Extended producer responsibility for textiles, explained
The revised EU Waste Framework Directive makes producers pay for the collection, sorting and recycling of used clothing and footwear. Who counts as a producer, what it costs and when it starts.
KEY TAKEAWAYS Summary by the editors
- Directive (EU) 2025/1892, which revises the Waste Framework Directive, entered into force on 16 October 2025 and requires EU member states to set up extended producer responsibility (EPR) schemes for textiles and footwear.
- Member states have 30 months from entry into force to establish the schemes, which points to April 2028, and 20 months to transpose the directive into national law.
- Producers include brands and distance sellers that first make products available in a member state, and non-EU sellers may need an authorised representative.
- Fees are expected to be modulated according to sustainability criteria such as durability and recyclability, linking product design to cost.
- Because each member state implements its own scheme, brands selling across Europe will face multiple registrations and reporting duties.
Every garment a brand sells in Europe will eventually become somebody's waste problem. Extended producer responsibility, usually shortened to EPR, moves the cost of that problem back to the companies that put the product on the market. After years of debate, the EU has made textile EPR mandatory across all member states, and the clock for implementation is running.
What is extended producer responsibility?
EPR is a policy principle under which producers are financially, and sometimes operationally, responsible for the end-of-life management of the products they sell. Europe has used it for decades for packaging, batteries and electronics. In practice, producers join a producer responsibility organisation, report the quantities they place on the market and pay fees that fund collection, sorting, reuse and recycling.
Some member states, France being the best-known example, have run textile EPR schemes for years. What is new is that the revised EU Waste Framework Directive requires every member state to have one, under a common set of minimum rules.
What does the revised Waste Framework Directive require?
Directive (EU) 2025/1892 of 10 September 2025 amends Directive 2008/98/EC on waste. It entered into force on 16 October 2025. Member states have 20 months to transpose it into national law and 30 months to establish EPR schemes for textile and footwear products, which points to April 2028. Micro-enterprises get an additional 12 months to comply with the textile EPR obligations, which points to April 2029.
| Element | What the directive provides |
|---|---|
| Products covered | Clothing, clothing accessories, hats, footwear, blankets, bed and kitchen linen and curtains; member states may also include mattresses |
| Who pays | Producers making these products available on a member state's market for the first time, including by distance selling |
| Registration | Producers register in each member state where they first make products available |
| Non-EU and distance sellers | May need to appoint an authorised representative in the member state concerned |
| Fee modulation | Fees adjusted according to sustainability criteria such as durability and recyclability |
| Use of fees | Collection, sorting, reuse and recycling, plus support for research and development and waste prevention |
The directive also builds on an earlier obligation: since 1 January 2025, member states have had to organise separate collection of textiles. The revision adds rules to ensure collected textiles are sorted before export, so that waste is not shipped abroad labelled as reusable clothing.
Who counts as a producer?
For most fashion brands, the answer will be: you do, in every EU country where you sell. The producer is the entity that first makes a product available on the market of a member state. A brand selling direct to consumers online in several countries is likely to be a producer in each of them. For wholesale, the position depends on who first makes the product available in that country: a brand delivering to a retailer in another member state, an importer or a distributor. National transposition will set the details, so wholesale contracts should state clearly who registers and reports.
How will fees work?
Fees will be set by national schemes and are typically based on the number or weight of items placed on the market. The directive requires modulation according to sustainability criteria, so products that are more durable or easier to recycle should cost less to place on the market than products that are not. The exact criteria will differ by country initially and may be informed by the ESPR textile requirements once those exist.
For brands, this creates a direct link between design decisions and an annual operating cost. It also means that accurate product data, such as composition and weight per item, becomes a financial matter, not only a compliance one.
What should brands do to prepare?
- List every EU market where you place products, and for each, the route to market: direct, wholesale, distributor or marketplace.
- Clarify contractually with retail partners and distributors who acts as producer in each country.
- Make sure you can report quantities and weights per product category and per country from your systems.
- Track national transposition and the launch of producer responsibility organisations in your key markets.
- Review product design choices that are likely to affect fee modulation, such as fibre blends and durability.
EPR is not a one-off project but a recurring reporting and payment cycle across many countries. Brands that treat it as a data and process topic early will avoid an annual scramble once schemes are live.
Frequently asked questions
When do brands have to start paying textile EPR fees?
Member states must establish their schemes within 30 months of the directive's entry into force on 16 October 2025, which points to April 2028. Some countries already have schemes, and others may start earlier, so timing depends on the market.
Does textile EPR apply to non-EU brands?
Yes, if they make products available in an EU member state, including through distance selling to consumers. They may need to appoint an authorised representative in each member state concerned.
Are second-hand textiles covered?
The directive includes provisions for social economy entities that handle reuse and second-hand textiles, which may be exempt from certain obligations. The precise treatment depends on national transposition.
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