March 2024

Extended Producer Responsibilities are increasing in Europe and these are introducing new registration, collection, recycling and reporting compliance obligations for manufacturers and producers of textiles.

Why is this happening?

The 2023 amendment to the EU Waste Framework Directive 2008/98/EC aims to make producers responsible for the full lifecycle of textile products in order that used textiles are sorted for reuse and that non-reusable textiles are prioritised for recycling. In particular, the amendment stipulates that all EU Member States must set up separate collection for textiles by 1^st January 2025.

We are now expecting to see a significant expansion of EU Member States implementing Textile EPR laws during 2024. For example:

• There are now new Textile EPR laws in force in the Netherlands and Latvia. In the Netherlands, producers of clothing and home textiles needed to be registered from 1^st July 2023 and makes them responsible for recycling and reusing textiles
• Several other countries and geographies have Textile EPR laws in progress and these are expected to go-live during 2024, including Sweden
• France has already implemented EPR laws surrounding textiles and this has been in force for several years

What are the EPR compliance obligations under new Textiles laws?

The specific obligations for Textiles EPR have similarities to those for EU WEEE, Batteries, and Packaging, including registration, collection, recycling and data reporting. Textile products may have material content requirements as well as reuse and recycling targets. The ideal of true harmonisation across the EU for Textiles EPR so far looks to be as elusive as it has been for the WEEE, Batteries and Packaging waste streams meaning that and the varied country registration and data reporting responsibilities are expected to be often involved, burdensome and complicated.

Does your company have EPR compliance obligations under new EU Member State Textiles laws?

Annex IVc of the 2023 amendment details the textile items that fall within the scope of Textile EPR and include textile-related (e.g. household furnishing textiles) and footwear products. These may also further include company promotional items not offered for sale (such as company branded t-shirts and socks).

If you would like to understand more about whether you might be obligated under the EU Member State Textiles laws, please message us without obligation and free-of-charge!