Part 2 | Textile EPR producer: when are you considered a producer?

Textile EPR: what is Extended Producer Responsibility?

Extended Producer Responsibility is a system in which the producer is held responsible for the recycling of certain materials, in order to move Europe towards a circular economy. A circular economy is one in which a country or continent makes the most of the resources already available, rather than importing or generating new materials. In practice, this means a separate recycling system for textiles is being developed to reuse existing resources and create new textiles wherever possible. Textile producers are the ones who finance that recycling, through the producer responsibility fee system.

What counts as Clothing, Linen & Footwear (CLF)?

The potential CLF scope set out in the Directive is based on certain commodity codes. Examples of codes in scope are CN codes starting with 61 or 62. In practice, all textile items newly placed on the market are in scope, from clothing to linen, towels, shoelaces and accessories such as scarves, gloves and hats. Leather clothing and accessories are generally out of scope, given the long lifespan of the product and the nature of the material.

Who is a Textile EPR producer?

The textile producer definition is in line with WEEE EPR, Battery EPR and Packaging EPR compliance: ‘a producer of textile, textile-related and footwear product is any manufacturer, importer, distributor, or other natural or legal person who, irrespective of the selling technique used – including distance communication – is established in a European Union Member State and supplies for the first time in-scope products on the market.’

In practice, this means all first sellers are obliged to carry out textile EPR registration and reporting. And regardless of your position in the supply chain, you will have an information obligation. You may fall outside the textile EPR reporting scope, but as long as you are part of the textile supply chain, you are obliged to provide information. We will come back to how this affects your organization later.

Textile EPR in Europe: how implementation differs per Member State

Similar to WEEE compliance, the EU textile EPR framework operates under a harmonized European directive: a legal order or official guideline that sets out the actions to be taken based on the released documentation. It provides an outline of the requirements, operational timelines and protocols that every EU Member State must abide by.

While the European directive obliges each Member State to implement a CLF EPR regulation, each state is free to design the system that best suits the needs of the country and its inhabitants.

National implementation can therefore differ per Member State on several levels. The main differences are expected to lie in the obligated product scope and in the practical implementation on the market. The starting date of textile EPR compliance is set in the local legislation, with implementation due by 2028.

What Textile EPR means for your organization

Navigating a fragmented European CLF EPR landscape requires a highly structured internal organization. With up to 27 different regulations to follow, the impact on your organization is significant. More internal resources are needed to manage the differences in legislation and, more importantly, to run the automated internal data processes for product classification and wider compliance management.

How to prepare for Textile EPR registration

The compliance journey starts with determining your position in the supply chain. Are you a supplier, reseller or manufacturer, and who are your customers? A clear picture of your organization leads to a more organized EPR compliance process. Building a data system and settling the scope, classification, reporting and requirement implementation should be an immediate priority. You cannot create a CLF roadmap if you do not know where to begin.

With limited internal resources, a sound strategic move is to engage established EPR specialists who can support you with legal guidance and a clear mapping of your obligations. The result is a more centralized reporting system, with an external project manager to guide you through it.

How Pincvision supports your Textile EPR compliance

Pincvision, your partner in trade compliance, is specialized in CLF EPR compliance. We combine in-depth regulatory knowledge and expertise with a practical way of working that suits your organization. With the right support in data management through our automated system, and reporting and compliance execution backed by our experience, we deliver practical implementation and legal guidance to meet your textile EPR obligations, so you benefit from Pincvision's specialist expertise. And while we build the centralized foundation, your organization can focus on Styling the world.

Textile EPR implementation starts long before the deadline

Getting your product data and internal structure in order is not only important for textile EPR. It also strengthens the foundation for the wider Extended Producer Responsibility obligations your organization faces, from packaging to Clothing, Linen and Footwear (CLF).

Unsure which textile EPR obligations apply to your organization? Or wondering where to start? Get in touch. We are happy to help you assess your obligations and build the foundation before the national deadlines arrive. ⬇️