Discover why the EU is introducing Extended Producer Responsibility (EPR) for textiles and footwear, how the new framework works and what businesses need to prepare for.
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The world faces a growing textile waste challenge.
Until recently, in the EU, textile producer responsibility requirements were fragmented across Member States, with only a few countries operating dedicated textile EPR schemes.
The revised Waste Framework Directive introduces, for the first time, harmonised minimum requirements for Extended Producer Responsibility schemes covering textile, textile-related and footwear products across all EU Member States.
In this article we’ll explore the new Extended Producer Responsibility requirements for textiles and footwear in the European Union, the origins of EPR and what the new textile EPR requirements mean for businesses across Europe.
The textile sector plays a central role in the European economy, supporting around 1.3 million jobs and nearly 200,000 businesses. Yet its scale also means that its environmental footprint is substantial.
According to European Commission assessments of consumer consumption footprints, textiles are the fourth most impactful consumption category in Europe overall, after food, housing and mobility. They rank third for water and land use impacts and fifth for raw material use and greenhouse gas emissions.
This has raised important questions about how products are designed, consumed, collected and managed at the end of their life.
To address these challenges and support the transition towards a more circular economy, the European Union has introduced a range of measures aimed at improving the sustainability of the textile value chain. One of the most significant of these measures is Extended Producer Responsibility, or EPR, a policy approach that places greater responsibility on producers for the environmental impacts of their products throughout their lifecycle.
Extended Producer Responsibility, or EPR, is an environmental policy approach that extends a producer’s responsibility for a product beyond the point of sale and into the product’s end-of-life stage.
Within EU legislation, Extended Producer Responsibility is defined under Article 8 of the Waste Framework Directive and has become one of the main policy instruments used to implement the polluter pays principle and improve resource efficiency across product value chains.
Under the revised framework, producer contributions are intended to cover the costs necessary to ensure separate collection, sorting, preparation for reuse and recycling of textile waste, as well as information and reporting obligations associated with the schemes.
However, EPR is also designed to encourage producers to improve product design, reduce waste generation and increase the reuse and recycling of materials. By linking end-of-life costs to products placed on the market, EPR creates incentives to make products more durable, repairable and resource-efficient.
Over the past decades, EPR has become a well-established instrument across the European Union. It is already applied to several product categories, including packaging, batteries, electrical and electronic equipment, and end-of-life vehicles.
The textile sector is now following the same path. As part of the EU’s transition towards a circular economy, textiles and footwear have become the latest product categories to be brought under a harmonised Extended Producer Responsibility framework across the European Union.
The introduction of Extended Producer Responsibility for textiles is part of a broader policy agenda aimed at accelerating Europe’s transition towards a circular economy.
A key turning point came in 2020 with the adoption of the Circular Economy Action Plan under the European Green Deal. For the first time, textiles were identified as one of the priority value chains requiring specific action, and the Commission announced the development of a dedicated EU Strategy for Sustainable and Circular Textiles.
That strategy was published in 2022 and set out a long-term vision for the sector. It established the policy vision that, by 2030, textile products placed on the EU market should be durable, repairable, recyclable, largely made from recycled fibres and free from hazardous substances.
The strategy also acknowledged that improving the sustainability of textiles would require stronger measures at the end-of-life stage. It therefore paved the way for the introduction of mandatory Extended Producer Responsibility requirements, which were later incorporated into the revised Waste Framework Directive.
Another important milestone followed on 1 January 2025, when Member States became required to establish separate collection systems for textiles.
However, collection alone was not enough. To support the costs of collecting, sorting, preparing for reuse and recycling growing volumes of textile waste, a dedicated financing mechanism was needed.
This led to the revision of the Waste Framework Directive, which entered into force on 16 October 2025. For the first time, all Member States are required to establish Extended Producer Responsibility schemes for textiles and footwear, making producers responsible for contributing to the end-of-life management of the products they place on the market.
Textile EPR should therefore be understood as one element of a broader regulatory framework that also includes ecodesign requirements under the Ecodesign for Sustainable Products Regulation (ESPR), Digital Product Passports, restrictions on the destruction of unsold products and enhanced sustainability information requirements.
The revised Directive explicitly aims to move textile management higher up the waste hierarchy, prioritising waste prevention, preparation for reuse and reuse before recycling.
The new rules establish a common framework across the European Union, while allowing Member States to determine how their national schemes will operate in practice. Producers will be required to contribute financially through EPR fees, which will support the development and operation of textile waste management systems.
