Olivia Fulton
Mishcon de Reya
Welcome everybody for, to our seminar on preparing for Green reforms. Thank you very much for joining. So I just, I’ll move straight onto introductions. I am Olivia, I’m an Associate in the Commercial team at Mishcon and I’m joined by Alexa, who is our Knowledge Lawyer and also, we’re joined here today by Shubham from TrusTrace so I’ll let you introduce yourself, Shubham.
Shubham Kulshrestha
TrusTrace
Thanks a lot Olivia and Mishcon for having me here. My name is Shubham, I currently lead our growth initiative for northern Europe and the UK market. TrusTrace is a B2B SAS provider for traceability and supply chain visibility and I’m really looking forward to contributing. Thank you very much.
Olivia Fulton
Mishcon de Reya
Thanks Shubham. So the topic for today, there’s been a sweep of wide-ranging legislation coming in in the EU for any retail bases that operating within the EU will need to comply with. We’ve set out here a wheel which highlights some of the key legislation. Because of such a large volume of legislation coming down the pipeline, what we’ve done here is we focus on legislation that impacts the point of lifecycles so the product is designed, the way the product is described or marketed and the decline of the product so, what happens to the product at the end of its lifecycle. We’ve also developed a handbook which sets out in much more detail each one of these pieces of legislation and we’ve got a QR code to that on the screen here.
So for the purpose of today, we’re just going to look at three pieces of legislation so, the Ecodesign for Sustainable Products Regulation, the Packaging and Packing Waste Regulation and the Green Claim Directive.
Alexa Lamont
Mishcon de Reya
We’re going to be following a scenario today throughout the session to look at, after we’ve looked at the key provisions, we’re then going to apply it to a scenario to see how businesses can comply with the rules. So this is the scenario, Mishco has been a successful retailer in the UK and EU for the past decade selling their distinctive orange t-shirts. They’ve recently learned about the EU’s new Green legislation and are concerned about how to comply with the new rules.
Olivia Fulton
Mishcon de Reya
So, first looking at the Ecodesign for Sustainable Products Regulation. So this is a framework piece of legislation and what that essentially means is it sets out the general principles and broad obligations that will apply to all products on the market with some limited exemptions for food and medicines and then how these products, how these principles and broad obligations will be applied to specific product categories will then be set out in secondary legislation and that secondary legislation hasn’t been published yet.
So, the ESPR embeds ecodesign requirements into a product’s lifecycle and these obligations broadly fall into three buckets. So the first bucket we’ve got performance requirements and these set out obligations in relation to how a product is designed. The second set of obligations is information requirements, so what information do you need to provide to your consumers in relation to the products and that comes in the form of the digital product passport and then thirdly, obligations in respect of unsold goods, so there’ll be reporting requirements on unsold goods and also a framework to prevent the destruction of unsold consumer products. So we’re just going to look at each of these in very high level, so the first set, the performance requirements, this relates to as I said a design obligations and this itself is set out into two separate types of obligations. So the first one will be quantitative requirements and this will set things like a minimum and maximum percentages for ways in which the, the product is produced so for example, a maximum amount of water that could be used when you’re producing a garment. And the second set is non-quantitative obligations and this would be things like absolute prohibitions on certain practices so for example a ban on the use of a certain chemical. In setting these requirements the Commission will identify sustainability improvements and they’ll base this on certain parameters such as water and energy consumption, carbon footprint and recycled material. The Commission has also said that they’ll look at things like the economic viability of any of the requirements that they set and they’ll also benchmark this against what other markets are doing outside of the EU but what the ESPR does prohibit them from doing is introducing any requirements that go to or hinder the functionality of a product.
And the second bucket is information requirements, so this is the digital product passport obligation, so all products entering the EU market will be required to have a digital product passport. Again, the kind of specific information that will be required will be set out in the secondary legislation and will be specific to product categories but the ESPR does give an indication of what that type of information would be so you need identifiers for the product and different entities within the value chain, environmental performance data and also information on recycling and disposal instructions for consumer at the end of a product’s lifecycle. And this information will need to be made easily available to consumers so for example that might be via a QR code.
