EU Adopts New Textile EPR Requirements

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In September, the European Union (EU) took a significant step to address textile waste and recycling through amendments to the EU Waste Framework Directive (WFD).  Under Directive (EU) 2025/1892, Member States must implement extended producer responsibility (EPR) schemes for textiles, establish national registers of textile producers, and adopt measures to improve the collection, sorting, and management of used textiles.

According to the directive, “[t]he appropriate collection of textiles will contribute to reducing the presence of waste synthetic textiles in the environment, including in terrestrial and marine ecosystems, by ensuring that textiles are reused, recycled and ultimately given a new life, thereby promoting a circular economy.”

Member States must transpose the amendments into national law by June 17, 2027.

Products Covered

The amendments apply to a broad range of textile, textile-related, and footwear products, including:

  • Articles of apparel and clothing accessories (including leather)
  • Blankets and travelling rugs
  • Bed/table/toilet/kitchen linen
  • Curtains and interior blinds
  • Worn clothing
  • Hats and other headgear
  • Footwear
EPR Requirements

Member States must establish textile EPR schemes by April 17, 2028.  The directive defines “producers” to include not only entities established in a Member State, but also foreign manufacturers, importers, and distributors that sell covered products directly to end users through distance contracts.

Producers will be required to cover the costs of collecting used textiles, transporting and sorting them based on their capability for reuse, and subsequent reuse and recycling operations.  These obligations will be fulfilled through producer responsibility organizations (PROs), which will collect fees from producers.  EPR fees must:

  • Be based on the weight, and, where appropriate, the quantity of the products placed on the market;
  • Be eco-modulated (i.e., adjusted based on sustainability criteria); and
  • Account for revenue generated by the PRO from reuse or recycling activities.

PROs may also modulate fees to discourage fast fashion practices.

The amendments do not exempt small producers from EPR obligations.  However, PROs are prohibited from imposing disproportionate fee burdens on small and medium-sized enterprises and must ensure equal treatment of producers regardless of size or origin.  Member States are encouraged to authorize multiple PROs to encourage competition, innovation, and cost efficiency.

Additional Obligations

Member States must establish national registers of textile producers.  Producers will be required to register in each Member State where they make textile products available, providing information such as their name, trademark, and brand names.  Where a producer has appointed a PRO, the PRO may fulfill these registration obligations on the producer’s behalf.

To address concerns that textile waste is frequently exported under the guise of reusable products, the directive introduces new shipment controls.  Textiles assessed as fit for reuse must be accompanied by evidence demonstrating their reusability, and exporters must retain records of the sorting process and professional assessments supporting that determination.

The directive also requires Member States to ensure that sorting operations:

  • Prioritize local sorting and local reuse;
  • Are conducted on an item-by-item basis that separates textiles fit for direct reuse from those that need additional preparation for reuse; and
  • Prioritize remanufacturing over recycling for textiles not suitable for reuse.

More on the WFD amendments, which also include measures addressing food waste, is available in a European Commission news article.