Do you sell clothing, linen or footwear in the EU? Then you may be responsible for financing the collection, sorting, reuse and recycling of those products. Textile EPR already applies in France, Hungary, Latvia and the Netherlands, and every EU Member State must have a scheme in place by 17 April 2028.
- Find out whether you have obligations, and in which countries
- Registration, reporting and cost calculations, arranged for you
- One approach for all countries, with up-to-date insight into legislative changes
What does this mean for your business?
The European Union is introducing Extended Producer Responsibility (EPR) for clothing, linen and footwear (CLF) in all Member States. As a producer, you are responsible for financing the collection, sorting, reuse and recycling of your products. You do this through Producer Responsibility Organizations (PROs). The principles are aligned with other EU EPR frameworks, such as packaging, WEEE and batteries. Compliance is mandatory.
Textile EPR is part of the EU Strategy for Sustainable and Circular Textiles, which aims to reduce textile waste in the EU and make textiles more durable, reusable and recyclable.
2028 is the deadline, not the starting point. Under the Waste Framework Directive (WFD), every EU Member State must have a Textile EPR scheme by 17 April 2028. Several countries already have one, so obligations may already apply to you today.
The goals of Textile EPR
- Create an economy for separate collection, sorting, preparation for reuse, reuse and recycling
- Producers of textiles and footwear finance the recycling costs, through PROs
- Registration requirements and formats are harmonized across the European Union
- Compliance fees based on Eco Modulation to motivate product recyclability.
- End users receive information about the products
Which products are covered?
The product scope in the Waste Framework Directive is determined through CN codes (Annex IVc of the WFD), including chapters 61 and 62 and additional codes for accessories, household textiles and footwear. This includes, for example:
- Clothing and clothing accessories, such as hats
- Footwear
- Bed linen and bedding, such as blankets
- Household linen, such as table linen and toilet and kitchen linen
- Curtains
Do you have obligations?
Textile EPR applies to several types of businesses. Your role can differ per country: one organization can be the manufacturer in one country, the importer in another and a distance seller in a third. You may have obligations if you are:
- A brand owner (Manufacturer in a Member State): If you manufacture textiles (under your own name or trademark), or if you have them designed and produced for you, you are responsible for compliance.
- A reseller (Manufacturer in a Member State): If you are the first seller of the textile item on the market in the Member State.
- An importer (with a local sales entity): If you import textiles from another country and sell them within an EU Member State, EPR requirements apply to you.
- A distance seller: If you sell textiles directly to consumers in an EU Member State via online or remote sales, you must meet EPR obligations. Even if your business is based outside the EU.
Not sure how this affects your business? In our article, we explain per role when you are considered a producer.
Are there exemptions?
Yes. Some producer exemptions apply under the Waste Framework Directive, but you need to assess your situation carefully per Member State. It is likely you do not have obligations if you are:
Not sure whether an exemption applies to you? We can assess this with you.
Where does Textile EPR already apply?
France, Hungary, Latvia and the Netherlands already have concrete Textile EPR regulations, and more countries are preparing legislation. The rules differ per country, for example in product scope and the data you need to report. As a producer or importer, you need to check what this means for your business in each country.
Which countries have implemented Textile EPR, and what is the status in each of them? We keep an up-to-date overview in our article Textile EPR Europe: which countries have implemented textile EPR?
How does Pincvision help you?
No time to analyze all the new requirements? We take this off your hands:
- Obligations: we identify your Textile EPR obligations, based on your legal entities, supply chain and sales flows.
- Country-specific compliance: we make sure you meet the requirements in each country where you have obligations.
- Registration, reporting and cost calculations: we support your registrations with PROs, and in our automated reporting system we collect, structure and enrich your product and sales data.
- Legislative updates: we monitor legislation and keep you informed of changes, adjusting the process where needed.
Want to read more?
In our Textile EPR series, we explain step by step what Textile EPR means for your organization:
- Part 1: Textile EPR implementation: 3 common pitfalls organizations should avoid
- Part 2: Textile EPR producer: when are you considered a producer?
- Part 3: Textile EPR Europe: which countries have implemented textile EPR?
- Part 4: Textile EPR and the PPWR: which compliance obligations apply to you?
- Part 5: Textile EPR roadmap: where should your organization start?
Learn more about our EPR services: WEEE declarations · Battery reporting · Packaging reporting · PPWR
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