And the third bucket of obligations so this is in relation to unsold goods, so there’ll be disclosure requirements, companies will be required to disclose the number of unsold goods, the reasons for discarding those goods and also, they’ll be required to disclose the proportion of those unsold goods which have been directed for reuse, manufacturing or recycling. There’s also going to be a ban on destroying unsold clothing and footwear and potentially down the line there’ll also be bans in relation to destroying other unsold goods as well. There’s very limited exceptions for this so, the ESPR at the moment talk about an exception for health and safety but notably there’s no exception for the destruction of, for example, samples and there will be some transition period so of six years it’s proposed at the moment for medium-sized companies and smaller companies will be exempt.
So the next steps the Commission will publish its working plan on its website. The text has been formally adopted by both the European Parliament and Council so the next stage is it will be published in the official journal and enter into force. The ESPR also sets out which product category they will prioritise first, as we talked about that secondary legislation will need to come in and it has said that clothing, footwear and furniture will be prioritised first.
So now looking at scenario, so we’ve got Mishco and they’re planning to introduce a new line of orange jeans and they want to ensure that their products meet the ESPR’s requirement, including the use of digital product passports. How can Mishco design their jeans to meet the new rules?
So, looking at the potential design requirements, so as I’ve said these specific requirements will be set out in secondary legislation so Mishco won’t know what those are yet but some examples that they can be thinking about is there might be a restriction on the maximum amount of water consumption that’s permitted in the production of the jeans, there might be a minimum percentage of recycled material that’s required per item and there might be prohibition on certain practices or designs that impair the repairability of the product. So whilst Mishco doesn’t know the specific obligations, they should start to design this new product in line with the general principles of the ESPR, which is durability, repairability and recyclability. So for example, if you’re looking at the design, they might not want to put an embedded zip in the jeans because that could be considered in the future detrimental to a consumer’s ability to easily repair the jeans.
One thing that they can start preparing for definitely is the implementation of a digital product passport because they will need to ensure that they’ve got detailed information about their product supply chain and sustainability credentials as well so, for example, who supplies the hardware, who supplies the original fabric, what’s the carbon footprint of the jeans and whilst they’re not under an obligation today to have a digital product passport, it’s important to note that it will likely take Mishco quite a long time to implement this, particularly as they’re a smaller, boutique brand, they might not have the leverage with their suppliers to collect that information easily and they will also need to select the right tech partner to collate that data and roll out their DPP which is probably a good point to hand over to Shubham.
Shubham Kulshrestha
TrusTrace
Thanks a lot, Olivia for that. I think, you know, very important topic and I think you’ve very well explained how this regulation is evolving. Just to give a quick sense on what some of the key criteria that a brand or retailer should be focussing on when it comes down to ESPR and then implementing DPP is that there are almost nine different information group or information pockets that brands and retailers will have to collect and these are respectively the brand information which is information about the product, you know what information that you would like to put on label. That’s one category, the second one is supply chain information which is more specific information about the manufacturing facilities, where the production took, the country of origin and things like that. The third category is product information where you are getting more information about the style ID, the style number or product composition and some of the specific details about product and material. The next most important thing would be the care instruction that they would have to put in and then I think the next major section is around compliance, circularity and sustainability information and as the regulation is also evolving, I think more and more detailed points have been added to this but overall these are the different information pockets that you will have to start collecting and the next important thing that you will have to start thinking about is the digital identifier. Currently, it can be in the form of an RFID thread or an NFC chip or a QR code. In terms of implementation, the QR code is the most easiest one to start this journey with but we also know that the other two options, like the RFID thread and the NFC can enable certain more business cases that you might want to explore in the coming years. So based on our experience, I think what we typically recommend any brand is to first do an internal assessment just to see the data that is available today versus what data they have to collect in future. The second thing that we would recommend is to start looking at their internal infrastructure