one instrument that already pairs an incentive with access, gives the person a reason to act, and creates a moment where what they brought back can be understood rather than just weighed. Build from there. The producers will fund it, because they are funding the infrastructure anyway. The stakeholders are all already at the table, the brands, the retailers, the recyclers, the waste firms, the regulators. And they already share the one goal that matters: keeping the thing out of landfill. The only actor not yet in the design is the one who actually puts it there, or does not.
The question
The producers are going to fund the collection infrastructure. The fees are being set, the schemes are being designed, the money is moving, and the customer is paying for all of it in the price either way. The waste companies, who see the whole problem, are asking for the one instrument that already works. Germany has shown us what it does to a return rate. And we have already agreed, through eco-modulation, that tuning a financial lever to reward better behaviour is sound policy.
So it comes down to this. We have done everything except design for the person who actually closes the loop, and we already have the proof that designing for them works. We know how to tune an incentive. We have decided a producer can be held to account for a product's end-of-life. We run a deposit scheme that brings bottles back in the high nineties. What is the actual reason we have written a blueprint for everyone in the chain except the one who decides whether it starts?
Without it, change will be glacial. Though on current form, that comparison will not last much longer either. Soon enough nobody will remember what a glacier was, and we will need a slower thing to point at.
If the customer is paying for it regardless, why are we so reluctant to let them feel it working?