Emperor Sustainability Briefing 25.09.2025

Issue #5

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Green light, red light

With the EU finally passing a flagship ruling to limit textile waste, and Australia not just holding but – wait for it – upgrading its emissions targets, we might be building up a head of steam going into the COP30 climate summit – now only a month and a half away. 

Elsewhere though, there’s signs of caution. The UK’s EV transition might hit a charging roadblock, while the US isn’t slowing down on scrapping legislation. 

It’s all a bit stop-start – you’d be forgiven for feeling seasick…

In this Briefing…

EU EPR – Australia’s targets

US scraps emissions – UK EV charging

ASOS supply chain – ESG finance considerations

Youth investor ESG  – Nuclear tie-up

Regulation and frameworks

EU’s Textile EPR: A speed check for fast fashion?

The EU has finally greenlit its long-awaited Extended Producer Responsibility (EPR) scheme for textiles, meaning the days of the “make, sell, bin, repeat” model may be numbered. Under the revised Waste Framework Directive, companies putting textiles or footwear on the EU market (including online-only brands) will soon be mandated to fund the collection, sorting, and recycling of their products. The scheme covers everything from clothing and footwear to home linens, and aims to reduce the EU’s 12 million tonnes of annual textile waste – while giving brands a nudge to design for durability and recyclability. 

Each EU Member State must roll out its own EPR scheme by summer 2028, with micro-enterprises afforded an extra year. The legislation also introduces requirements to reduce food waste by the end of 2030, including a 10% reduction from processing and manufacturing. Any UK business exporting textiles to the EU single market will be required to comply fully with this regulation. The UK’s own Circular Economy Taskforce is working on the UK’s own EPR to mirror the EU’s – something of a theme in UK sustainability regulation post-Brexit – but we haven’t heard much about this yet. 

Although it’s been on the horizon for a while, the introduction of EPR for textiles will be significant for fashion and furnishings companies, who will now be required to have further oversight on the lifecycle of their goods. This will likely become an important part of communications and disclosure for companies in affected sectors – get in touch with us if you’d like to chat through what it might mean for you. 

Policy

Australia raises its emissions reductions target

Australian Prime Minister Anthony Albanese has increased the country’s emissions reduction target for 2035 from 62% to 70%, a substantial increase in ambition. With countries working to establish their Nationally Determined Contributions (NDCs) to emissions reductions ahead of November’s COP30 climate summit, a strengthened target is encouraging, particularly given existing criticism of Australia over the country’s continued dependence on fossil fuels. 

US EPA to scrap emissions reporting requirements 

The US Environment Protection Agency (EPA) has proposed to end its Greenhouse Gas Reporting Program (GHGRP), the regulation mandating emissions measurement and disclosure from the most carbon-intensive facilities in the US. The announcement makes a point of estimating the financial savings that the scrapping of this ruling might create for oil and gas companies in particular, which is thematically in line with the Trump administration’s aim of removing ‘red tape’ and supporting fossil fuel production. The proposal comes just a few weeks after the EPA proposed to rescind the 2009 ‘Endangerment Finding’, a foundational piece of legislation for US action on climate change. And in his firebrand address to the UN on Tuesday, Trump called climate change the “greatest con job ever perpetrated on the world” – don’t expect them to slow down now. 

Charging costs puts the brakes on the UK’s EV rollout momentum

A new analysis by trade body ChargeUK and Cornwall Insight shows the charging sector’s energy bills have increased by 79% since 2021. With standing charges up 462% at rapid charge sites, and a 20% VAT rate on public charging (compared to 5% at home), the spike is hitting drivers without home chargers hardest – and undermines the overall affordability of EVs. Particularly in the context of cost-of-living challenges, the increases threaten the rate of consumer transition to electric mobility, which in turn affects the speed at which automotive companies can drive their own transitions. The study urges government intervention as a solution, including the inclusion of EV charging in the renewable Transport Fuel Obligation scheme. 

