Harmonised EPR for Textiles

Positioning the EU at the Forefront of a Sustainable Textile Market

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Extended Producer Responsibility (EPR) has been recognised as a vital mechanism within the EU Strategy for Sustainable Textiles to address waste reduction and combat environmental deterioration associated with the textile industry. By 2025, each European Member State is expected to collect textile waste. This raises the question: How could an EPR scheme for textiles be implemented most effectively to drive system change for a circular economy? 

To explore this question and design the EPR scheme to maximise its impacts, and in the context of the recent publication of the Revision of the Waste Framework Directive last 5 July 2023, the Policy Hub co-authored a report with Eunomia Research & Consulting titled “Further Considerations to Textiles EPR and Complementary Measures“. As highlighted in the report: the implementation of EPR is instrumental in catalysing the shift towards circular economy practises within the textiles industry.


Most importantly, the report underscores the commitment to the “polluter pays” principle, ensuring that manufacturers are duly responsible for managing the end-of-life processes concerning textile waste products. Complementing the revision of the Waste Framework Directive (WFD), EPR provides an opportunity to harmonise the textile sector, which subsequently benefits European citizens and the European market. Failure to achieve harmonisation of Extended Producer Responsibility (EPR) schemes could lead to the fragmentation of the European textile market, with the scheme serving primarily as a waste-management system. However, if properly implemented, EPR for textiles holds the power to facilitate the transition towards a circular economy.


Why is EPR harmonisation necessary?


Many European countries are already proceeding with amending their respective EPR legislation around a current scheme, like France, or are developing and implementing new schemes, such as the Netherlands, Sweden and several more. Still, there is an inherent need for standardisation in certain parts of the policy process. This is because disparities and inconsistent approaches can lead to conflicting signals to producers and jeopardise the goal of a sustainable and effective textile industry. Harmonised EPR schemes, therefore, serve as a cornerstone for an effective and consistent approach across EU Member States. A harmonised approach will help to ensure the desired environmental outcomes, delivering higher rates of reuse, increasing the quality of recycled materials, and maximising the incentive through EPR for more sustainable design choices in the most efficient way.

What are the core objectives and underlying principles of EPR implementation?


In pursuing a more sustainable textile industry, EPR is a crucial element in any comprehensive strategy for moving towards a circular economy by addressing the issues connected to textiles’ end-of-life collection and management. The central objectives of EPR include:

  • Supporting design changes
  • Optimising separate collection
  • Supporting reuse and the development of high-quality recycling
  • Driving consumer behaviour change
  • Supporting innovation
  • Accounting for the costs of disposal

This holistic approach necessitates cooperation between producers, consumers, and policy enforcers to achieve shared sustainability goals.

Following the above, the report outlines defined objectives and principles that should guide EPR schemes. A fundamental takeaway is that EPR schemes should aim to address systemic issues in collecting and managing end-of-life textiles. For optimal functioning, the objectives and targets must be ambitious to drive change and to be economically viable for producers. This balance ensures the success of the scheme in the long run.

Who are the producers that should oblige to the EPR standards?


As outlined during the launch in Brussels: defining and understanding who ‘obligated producers’ are, is vital to ensure clarity of responsibility, policy effectiveness, and consistent implementation across markets for EPR schemes. The report proposes that an ‘obligated producer’ is an economic operator selling a new, finished textile product to a final consumer for the first time in an EPR jurisdiction.


To exemplify, obligated producers include physical and online retailers, online marketplaces, non-national sellers, and small and medium-sized enterprises (SMEs). While second-hand actors are currently excluded, this may change as their market share grows.


What products should be included in EPR standards?


For the same reasons that identifying ‘obligated producers’ is essential, it is important to define which products fall within the scope of EPR accurately. This consistency can also ensure the appropriate application of EPR principles, establish clear responsibilities, and enhance the effectiveness of EPR schemes.


The report recommends starting with clothing as the core waste stream, including both apparel and footwear. Other items should be included depending upon their compatibility with the collection, sorting and recycling infrastructures. Following this, the scope should be gradually expanded as understanding grows and the scheme matures. This staged approach ensures adaptability and compatibility with current and evolving infrastructures, allowing for real-time improvement whenever necessary.

How should we approach the standardisation of EPR reporting?


Another key takeaway from last week’s event was the crucial need to balance precision and granularity of reported data to enable an EPR scheme to allocate costs back to producers accurately and fairly while also considering feasibility for all producer sizes and actual EPR scheme needs.


While EPR schemes are expected to be national, with Member States applying a common set of principles by the EU, the report proposes that an integrated reporting system would be highly beneficial for the European market. This way, the EU would significantly reduce the administrative burden for producers reporting on their products across the EU market in different Member States.


The report details recommended reporting principles covering precision and granularity, alignment with other reporting requirements, the inclusion of stakeholders, data security, and the evolution of reporting requirements.


What comes after EPR?


Throughout the event in Brussels, one resounding message was reiterated: EPR is not a silver bullet solution, but it is critical for successfully implementing the EU Textile Strategy. EPR alone cannot address all sustainability challenges in the textiles sector. A complementary policy framework is necessary to address broader sustainability issues in the textiles value chain. The successful implementation of tools and policies, including the Ecodesign for Sustainable Products Regulation (ESPR), Waste Framework Directive (WFD), and proposal for Digital Product Passports (DPP), are needed to construct an integrated approach for holistically transforming the industry.


Acting on these changes will benefit the EU while setting a leading example for a global shift towards a more circular textile system. The EPR offers a substantial opportunity to incentivise reduced environmental impact at the design stage, which could drive a systemic transition in the textile industry. Now is the time for industry, policymakers, and NGOs to come together and seize this opportunity. Collaborative efforts and concerted action are crucial in driving positive industry shifts.


How does the recently published revision of the Waste Framework Directive interact with the report´s recommendations?


Published on 5 July 2023, the revision of the Waste Framework Directive lays down targeted amendments in the fields of food and textile waste. Amongst the new provisions on textiles, the revision introduces obligations for Member States to implement EPR schemes 30 months after its adoption (Art. 22a). It also introduces clauses calling upon and EU-wide harmonisation of EPR and calls for its financing through ecomodulation fees paid by producers and based on the ecodesign requirements as introduced in the ESPR. Additionally, it clarifies the products in scope and identifies the producers that will be subject to the new obligations (Art. 3), including online platforms placing products in the EU. As part of their new obligations, producers will have to register in a harmonised register to proof compliance with EPR obligations (Art. 22b). Finally, the proposal introduces further rules for the export of textile waste and used textiles (Art. 22d). As next steps, the proposal will now be referred to the European Parliament and the Council, giving start to the ordinary legislative procedure.


Since 2019, the Policy Hub – Circularity for Apparel & Footwear has been facilitating collaboration and harmonisation around the EPR mechanism. Supported by Global Fashion Agenda, this has involved the organisation of six roundtables which convened policymakers, brands, retailers, and recyclers, amongst other stakeholders around the topic. Most recently, this has encompassed the launch of a new series of webinars, where Member States and Producer Responsibility Organisations (PROs) are invited to share updates on their national-level EPR efforts.

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