The scope extends beyond garments and footwear and includes a broad range of textile-related products identified in Annex IVc of the Directive, covering household textiles, accessories and other specified textile articles.
Importantly, the obligations are not limited to companies established within the European Union. The rules also apply to producers selling through distance-selling channels, including online platforms, ensuring that all businesses placing textile products on the EU market are subject to the same responsibilities.
A question many organisations are now asking is: when will these new requirements actually start to apply?
Although the revised Waste Framework Directive entered into force on 16 October 2025, the new obligations are not implemented overnight. The Directive provides Member States with a transition period to incorporate the new requirements into national legislation and to establish the necessary Extended Producer Responsibility systems for textiles and footwear.
Following the entry into force of the revised Directive, Member States have 20 months to transpose the provisions into national law and 30 months to ensure textile EPR schemes become operational.
This means that implementation will take place progressively across Europe over the next few years. While some countries may move faster than others, textile EPR schemes are expected to become operational across the European Union between 2027 and 2028.
As a result, the period between 2026 and 2028 will likely be characterised by significant regulatory activity at national level, including the designation of producer responsibility organisations, registration requirements and fee-setting methodologies.
The Textile EPR rules apply to producers of the textile, textile-related and footwear products listed in Annex IVc. Essentially, it covers anyone putting textiles or footwear onto the EU market for the first time. We’re talking about manufacturers, importers, brands and online retailers. This includes businesses selling directly to EU end-users via distance-selling channels.
There are also important exclusions. The definition of producer does not include operators that supply used products fit for re-use, products derived from used or waste products or, for example, self-employed tailors producing customised products.
Register in each Member State where products are first placed on the market
Each Member State must establish a register of producers. Producers will need to apply for registration in every Member State where they make covered textile, textile-related or footwear products available on the market for the first time.
A producer will only be allowed to place covered products on a Member State’s market if they are listed in that country’s register. Where applicable, that same registration requirement falls onto their designated, authorized representative for EPR.
There is one important distinction. Companies selling from another EU country must appoint an authorised representative in the Member State where they sell their products. For companies based outside the EU, Member States can decide whether that representative is required.
Entrust a Producer Responsibility Organisation
Under the new rules, producers will need to join a Producer Responsibility Organisation, or PRO, which will fulfil their Textile EPR obligations on their behalf.
PROs will be at the heart of the system. They will manage EPR obligations on behalf of producers. Depending on the scheme, they may take on financial responsibilities only, or both financial and operational responsibilities. PROs must also be authorised by the competent authority.
Finance collection, sorting and treatment
Producers must cover the costs linked to the management of used and waste textile, textile-related and footwear products covered by Annex IVc. These costs include the collection of used products for re-use and the separate collection of waste products for preparing for re-use and recycling.
These costs also cover transport, sorting, preparation for re-use, recycling, other recovery operations and disposal. In addition, producers must finance the collection, transport and treatment of waste managed by social economy entities and other actors that are part of the collection system.
Producers must also fund a number of additional activities. These include compositional surveys of mixed municipal waste, information campaigns for consumers, and data collection and reporting. They must also support research and development to improve product design, prevent waste and enhance waste management in line with the waste hierarchy.
Member States may also require producers to cover, partially or totally, the costs associated with covered products ending up in mixed municipal waste.
Prepare for eco-modulated fees
Producer financial contributions must be based on the weight and, where appropriate, the quantity of the products concerned.
For textile, textile-related and footwear products, producer fees must also take ecodesign requirements into account. These requirements are set under the Ecodesign Regulation.
Member States may also take fast-fashion and ultra-fast-fashion business models into account when setting EPR fees. They may consider factors such as how long products are designed to last, whether they can be used by more than one owner, and how effectively textile waste is turned into raw materials for new products.
Provide data and reporting
Reporting will be a core part of the system.
At least once a year, PROs must publish key performance data, while respecting commercial and industrial confidentiality. They must report on products placed on the market, collection volumes, re-use and recycling performance, recovery and disposal outcomes, and exports of both re-usable used products and waste.
For smaller producers, reporting is simpler. If a company has fewer than 10 employees and annual turnover and balance sheet totals of no more than EUR 2 million, the PRO must request only information on the amount of products placed on the market for the first time, including their weight.
Also, the Directive introduces specific controls for online sales and fulfilment services.
The new EU Textile EPR requirements will bring new obligations around reporting, traceability and waste data management. For many organisations, this means more spreadsheets, more documentation and greater compliance complexity.
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