Extended Producer Responsibility (EPR) for Textiles in the EU

EU Textile Extended Producer Responsibility (EPR)

The revised EU Waste Framework Directive establishes a common minimum framework requiring every Member State to create EPR schemes for covered textiles, textile-related products, and footwear. The core business change is that producers must help finance and, through scheme arrangements, support products’ end-of-life management. National systems may differ, so companies selling across Europe will need to track obligations country by country.

Business context and policy direction

• The textile sector supports around 1.3 million jobs and 200,000 businesses in Europe.
• European Commission assessments cited in the workshop rank textiles as the EU’s fourth most impactful consumption category, third for water and land use, and fifth for raw-material use and greenhouse-gas emissions.
• EPR extends producer responsibility beyond the point of sale. Contributions are intended to fund collection, sorting, preparation for reuse, recycling, consumer information, and reporting.
• The policy is designed not only to finance waste management, but also to encourage products that are more durable, repairable, and resource-efficient, and to increase reuse and recycling.

Framework and timeline

• The EU’s 2020 Circular Economy Action Plan identified textiles as a priority value chain.
• The 2022 EU Strategy for Sustainable and Circular Textiles set a 2030 vision: textile products should be durable, repairable, recyclable, largely made from recycled fibres, and free from hazardous substances.
• From 1 January 2025, Member States were required to establish separate textile collection systems.
• The revised directive entered into force in October 2025, according to the workshop. EPR financing obligations apply from October 2025 where a scheme was already in place; elsewhere, they begin when national measures take effect.
• In all cases, the obligations must apply no later than 17 April 2028. Implementation will therefore be phased across Member States.

Who is affected

Covered producers include businesses placing listed products on an EU market for the first time, such as:

• Manufacturers, importers, brands, and online retailers.
• Businesses outside the EU selling directly to EU consumers, including through distance-selling channels.

The workshop notes exclusions including suppliers of used products fit for reuse, products derived from used or waste products, and self-employed tailors making customized products.

Operational playbook for producers

• Register in each relevant Member State. Producers must be listed in the national register wherever they first place covered products on the market. Where required, an authorized representative must meet this obligation.
• Check representative requirements. Companies selling from another EU country must appoint an authorized representative in the destination Member State. For non-EU companies, Member States may decide whether one is required.
• Join an authorized Producer Responsibility Organization (PRO). A PRO handles EPR obligations for producers and may be responsible for financial duties alone or both financial and operational tasks, depending on the scheme.
• Budget for end-of-life costs. Eligible costs can include collection of used products for reuse; separate collection of waste; transport, sorting, preparation for reuse, recycling, other recovery, and disposal; and collection and treatment carried out by social-economy entities and other participating actors. Funding may also cover consumer information campaigns, waste-composition surveys, data collection and reporting, and research and development.
• Prepare for eco-modulated fees. Contributions are based on product weight and, where appropriate, quantity. Member States must account for relevant ecodesign requirements and may consider fast-fashion or ultra-fast-fashion models, including product durability, potential for use by multiple owners, and how effectively waste is converted into raw materials.
• Build data and reporting processes. PROs must publish key performance data at least annually, subject to commercial and industrial confidentiality.

Reporting metrics and smaller-producer rules

Reported information may include:

• Products first placed on the market.
• Collection volumes and reuse and recycling performance.
• Recovery and disposal outcomes.
• Exports of reusable and used products and waste.

For a producer with fewer than 10 employees and annual turnover and balance-sheet totals of no more than €2 million, reporting is simplified: the PRO must request only the amount of products first placed on the market, including their weight.

Practical implications

Businesses should begin mapping covered products and destination markets, identifying registration and representative requirements, assessing PRO options, and improving product and sales data. They should also plan for fees and reporting across multiple national systems. The directive prioritizes prevention and preparation for reuse and reuse before recycling, so product design and waste-prevention practices may affect both compliance and future costs.

Presenter and sources mentioned: Perla Gandara, TEIMAS Workshop. The workshop refers to the revised EU Waste Framework Directive, the European Commission’s Consumer Footprints assessments, and the EU Strategy for Sustainable and Circular Textiles.