From laundry to legislation - navigating Europe’s textiles EPR

Textiles include clothing and accessories, hats, footwear, blankets, bed and kitchen linen, and curtains. The definition of a producer remains broad and it’s worth spending the time to properly review your sales channels, because the obvious answer isn’t always the right answer. The rule of thumb is that:  

If you make, import or sell textiles, accessories, or footwear in the EU, you are IN scope.  

Second-hand goods, recycled materials, and bespoke pieces from independent tailors are OUT of scope. 

But it is not just about who sells, it’s about who places goods on the market. That includes online platforms, drop-shipping models, and even brand collaborations. If you are unsure, reach out to us and we can assess if you will be obligated.  

How will textile producers fees be spent? 

Producers will be expected to cover costs for: 

• Collection and transport 
• Sorting, recycling, and disposal 
• Consumer awareness campaigns 
• Record-keeping and reporting 
• Investment in better design and recycling tech

What can you expect from PRO’s (Producer Responsibility Organisations)? 

• PROs must offer consistent service nationwide and be officially authorised 
• Producers will need to report annually to PROs on what’s sold, collected, reused, recycled, and exported 
• PROs will calculate fees depending on how much is put on the market, with adjustments made for eco-friendly design and circularity 
• PROs must also run consumer education campaigns about sustainable choices and recycling

The real-world challenges 

Compliance in the EU brings it’s own challenges. Each member state will implement the rules in its own way, so expect a patchwork of systems across Europe. This means that recycling targets, reporting requirements, and fee structures will differ, making cross-border compliance tricky. Brands operating in several countries will have to juggle multiple registrations and reporting processes.  

Needless to say, smaller businesses may find the admin and reporting requirements tough to manage, but businesses classed as a micro-enterprise will have an extra year to comply with the new requirements. 

There are still many grey areas to be clarified too, including how recycled content will be counted, what happens to deadstock, and how recycled materials are used. 

Where is Textiles EPR already in place?  

Countries with existing textile EPR schemes will also need to update them to fit the new directive, including: 

• France that has had a scheme in place since 2007 
• Latvia implemented a scheme in 2024 
• The Netherlands and Hungary are set to launch schemes in 2025 
• Sweden, Italy, Spain, Bulgaria, and Norway are also working on their own versions

Let’s iron this out  

Just like your laundry basket, the compliance load keeps refilling, and if you don’t stay ahead of it, you’ll be stuck trying to dry things out in the rain. The EU’s updated Waste Framework Directive is a big one, especially for textiles, and it’s going to reshape how producers, retailers, and compliance teams operate across the continent. 

The more you understand now, the better prepared you’ll be when the time comes to comply. When it comes to compliance, early action beats last minute panic every time. 

If you need more help to understand more about how your business is impacted, simply contact our team.