in terms of what data exists in which system and how much data they would want a new system to collect. From a traceability sense, TrusTrace is a player which can help you collect information around supply chain, compliance, sustainability and also recently we have done a pilot programme with some of the Nordic brands on DPP so, we can also help you collect circularity data because circularity data is something where you would have to start involving the post-consumer traceability players as well such as recycler and sorters but in terms of the approach, I think doing an internal assessment on the data availability then doing a technical assessment on what data exists where, and then the third most important thing would be then to start planning the specific block of information that you are looking to collect because currently, the research that we have done within TrusTrace we have identified that there are 104 different data points that organisations have to collect as part of this and this information is available in our digital product passport protocol which is available on our website, you can go and look at each of these data points. We feel that it will take almost 15 to 24 months for a brand to collect all these data points at scale but it is very important that you know you break this down into what you can focus for the first three months and then the next three months and things like that, so I think the third most important step is that scope identification and then planning the rollout because these three things will overall depend, overall help you identify how much internal resources you need, how much external help you would need and then, you know, it will help you start planning for that so, but I think it’s great that we have seen a lot of brands and retailers now thinking about this and you know, get preparing for this. There are also lighter versions of digital product passport that brands can typically adopt as a Phase 1 approach because we’re also seeing that as we speak about this regulation, a few more things are being added to that but I think these are the few critical action items that I can recommend you based on our experience and at any point in time if you feel that you need more information, then please reach out to us, we’d be happy to help you in these assessments but also once you have identified the scope, then start identifying the right partners that can help you with that journey. Maybe I’ll pass it back to Olivia on that.
Olivia Fulton
Mishcon de Reya
Thanks very much, Shubham, that’s really interesting. We’re going to move onto the Packaging and Packaging Waste Regulation now and so, Alexa I’ll hand over to you.
Alexa Lamont
Mishcon de Reya
Thanks. Thank you. So, yes, we’re going to have a look at this one. So, just looking, this, this establishes requirements for the lifecycle of packaging to improve sustainability and there’s sort of three broad buckets again, a little bit like the previous legislation so we, we’ve just categorised them into these three things. The first is design requirements and the point of these requirements is try to prevent packaging waste. There’s also labelling requirements and also rules on waste management, including extended producer responsibility for packaging. So, the regulation applies to all packaging regardless of the material used and to all packaging waste and it’s got quite a wide definition of packaging. It says “items of any material that are intended to be used for the containment, protection, handling, delivery or presentation of products” so, this goes beyond just product packaging and there’s also provisions for packaging use and transport and also ecommerce packaging so it’s really wide in terms of scope. And it gives some examples of packaging in the annex and it includes items beyond what you might think of packaging, including coat hangers sold with clothes and also mascara wands so, we’re looking at a piece of legislation that is incredibly broad.
Just looking at that first bucket then, design requirements, just a few key provisions from there. All packaging placed on the e-market must be recyclable, with a few exemptions and it must meet specific design criteria for recycling. Any plastic part of packaging must contain a minimum percentage of recycled content recovered from post-consumer plastic waste and from the 1 January 2030, economic operators are not allowed to place certain packaging formats on the market and it’s got a full list of what those are set out in that annex and this includes very lightweight plastic bags, with a few exemptions. So, so, packaging must also be manufactured to minimise the presence and concentration of substances of concern. So, while these, these packaging minimisation requirements I just mentioned must take effect from the 1 January 2030, there will be an exception in respect of certain packaging that is protected by trademark or design in the EU as the date that this legislation comes into force, which we’re anticipating will be Autumn 2024. So, where the application of the packaging minimisation requirements effects the packaging design in a way that alters its novelty or its individual character or the trademark in a way that the trademark is not capable anymore to distinguish the marked goods from those of other undertakings then in that case there might be an exception if it’s protected trademark or design in the EU. So, where appropriate, brand owners should therefore start investigating this and thinking about taking steps about TM or design protection.
