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After several years of fierce debate, lobbying and fine-tuning, the European Union (EU) has at last adopted the final text for its extended producer responsibility (EPR) legislation, which promises to curb textile waste and make producers pay for how it is collected, sorted and recycled.
As ever with the EU, passing legislation is a long process that requires a lot of back and forth between various parties. It is also only the beginning, and there are still lots of details to be ironed out. The European Parliament finally adopted the text on Tuesday, after the European Council agreed to proposed amendments earlier this summer. On Wednesday, both signed the updated text, kick-starting a roughly 20-day process during which the legislation will enter into force. Once it has been published in the EU Official Journal — which is expected to happen in early October, but could be any day now — the rules will officially apply.
However, producers — which means brands and retailers, rather than the suppliers actually producing clothes on their behalves — won’t be on the hook for a while. Once the legislation enters into force, each EU member state will have 20 months to “transpose” the rules into national legislation, either amending their existing waste rules or creating new ones. Within 30 months — which takes us to April 2028 — each member state will have to establish its own EPR scheme (or multiple schemes) to actually enforce the legislation.
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In the meantime, each member state has to work out exactly how much they want to charge producers (there are no minimums or maximums), and what they want their local EPR schemes to look like. The EU has issued limited guidance on this front, but member states are encouraged to charge companies based on how much they sell in that country, and they are allowed to charge more if a business fails to meet certain environmental or social criteria, or if its business model could be described as fast fashion. It’s also worth noting that most aren’t starting from scratch: the separate collection of textiles has already been mandatory in EU states since the beginning of 2025, and countries including France and the Netherlands already have EPR schemes in place.
While the fees likely won’t apply for a while, brands will need to get their ducks in a row. Producers need a legal entity or representative everywhere their products are sold, and they will be charged in every country they sell into, meaning brands could be charged multiple times. Micro-enterprises will have an extra year to comply — the EU said they are not the main contributors and therefore not the main targets — but they won’t be exempt entirely. If they were, larger businesses could attempt to fracture their sales figures and side-step larger fees. There are some exemptions, however, including self-employed tailors producing custom garments and businesses selling secondhand or entirely upcycled garments. A few grey areas remain around the use of recycled content and deadstock, but it’s likely that these will still be charged as the products in question will need handling at the end-of-life stage.
What many people don’t realise is that the EPR legislation is complemented by producer registers, which log every producer in every EU member state. As part of the register, producers will be required to disclose how much they produce per year by volume — something fashion activists have been campaigning for, but which has remained hidden, until now. It’s up to member states how frequently they ask producers to report on this, and what other information they ask for. It also remains to be seen whether this data will be publicly available.
Still, the finalised text leaves a lot to be desired, and in many ways, it raises as many questions as it provides answers. Here, the fashion industry reacts.
Liz Ricketts
Co-founder of US-Ghanaian non-profit The Or Foundation, which supports upcyclers and resellers at Kantamanto Market in Ghana, one of the world’s largest secondhand textile markets
We are happy to see the EU officially recognise textile waste as a crisis and we appreciate the attempt to improve what is exported to communities like Kantamanto. However, we are disappointed that the final language of the revision does not immediately include the critical requirement of global accountability that we have been calling for, along with thousands of other people, organisations and brands. Without global accountability, the money brands pay will largely go towards subsidising exports to markets like Kantamanto, without supporting those very same global reuse markets where the heavy lifting of circularity is truly performed.
Failure to institute global accountability means that the fees brands pay into EPR will fund waste colonialism, but there is an opening for brands to voluntarily do what regulators at the EU level have failed to do. They could move a portion of the funds collected into communities like Kantamanto who are managing the overwhelming majority of the EU’s textile waste and who will continue to do so for many years to come, because the EU will not build circular infrastructure to manage its own waste overnight.
Elmar Stroomer
Co-founder of Africa Collect Textiles, which works to build a circular economy for textiles in Kenya and Nigeria
EPR fees are not a waste tax, they are an incentive for collectors and sorters to collect more, which can result in selling more used textiles to the Global South. As an unintended consequence, the price of secondhand clothing could drop. The question is: is it best to use the fees locally or to start building up infrastructure in the countries receiving textile waste shipments? I am worried that the future payment of EPR fees will lower the chance of funding or grants trickling down to importing nations, because brands will feel like they are already paying their dues. Pain points like this still need to be reviewed.
Jordan Girling
Head of extended producer responsibility at the Waste and Resources Action Programme (WRAP)
We are overall very supportive of the text and are pleased to see the formal commitment to better manage this problematic waste stream in a more sustainable way. One of the biggest barriers is harmonisation. The text includes some provisions making it mandatory for all 27 member states to harmonise specific elements of EPR schemes, which is commendable to minimise the complexity of compliance for obligated producers, but in most instances these criteria are yet to be determined. Depending on how long this takes, there could be real challenges implementing EPR by the deadline.
The biggest challenges for small enterprises are the administrative burdens associated with registration and data reporting, particularly for enterprises that operate across several EU markets, and, of course, the new financial cost. However, the timelines are sufficient enough for small enterprises to prepare adequately.
Maria Bystedt
Programme director at H&M Foundation, responsible for its partnership with Indian collective Saamuhika Shakti, which helps waste pickers out of poverty
The EU’s new EPR rules are a landmark step towards a more circular textile industry, and we welcome this clear signal that waste can no longer be externalised. For many producers, especially SMEs (small and medium enterprises), the challenge is not knowing what not to do, but how to do things right in practice. They face rising compliance demands while being asked to invest in sustainable solutions without the means to do so. If we don’t support them properly, the risk is that well-intended rules create barriers instead of progress.
This is where philanthropy has a crucial role: de-risking early solutions, building proof points and viable business cases, and convening diverse stakeholders. Going forward, it is essential that the solutions built under EPR have a just transition lens, ensuring that those working in collection, sorting and aggregation, such as waste pickers and informal workers, are part of the process and benefit from the transition. Through Saamuhika Shakti in India, we’ve seen how involving communities from the ground up not only strengthens livelihoods but also makes circular systems more resilient. With the right support, these rules can accelerate both circularity and inclusion, creating an industry where businesses, communities and the planet thrive together.
María Luisa Martínez Díez
VP of public affairs at Global Fashion Agenda
The obligation for member states to set up EPR schemes within 30 months creates a clear timeline, while eco-modulation will reward products designed to last longer or be recycled more easily. Together, these measures send a powerful message: sustainability is no longer optional, it’s the new baseline for doing business in Europe.
The biggest risk is fragmentation. While the Waste Framework Directive sets minimum rules, member states can still design their own systems. This could lead to divergent approaches, double fee payments and a lack of coordination especially as national schemes emerge in countries like Italy and Spain. Industry groups including Euratex, Euric, Fesi and the Policy Hub have stressed that without consistent rules, member states could create a patchwork of systems that undermine both efficiency and fairness.
Enforcement is another challenge. Without stronger investment in collection, sorting and recycling infrastructure, there’s a danger the system becomes just another fee mechanism rather than a real driver of circularity.
Looking ahead, the forthcoming Circular Economy Act, expected in 2026, is set to play a pivotal role. Among its goals is to expand access to incentives such as public procurement preferences and funding for circular products and infrastructure. These measures will be essential to close today’s investment gaps and give Europe the tools it needs to build a truly circular textile economy.
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