Understanding Extended Producer Responsibility for Textiles in the EU

Extended Producer Responsibility (EPR) is a regulatory framework that holds producers responsible for their products' entire lifecycle. This includes the design, production, take-back, recycling, and disposal stages, minimizing waste destined for landfills and increasing recycling rates. The European Union (EU) has existing EPR directives for packaging, Waste Electrical and Electronic Equipment (WEEE), and batteries, but emerging legislation will focus on the textile industry. The EPR for textiles strategy will be mandatory and is expected to be harmonized across Member States, to increase the circularity of textile products – utilizing similar methods for existing EPR waste streams.  

EPR policies shift responsibility upstream towards the producer and away from municipalities. Producers must manage and finance waste collection, recycling, and disposal. Read our blog “What Is Extended Producer Responsibility?” for a more general overview of EPR. 

What is to be expected from the EU’s EPR for textiles? 

The Extended Producer Responsibility for Textiles proposal makes producers and importers of textiles responsible for the entire lifecycle of their products. Textile products include clothing, accessories, footwear, linens, and curtains. Products containing textile-related materials, such as leather and plastic, are also expected to be within scope. This is to address the fact that textile consumption – and waste – is the fourth largest contributor to environmental pollution and climate change. Companies will not only need to focus on the eco-friendly production of textiles but also on their end-of-life management, focusing on utilizing the Waste Framework Directive’s waste hierarchy. Key elements of the proposed rules include: 

  • Enacting national registers for textile producers
  • Implementing an eco-modulation system to finance the collection, sorting, re-use, and recycling of textiles  
  • Increasing the circularity of products - moving away from ‘fast fashion’ 

The proposed amendment to the Waste Framework Directive fits into the larger goal of having only durable, repairable, and recyclable textiles on the EU market by 2030. There are also direct links with the Eco-design for Sustainable Products Regulation. The EU has published an EPR Textiles factsheet on the topic to provide more detailed information.       

  • Companies will be required to demonstrate compliance with the EPR rules, emphasizing the need for a comprehensive approach to sustainable textile products and their production, waste management, and supply chain cooperation. To comply, companies must adapt their production processes, product designs, supply chains, and waste management strategies, and register with a Producer Responsibility Organization (PROs). 
  • Requirements will be dependent on the schemes in specific member states but will always involve some sort of responsibility for the collection and reuse of textile waste either per company or collectively through PROs. The designation of such organizations is another concrete example of the impact of these rules.  
  • PROs will be authorized by the relevant National Authority and will (among other things) manage financial contributions from producers, establish separate collections systems for used and waste textiles, and make available information on the sustainable aspects of textiles to end-consumers. 

Examples of EPR textiles legislation

Current EPR textiles legislation in France and the Netherlands serve as examples of what to expect from the EU’s new directive. 

In France, manufacturers are accountable for the reclamation, recycling, and disposal of their textile products. They are currently the only country with this kind of EPR system in place. Producers, distributors, and importers must manage the end-of-life processes for their products. This requires them to either self-manage their compliance by creating their own approved recycling program or by delegating their responsibilities to an existing Producer Responsibility Organization (PRO). The French government has issued an Order encouraging brands to use recycled materials, display environmental labels, and champion more sustainable processes. 

The Netherlands’ Ministry of Infrastructure and Water Management implemented EPR legislation for textiles in 2023. The law requires producers to finance a reliable system to gather, recycle, and reuse textiles. The legislation affects all companies that sell clothing on the Dutch market, as well as partially recycled material. It also includes foreign and domestic online retailers that sell products within the Netherlands. Producers must also offer collection points for consumers to drop off used textiles, enhancing a new circular economy.  

What are the goals of EU EPR for textiles? 

The EU’s new EPR for textiles directive aims to harmonize EPR requirements across EU member states, reducing compliance complexity for companies operating in multiple jurisdictions. The goal is that these regulatory changes will: 

  • Require textile companies to rethink their product lifecycles 
  • Enhance their sustainability practices  
  • Ensure compliance with new reporting and financial obligations 
  • Manage textile waste in line with the waste hierarchy: used clothes to be directed as a priority to re-use; more textile waste to be recycled   
  • Incentivize producers to increase the circularity of products by design 
  • Boost circular economy business models  
  • Encourage timeless fashion over fast fashion 

The EU is also working on establishing clear end-of-waste criteria for textiles, which will define when recycled textile waste can be reclassified as a product. Requiring textile producers to adapt to the new directive will help to reduce textile waste, promote reuse and recycling, and increase sustainable industry practices, which will further support the circular economy. 

The Waste and Resources Action Program (WRAP) report on the proliferation of EPR systems for textiles highlights the increasing adoption of EPR schemes globally to manage textile waste. These systems are important in addressing the significant greenhouse gas emissions caused by textile production. The EU is one of many countries implementing EPR policies for textiles based on environmental benefits. Though these new EPR initiatives create economic implications for producers, there is a clear need for comprehensive textile management systems and a global reduction of textile waste.  

How can producers prepare for textile EPR legislation?  

There are several actions businesses on the EU market can take to prepare for EPR for textiles and reduce their risk.  

  • Work towards a more structured data collection process in collaboration with vendors, suppliers, and other supply chain partners 
  • Approach design with the sustainability of your products in mind
  • Conduct a comprehensive review of textile production and waste management processes 
  • Invest in technologies or systems to track and manage products and supply chains 
  • Explore certifications or partnerships that can aid in compliance and sustainability efforts 

Ensuring compliance with the new EPR for textiles strategy is crucial, as noncompliance can result in significant financial penalties, increasing operational risk for producers.  

Learn more about EPR with Source Intelligence’s introductory e-book  

EPR is a complex policy approach that leaves producers with new responsibilities and added complexities within their supply chains. As EPR policies continue to emerge worldwide, having a clear understanding of EPR and what it means for your business is essential. If EPR is relatively new to you, our introductory e-book on EPR will educate you on the basics, including what EPR means for producers, the challenges of EPR compliance, and EPR compliance in practice.  

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