Packaging must also be designed to reduce unnecessary weight and volume and the empty space ratio in ecommerce transport and group packaging should be a maximum of 50% and empty space in sales packaging should be reduced to the minimum necessary. And space fillers such as paper cuttings and Styrofoam chips, as you can see in the image there, will all be considered empty space and false bottoms or packaging with the aim of increasing the perceived volume of a product will be banned. So in regards to the second bucket, labelling requirements. Packaging must be marked with labels containing information on material composition and for certain packaging, indicate if the material is compostable. Packaging must contain a label on reusability and may have a QR code or similar for further information and packaging which is subject to deposit and return schemes should have a clear and unambiguous label. In addition, there will be a general prohibition on displaying label on packaging that are likely to mislead or confuse consumers with respect to the sustainability of the product’s packaging and also, it’s expected the commission will harmonise specifications for labelling.
And then in regards to the third bucket, there are targets and requirements for the reuse of certain packaging and member states must take measures to encourage the setup of systems for reuse and refill. Member states must establish deposit return schemes for drinks bottles and cans and also, producers will have extended producer responsibility for the packaging they make available for the first time in a member state and this may include financial contributions to cover waste management costs.
So, in terms of next steps, the European Parliament has formally adopted the regulation, however under the EU legislative process, both the European Parliament and the European Council have to agree on the final wording. So, at the moment, we’re waiting for the Council, the European Council to also formally adopt the same text before the regulation can enter into force. And once the regulation comes into force, then many of these obligations will only take effect after a transition period.
So, in terms of the scenario, we’re going to go back to our retailer Mishco and Mishco wants to use a to use a distinctive orange box to package its orange jeans in the EU and they want to ensure that their packaging meets these new rules. So, what are some of the things that they can start to do to prepare now? I’m going to hand over to Liv, who’s going to talk about this.
Olivia Fulton
Mishcon de Reya
So, one of the things they need to start thinking about is collecting data. A lot of businesses, including Mishco, are focussing on the data about their supply chain and their products at the moment and are lacking some of that data around packaging so, they need to get a real understanding of the type, material, size of the packaging that’s used for the jeans and also, the packaging that’s used for transport, particularly where they’re selling the jeans online. The second thing they need to think about is who are the key stakeholders? So, who within the business is responsible for designing and selecting the packaging? Who outside of the business needs to be engaged as well so, whether that’s their logistic providers to collect the data that they need or their packaging suppliers and manufacturers as well. And the third thing they should start to be thinking about is relationships with their packaging suppliers so, what contractual provisions do they have in place to require, for example, the suppliers to comply with local legislation? How flexible are their contracts to enable them to change a specification of the packaging if they need to and what obligations are there on their suppliers to provide the information that the need to be able to comply with this? And it’s not on the slide, but also Alexa mentioned earlier, thinking about whether their packaging could be subject to design registrations. And I’ll just hand back over to Shubham now for TrusTrace’s thoughts and what you’re seeing in the market in relation to packaging.
Shubham Kulshrestha
TrusTrace
Absolutely. Thanks Liv. I think, as you know this is one regulation that we are all slowly learning along with our brands and retailers. The reason for that is for the last five, six years of our journey a lot of brands that we worked with have significantly focussed more efforts on doing data collection for their main fabric. I think it’s now because of this regulation that they have started to realise that they need to start collecting more deeper data on packaging as a, you know, bill of material item. In the past we’ve seen brands collect maybe basic data around it but I think with this regulation coming in now, they have to go a bit more deeper. So some of our initial learnings that we have had so far is that there is a lot more standard available when it comes down to different main components of the garment but currently, at least the fashion in the textile industry has very little standard when it comes down to the packaging material. So, one of the things that we are trying to do with a lot of the brand partners and retailers is to first, enable them to collect this data because unlike the main fabric or the main material of a garment, packaging is something that can vary between brands and retailers and the way they package. I think we spoke about that there could be hangers and you know some of the other things, even currently the way some of the packaging is done is very, very different based on the capacity and the size of you know, the shipment that they received them and things could really vary between them. So, our first recommendation to all the brands and retailers as of today is to let’s start collecting some data so that we have much more clarity on how, how much you know they are doing with respect to each of these packaging materials and also then try to understand what is the waste because we’ve also realised that the waste can vary between brand to brand as well so, then we are working with a few brands to set up a standard wastage framework so that they know that this is the amount of wastage that they are able to do. So our first step recommendation to