ESPR Textile Delegated Acts published — impact on durability and recyclability · CSRD Omnibus proposes delay for SMEs — vote in European Parliament · DPP Technical consultation on interoperability standards closes Jun 2026 · CSDDD Due diligence directive: transposition deadline confirmed for Jul 2026 · REACH Proposed PFAS restriction in textile processing — open consultation · GREEN CLAIMS Directive in force — transposition by Member States by Jul 2026 · ESPR Textile Delegated Acts published — impact on durability and recyclability · CSRD Omnibus proposes delay for SMEs — vote in European Parliament · DPP Technical consultation on interoperability standards closes Jun 2026 · CSDDD Due diligence directive: transposition deadline confirmed for Jul 2026 · REACH Proposed PFAS restriction in textile processing — open consultation · GREEN CLAIMS Directive in force — transposition by Member States by Jul 2026 ·
CASCO Score · Canindé

Prospective regulatory vulnerability assessment

The CASCO does not measure what your company has already done on sustainability. It measures how exposed it is to regulations that have yet to enter into force — before they become real contractual and operational risks.

Regulatory Compass
Fashion & Textile · EU Green Deal
What is CASCO

ESG Performance ≠ Regulatory Preparedness

Instruments such as EcoVadis, B Corp and GRI measure present environmental and social performance. They are outcome tests. CASCO measures something different: prospective vulnerability — how positioned a company is (or is not) to meet the demands of the European Green Deal over the next 2 to 5 years.

The finding that gave rise to CASCO: Richemont — with a GRI report verified by external auditors — scored 28% on CASCO. Inditex, frequently criticised for the scale of its production, scored 74%. ESG performance and regulatory preparedness are orthogonal dimensions.

Think of it as preventive medicine: a check-up that identifies where a company is vulnerable before the regulator or the client demands compliance.

The 5 CASCO Domains

Assessment architecture

Each domain is anchored in current or pending mandatory legislative text. The weights reflect current regulatory intensity for the European textile sector.

E5 · Circularity
Circularity
35%
ESRS E5 · ESPR · DPP · EPR
End-of-life management, design for disassembly, Digital Product Passport, extended producer responsibility.
E1 · Climate
Climate
30%
ESRS E1 · CSRD · SBTi
Scope 1–3 emissions, science-based climate targets, CSRD reporting and transition plans.
E3 · Water
Water
15%
ESRS E3 · WFD
Water management in dyeing processes, effluent treatment, compliance with the Water Framework Directive.
E2 · Pollution
Pollution
10%
ESRS E2 · REACH
Substances of very high concern, PFAS restrictions, compliance with REACH in textile products.
GOV · Governance
Governance
10%
ESRS G1 · CSDDD
Value chain due diligence, supplier policies, grievance mechanisms, tier-2 traceability.
How It Works

Three steps, from exposure to action

01
Assessment
Structured evidence collection across 5 regulatory domains. Document analysis of public reports, internal policies and existing certifications. Duration: 3–5 business days.
02
CASCO Score
Weighted scoring with application of the evidence coefficient (E0–E3) that penalises unverifiable claims and rewards external certifications. Result: 0–100% per domain and overall score.
03
Action Plan
Report of vulnerabilities prioritised by regulatory urgency and operational impact. Concrete recommendations per domain with a time horizon based on current legislative calendars.
Methodology · Evidence Coefficient

The anti-greenwashing mechanism

The E0–E3 adjustment system prevents statements of intent or ESG marketing from artificially inflating the regulatory preparedness score.

Greenwashing risk: generic statements without any measurable data or implementation proof.
E0
No evidence
−40%
Statements of intent or ESG marketing only, without data.
Click for context
Policy exists on paper but implementation cannot be independently verified — common in SME supply chains.
E1
Declared policy
−20%
Documented internal policy without verifiable implementation data.
Click for context
Baseline standard: public metrics that any third party can cross-check against the reported figures.
E2
Verifiable data
0%
Measurable metrics publicly available and verifiable by third parties.
Click for context
Gold standard: external audit or ISO/GRI certification provides the highest confidence in the data quality.
E3
External certification
+10%
Independent verification by accredited auditor or recognised certification.
Click for context
Download methodology (PDF)
Validated Cases

Three companies, three exposure profiles

Cases were built from public documents (annual reports, sustainability policies, GRI reports) and empirically validated in the academic research that originated the CASCO.

0
%
Inditex Group · 2024
Moderate Exposure
Well positioned in Climate (E1: 88%) and Governance (GOV: 84%). Critical gaps in DPP and tier-2 traceability.
0
%
H&M Group · 2024
High Exposure
Extensive sustainability reports but high E0/E1 coefficient. No verifiable DPP infrastructure.
0
%
Richemont Group · 2024
Critical Exposure
Externally verified GRI report. Low score due to absence of specific preparation for EU textile regulations.
The counterintuitive finding

Why Richemont scored below Inditex

Richemont has a sustainability report verified by external auditors to the GRI standard. Inditex is frequently criticised for the scale of its fast-fashion production. Yet CASCO measures a completely different dimension: specific preparedness for European Green Deal regulations — ESPR, DPP, CSDDD, textile CSRD. Inditex invested in the digital and operational infrastructure these regulations require. Richemont, focused on the luxury market, did not prioritise this dimension. ESG performance and regulatory preparedness are orthogonal dimensions.

Methodological Note

The case studies above were developed exclusively to validate the CASCO methodology, using publicly available information at the time of the analysis (2024). The results represent a specific point in time and do not constitute a permanent, current or official assessment of the companies mentioned. Subsequent changes to internal policies, processes, documentation, sustainability practices or regulatory compliance may significantly alter the outcome if the methodology were reapplied. CASCO is a regulatory exposure diagnostic tool — it does not replace independent audits or certifications, and does not constitute an official compliance opinion.

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