Corporate

ASOS signs supply chain deal to protect transport workers 

Fashion retailer Asos has signed a legally binding agreement with the International Transport Workers’ Federation (ITF) union to strengthen due diligence across its transport and logistics supply chains. The agreement will see ASOS be assisted with policy design and risk identification, a strong move towards protecting rights within the business’ activities. With fashion retail often reputed as an area with weak social supply chain oversight, the news might provide a precedent for actions that companies within the same sector can take. Coming alongside the approval of the EU’s new textile laws (see above), it’s been a busy two weeks for the industry!

Finance

Morningstar study shows asset owners maintaining ESG fundamentals 

Green shoots are beginning to emerge in the financial sector despite ongoing anti-ESG pressures following Morningstar’s latest annual global survey of 500+ asset owners. The survey, whose participants ranged from pension funds to family offices, found that 58% of asset owners believed the importance of ESG had increased in the last 5 years. The only country who believed ESG had become less material was the US, with the term ‘responsible investment’ appearing to be a more popular term now across North America. 

In terms of what asset owners are actually doing, the number that accounted for ESG-related factors across their entire portfolio has doubled since last year, with the most important factors being energy management, physical climate risks and low-carbon transitions. With Morningstar’s analysis being well reputed, the news can be taken as an indication that the fundamentals of green finance haven’t gone away, with the landscape pointing towards a divergence of approaches rather than a widespread withdrawal. 

ESG remains popular amongst younger investors 

Investment manager Vanguard has released data indicating that younger, and female, investors were much more likely to pursue ESG-focused voting policies. In an analysis of 82,000, it was found that 42% of investors under 45 favoured ESG, compared to only 17% above that age bracket. Female investors in turn stood at 28% favouring ESG, compared with 16% of male investors. Although total ESG policy votes in the study fell by 6%, this news pairs with the Morningstar study above to paint a picture of ongoing belief in ESG from many investor pockets – suggesting that current drawbacks may be a precursor to a return to form in due course. 

Energy

UK and US reactor tie-up, EU recognises nuclear sustainability 

Glitz at Windsor, politics at Chequers – and nuclear at Hartlepool. Announced prior to Trump’s state visit, a timely UK and US tie-up will see Britain’s Centrica pair with US reactor firm X-energy to build up to 12 new Advanced Modular Reactors (AMR) in north-east England. While AMRs are a novel technology, and nuclear energy’s environmental impacts remain hotly debated, the move reflects a vote of confidence from the current government in nuclear as a key pathway for phasing out fossil fuel generation. Relatedly, the EU this month settled a long-running lawsuit opposing the inclusion of gas and nuclear energy in the EU Taxonomy, its classification system for activities deemed to be ‘sustainable’, ruling that nuclear could deliver energy at near-to-zero emissions and at sufficient scale to meet energy demand sustainably. While the issue of nuclear waste remains unresolved, 2025 has seen the energy type make meaningful strides towards further expansion. 

One Number:

$1.25 trillion

The projected five-year cost of nature loss to eight key sectors, including food, retail, and pharmaceuticals, according to climate non-profit Ceres. Their report found the steepest financial risks in the food production sector, which will have to face increased drought conditions and reduced yields.

Short List:

Asahi UK has transitioned its Cornish Orchards cider production site to operate entirely using renewable energy, eliminating fossil fuel use on-site. 

Octopus Energy has partnered with Chinese wind turbine manufacturer Ming Yang Smart Energy, which may see the first Chinese-made wind turbines installed in Britain. The partnership supports the energy supplier’s Winder initiative, matching project developers with communities that want wind farms.

Microsoft has signed a deal worth of over $6bn with AI company Nscale and industrial investment company Aker, providing Microsoft with 100% renewable energy to power a new large-scale AI infrastructure project in Northern Norway.

To discuss any of these topics in more detail or speak to one of our Sustainability team about how to better your corporate sustainability efforts, email [email protected] -we'd love to hear from you.