Innovation in extended producer responsibility: EPR for textiles

What Is EPR for Textiles?

Extended Producer Responsibility (EPR) requires manufacturers and retailers to take responsibility for the entire lifecycle of their products — from production and use to disposal or recycling. In the textile sector, this includes clothing, shoes, home textiles, and other textile products. Companies that place such products on the EU market are responsible for their collection, sorting, reuse, and recycling.

The goal of EPR is to reduce the environmental impact of textile waste and promote a circular economy. Around 5.8 million tons of textile waste are generated annually in the EU, but only 30–35% is collected for reuse or recycling. Less than 1% undergoes fiber-to-fiber recycling — meaning new garments made from recycled fibers. EPR aims to change this by encouraging manufacturers to design more durable, repairable, and recyclable products. They must also bear the cost of disposal.

What This Means for Companies:

• Registration requirement: Companies must register in national producer registers, similar to Germany’s LUCID system for packaging.

• Fees: Quantity-based contributions finance collection and recycling systems. These fees can be reduced through eco-modulation if products are designed to be more environmentally friendly.

• Take-back systems: Companies must join existing systems for collection and recycling or implement their own compliant systems.

The New EU-Wide Regulation

With its EU Strategy for Sustainable and Circular Textiles launched in March 2022 as part of the European Green Deal, the EU laid the foundation for a harmonized EPR scheme for textiles. This will be legally established through the revised Waste Framework Directive (2008/98/EC). The aim is to make the textile industry more sustainable and reduce inconsistencies between member states.

As of January 1, 2025, separate collection of textiles will be mandatory in all EU countries. Municipalities and waste management entities must provide collection options such as containers or in-store drop-off points. Producers will bear the cost of this infrastructure, as well as the costs of sorting, reuse, and recycling. Fees will be eco-modulated, meaning longer-lasting, repairable, or recyclable products will incur lower fees.

On June 17, 2024, the EU Council defined further details:

• Obligation for all businesses: Even microenterprises are subject to EPR, with some exemptions for very small volumes.

• Targets: By 2028, member states must meet specific goals for waste prevention, collection, reuse, and recycling.

• EU-wide transparency: A central website will link to all national producer registers to simplify compliance.

• Implementation period: Member states have 24 months from the directive’s entry into force to establish national EPR systems (extended from the initial 18 months).

Some countries are already ahead: France has had an EPR system for textiles since 2008, and the Netherlands introduced theirs in July 2023. In France, textiles must carry the Triman symbol, which indicates separate collection. Sweden, Portugal, and Hungary are currently developing their own systems. The EU directive aims to unify these efforts. Until full harmonization is in place, companies operating in multiple countries must comply with each nation's requirements.

The EU also plans to influence product design — textiles should contain fewer harmful substances and be easier to recycle. This is supported by the Ecodesign for Sustainable Products Regulation (ESPR), which is being developed in parallel to EPR.

Current Status in Germany

Germany does not yet have a mandatory EPR system for textiles, but its introduction is imminent. EU directives must be transposed into national law by no later than 2027. Industry bodies — notably the German Association for Secondary Raw Materials and Waste Management (bvse) — are already calling for EPR to support existing infrastructures for collection, sorting, and recycling.

Starting January 2025, separate textile collection will be mandatory in Germany. This will initially affect consumers and municipal waste services, who must provide appropriate collection systems. However, EPR will pose a much greater challenge for companies, which must prepare for registration obligations, fees, and participation in take-back schemes.

In 2023, the German Environment Agency (UBA) developed four potential EPR models, ranging from voluntary industry initiatives to mandatory systems. Final implementation details remain open, but all models emphasize the importance of incorporating existing systems such as secondhand markets and social enterprises.

Companies selling textiles in Germany should begin preparations now — especially if they are already active in countries like France or the Netherlands, where additional obligations like Triman labeling apply. In Germany, registration will likely occur through a system similar to the LUCID portal used for packaging compliance.