probably a lot of brands and retailers today would be to start just collecting data because that will give you a firsthand experience on how currently packaging is being even handled in your supply chain. The second thing is, identify who is the actor in the supply chain who can give you this data because unlike the main fabric and the main material, you know that this my tier one manufacturer, this is my tier two supplier and you can reach out but with packaging I think there are traders involved, there are different organisations involved to whom you place this order so, it’s important to identify who are the actors and from where you can start collecting the data. And then the third recommendation would be that once you start collecting this data, I think then you’ll have to make certain changes to the way you might package because some of the specifications that are mentioned in these regulations you might identify that currently doesn’t completely rely so, with some companies we have seen that now they are then changing their packaging strategy so as to, you know, enable or start working on this direction. One of the other things that we always go out to brand is that don’t expect a perfect setup on Day 1, you know, that’s one of the key reasons why a lot of these regulations are established and no I think regulatory body is also looking to penalise anyone on Day 1, they are all looking that as a brand or retailer are you making the right actions or the effort so, when it comes down to some of these newer topic and regulations, I think showing their intention or having that vision plan that these are the different actions that you are going to take, you know, to collect data in order to identify people and then this is the frequency of data collection and as long as that process looks very solid and you are able to regularly demonstrate that it is following all the right things, then everyone appreciates the progress as well. So, these are certain fundamental things that we have observed and I think this will also require a lot more, stronger collaboration with other actors in supply chain which may be or not engaging on a regular basis because packaging until now was never the main focus in the main product but I think with this Packaging Regulation coming in, I think that is going to also request a lot more attention. So, yeah, that’ probably a quick thought on it. I’ll pass it back to Alexa and Olivia.
Alexa Lamont
Mishcon de Reya
Great, thank you. Okay, so moving on, we’re going to look at the third piece of legislation, the Green Claims Directive. So, this proposes new rules about the substantiation and verification of green claims to consumers and the purposes really to tackle the issue of greenwashing. So, what this piece of legislation does, it sort of focuses broadly on this time two buckets. We’ve got explicit environmental claims and then also environmental labelling schemes which are not regulated by any other EU acts. So the directive builds on new rules for greenwashing. They’ve been set out in a different directive called the Empowering Consumers for the Green Transition Directive and that other directive introduces new misleading practices for businesses about greenwashing such as misleading consumers about the environmental aspects of a product and it’s introduced these misleading practices into consumer law. So what the Green Claims Directive does, it sort of builds on that and sets out the detail for how exactly green claims should be substantiated and verified. So, in terms of who it applies to, does it apply in the UK? Non-EU businesses making green claims directed at EU consumers would need to adhere to the directive. Companies that have fewer than ten employees and generate less than 2 million euros annual turnover would be exempt from the rules about green claims but note that they may still need to comply with the rules about greenwashing in that other directive which is called Empowering Consumers for the Green Transition Directive because that is in relation to consumer law.
So just looking at these two buckets again, I’m going to start with the first one, Explicit Environmental Claims, and we’re going to have a look at what exactly this means. So, Explicit Environmental Claims are those claims made by traders, they have to be about themselves, the trader themselves or their products. It has to be in business to consumer communications, the claim has to be directed at consumers and it must be in text form or in some kind of sustainability label. And the claim has to state or imply that a product or the trader either; 1) has positive or no impact on the environment, 2) is less damaging in comparison to other traders or products or 3) has improved its impact over time. So an example of an explicit environmental claim might be something like packaging made of 30% recycled plastic because it goes through all that criteria. And in relation to these explicit environmental claims, these are the sort of new rules that are coming in in relation to those. Firstly, these claims need to be substantiated with evidence. So, companies would need to carry out an assessment to substantiate that claim, meet a number of requirements, for example, claims must specify their scope such as whether it concerns the whole product or only part of it or if it concerns all the activities of a company or only some of them and claims must be based on widely recognised scientific evidence using accurate information and also international standards. And then in relation to verification, the claim also needs to be independently verified and to verify the claim, the proposal is it would need to be assessed by an independent and accredited third party and a certificate of conformity may be issued following a successful assessment. And finally, in relation to communication, the communication of the explicit environmental claim must only, you must only communicate those which have been substantiated and this claim has to be clear and you have to provide information about the claim and its substantiation and the directive proposal sort of gives an example of using a QR code to link to further information so people can find out more information about the claim that you’ve made.
And turning next to the proposals in the directive for environmental labelling schemes, the proposal is for these schemes to be, to have more controls around them to avoid consumer confusion about them because there’s so many at the moment in, in operation and some people find them quite confusing. So when we’re talking about environmental labelling schemes, these are labels that certify that a product, process or company complies with the requirements of that particular labelling scheme so they’re sort of used as a sort of mark or token of the product being sustainable. The proposal is that these should be subject to new requirements, for example, there should be more information about its ownership and how compliance is monitored should also be transparent, how compliance with getting the label should be transparent. The directive proposes that new public labelling schemes can only be developed at the EU level and private schemes must require pre-approval. And also, companies will no longer be allowed to use labels showing a rating or score for a product or company representing cumulative environmental impacts unless it’s been a scheme set up under EU law.
So one thing to make clear about this directive is at the moment it’s still going through the legislative process. It is, at the moment, the as I said before, you have the European Parliament and the European Council and they’ve got to agree together what the final wording of this directive is going to be so in, they’re in the process of doing that the moment before it becomes law and on the 17 June just gone, so ten days ago, the Council of the EU announced that it was going to seek a few amends to the directive and try and agree those with the European Council and an example of one of the amends they wanted to make was, “A simplified procedure should exempt certain types of explicit environmental claims from the third party verification procedure.” So, that’s quite an interesting development and we’ll see what comes of that and whether that makes it through to the final text. Once the directive comes into law, there will be again a sort of transition period and also the, the Green Claims Directive allows for new rules to be added later so, it may be that you know there are further rules that come into play after this one comes into force.
So, moving on to our scenario and just applying this to our story that we’re following. So, Mishco would like to have an Instagram advert in the EU which states that their new orange jeans are made from at least 50% recycled materials. What does Mishco need to think about before it makes this claim? So, I think one thing to think about is that for Mishco making this claim in an ad might mean increased compliance costs for Mishco to meet the Green Claims Directive requirements so, it’s thinking about the budget early on and thinking about how they can weigh up those extra costs that might come into marketing the product. One thing that might come into that weighing up equation is that green claims are voluntary, so Mishco will need to decide if the benefits of making this green claim outweigh the cost that might be associated with it and in the directive itself, the proposal they give some examples of the costs that might accompany making these claims in the future and it really depends on the type of claim that you want to make and they sort of give this sliding scale. So, if it’s a claim on materials used in production then it might be for example around 500 euros and so in Mishco’s case they wanted to claim that the jeans are made of 50% recycled materials so that would probably fall into around the 500 euro camp but if Mischo wanted to make a claim on the environmental footprint of a product then the costs then might leap up quite significantly to 8000 euros and then finally, if Mishco wants to make a claim on the environmental footprint of Mishco itself, the whole organisation, it jumps up even further to 54, 000 euros. So, you can see there’s a, there’s a huge scale here and these are things that are given as examples in the directive itself so, if you are concerned about the costs, I suggest you, you know have a look at the directive and see the examples that are set out there in terms of costs.
Mishco will also need to make sure they have in place a robust internal process for collecting environmental data so that in the future it could substantiate its green claims and have that in place when it wants to communicate them. And Mishco can start to prepare by mapping current processes for substantiating and communicating green claims so what does it already have in place at the moment? Are there any rules or procedures that it has internally about greenwashing? And then identify any gaps in its data, internal knowledge or its communication policies.
So, I’m just going to hand over now to Shubham to talk about what he’s seeing in the market in relation to this.
Shubham Kulshrestha
TrusTrace
Thanks Alexa. I think this is very, very interesting because we are really seeing you know a lot of things that I’ve spoken about this specific regulation because a few certain claims were made in the past and then now with this, I think the market is really going through a lot of you know I would say different challenges but overall from what we have seen that this specific regulation follows six key principle. It predominantly rotates around being truthful and accurate where, you know, the impact information that is being reflected is true. The second thing, it should be clear and unambiguous where you know it should be straightforward and not confusing because we have had instances where it is 10% or 5% or 3% or 50% and then by the time a consumer will understand it is very, very tough. The other important thing that it needs to have a fair comparison and clear criteria because in the past when some of these claims have been made it is, it is put in such a way that it was not an apple to apple comparison and you know, I think now it’s very important that all the information should be very comprehensive and the claims at the end of the day needs to be supported by credible evidence. And so I think these are the six key principles that I would say Alexa also touched upon when we, when she was explaining. The other important thing that we have realised is not only there is a financial risk that will come along with some of these things but the bigger thing is the reputational impact because misleading claims can really damage the trust and consumer loyalty and in the past we have not seen direct implications of similar, I would say, scenarios but I think there are instances when publicly if you know some people call out a company for bad claims or bad practices, then it directly starts affecting their stake share value in the stock market and then that kind of leads to a lot of bigger, I would say, financial loss and reputational impact so, I think it’s not just about that specific product but it, at the end of the day, the overall vision and the policy that the companies are thinking about, right. So, overall I will repeat back to everyone is that this is the data collection that we’re looking for. Green claims also requires a lot more evidence based collection because I think before this whatever we have spoken that that was data in different dimension but for this one it is deeper data as well because every claim, every data point that you are trying to prove would have to be backed properly. So for example, if you’re saying it is 50% recycled material then it has to have the right transaction certificate, the transaction certificate will have to demonstrate the right chain of custody, it will have to follow a product segregation framework and things like that and so on and so forth, right. So it’s very important that if you are thinking about green claims code the first step has to be starting to map your supply chain so at least you know where your suppliers are and from whom you have to collect this data. The second thing you’ll have to do is start collecting basic data at the product level and then go deeper and start collecting those evidences and get those evidences validated using our platform, AI framework or using third party verification and things like that but overall I think for this specific regulation, our sense is that collecting evidences at scale and ensuring that the right evidence is linked with the right product with the right claim is the most critical thing that we are seeing so, overall it might seem that there is a lot of effort that you need and a lot of systems that you need but overall it’s a two, three year journey, I think brands who have been working with us for last five years are very comfortable because they have already adapted to it and overall we feel that some of these regulations will keep on coming, keep on changing its form but as an organisation you should focus on building that primary data foundation because maybe the use case today is green claim, tomorrow it is digital product passport, day after tomorrow it will be a regulation that we are not even aware about as of today, right so, as long as that primary data is there, then that data can be then massaged and then can be put into different reporting but establishing that foundation, that architecture overview is very, very critical so, I think the last thing that I would say is, don’t get afraid, I think it is a long journey, you know collaborate with organisations like us, us and Mishcon, who will give you that right kind of guidance on how to prepare and then I think it’s all about putting that first step in and once you are in, I think it is a smooth journey. I’ll pass it back to Alexa and Olivia.
Olivia Fulton
Mishcon de Reya
Thank you so much, Shubham, I think that’s a great note to end on that, yeah, obviously when we’re talking about all this legislation, it can feel overwhelming of how you start to, start to comply but as you said Shubham, it’s about taking that first step and also about focussing on collecting the data. So, we’ll just wrap up now, so yeah, as we mentioned at the beginning, please do download our guidebook which provides a lot more detail on the legislation, it’s listed around the wheel here. We do also offer kind of 30 minute consultations, I think there should be a popup at the bottom of your screen at the moment, where you can click through and book one of those, and that’s with someone from our team and it can be you know to chat about a specific issue that you have or also if you just generally kind of don’t know where to start and want to discuss what the next step would be to take, we can discuss that with you as well. So thank you so much for joining and also for bearing with us at the beginning, I really do apologise for the technical issues that we had. Thanks so much. Bye.