Spain Textile EPR: What Brands Need to Prepare For

Spain textile EPR is a proposed Extended Producer Responsibility scheme that would make producers responsible for registration, reporting, financing, and supporting waste management for textile and footwear products placed on the Spanish market. The draft Royal Decree is not yet in force and currently progressing through the EU notification process, but brands, importers, retailers, and cross-border sellers should begin preparing product and sales data now.

Spain is moving toward a dedicated textile and footwear EPR framework through the proposed Draft Royal Decree Regulating Textile and Footwear Products and the Management of Their Waste.

The proposal is part of Spain’s transition toward circular textiles and is designed to implement the revised EU Waste Framework Directive textile EPR requirements. Under that EU framework, Member States are expected to transpose new textile EPR requirements by 17 June 2027 and establish textile and footwear EPR schemes by 17 April 2028.

The draft proposal applies broadly to producers placing covered products on the Spanish market. This includes manufacturers, importers, distributors, and online sellers – even those based outside Spain who sell directly to Spanish consumers.

The practical message is simple: if you place textile or footwear products on the Spanish market, Spain textile EPR may become a data, registration, and financing obligation.

What is Spain’s proposed textile EPR scheme?

Spain’s proposed textile EPR scheme would require producers of in-scope textile and footwear products to help finance and organise waste prevention, separate collection, reuse, recycling, consumer awareness, and end-of-life management.

The draft decree would create a dedicated Textile and Footwear Products section of the Register of Product Producers. Producers would be expected to register, report annual market placement data, and participate in an authorised collective EPR scheme.

Spain textile EPR is intended to shift more responsibility for textile waste from municipalities to the companies that place products on the market.

Municipalities are still expected to play an important role in collection and waste management, but producer financing would become a central part of the system.

Which products are expected to be in scope?

The draft decree covers textile and footwear products listed in Annex I and identified by Combined Nomenclature (CN) code.

Product category	Expected scope under the draft decree
Clothing and apparel	In scope
Footwear	In scope
Fashion accessories (e.g., hats, certain accessories)	In scope where covered by listed CN codes
Household and home textiles	In scope
Certain leather apparel and accessories	In scope where covered by listed CN codes
Workwear, uniforms and textiles used in hospitality, healthcare or industry	Generally in scope unless covered by a professional or safety-related exclusion.
Professional or military products with safety, health or hygiene functions	Excluded

Product classification matters. A product should not be assessed by commercial description alone.

CN codes will be central to determining whether a textile, footwear, accessory, or related product falls within the Spanish EPR scope.

Who is considered a producer under Spain textile EPR?

A producer is generally the person or company that first places in-scope textile or footwear products on the Spanish market or sells them directly to end users in Spain through distance-selling channels.

A business may be considered a producer if it:

• Manufactures or sells products under its own brand or trademark
• Has products manufactured by a third party and places them on the Spanish market under its own brand or trademark
• Imports products into Spain and places them on the market for the first time
• Sells products directly to Spanish end users from another country through e-commerce or other distance-selling channels

Producer obligations may also apply to businesses established outside Spain. Companies selling directly to Spanish consumers from abroad may be required to appoint an authorized representative in Spain.

What obligations are producers expected to have?

Businesses placing in-scope products on the Spanish market are expected to prepare for five core obligations.

Obligation	What it means for businesses
Producer registration	Register in the Textile and Footwear Products section of the Register of Product Producers.
Annual reporting	Submit market placement data, including quantity by weight and number of items.
Origin reporting	Distinguish products from within the EU and products imported from third countries.
Collective EPR participation	Join and finance an authorised collective EPR scheme.
Marketplace and logistics information	Provide registration and EPR compliance information where required.
Authorised representative	Appoint a representative in Spain if established outside Spain and selling directly to Spanish consumers.

Annual reporting will likely require product data that many brands do not currently hold in one system.

EPR fees, reporting, and compliance checks will depend on reliable product, sales, and supply-chain data.

Certain SMEs may benefit from simplified reporting requirements and additional time to comply, but the final conditions should be confirmed once the decree is adopted.

What additional requirements may apply to larger producers?

Larger producers placing more than 2.5% of all textile and footwear products on the Spanish market in a calendar year may be required to develop eco-design and waste prevention plans.

These plans may be prepared individually or through a collective EPR scheme.

Expected plan topics include:

• Product durability.
• Repairability.
• Recyclability.
• Reduction of hazardous substances.
• Measures to limit microplastic releases.

For larger producers, compliance may also involve product-specific eco-design requirements and waste-prevention initiatives, in addition to reporting and financing obligations.

What is the current status of Spain’s textile EPR scheme?

After the European Commission issued a Detailed Opinion under the Technical Regulation Information System (TRIS) procedure, Spain submitted an official response confirming that it will amend the draft Royal Decree to address the Commission’s comments and ensure compatibility with EU law. The textile EPR scheme is therefore not yet in force. See the European Commission TRIS notification for Spain textile EPR.

Among the issues raised by the Commission, Spain confirmed that the requirement for online platforms to display producer registration numbers will be removed from the draft due to concerns regarding compatibility with the Digital Services Act and the E-Commerce Directive.

The response also confirms that the proposed eco-modulated EPR fee framework will remain in place. Spain considers the current approach to be consistent with the revised Waste Framework Directive, including provisions that may take sustainability and fast-fashion business practices into account when determining producer contributions.

In addition, Spain clarified that the future Digital Product Passport (DPP) and Textile EPR reporting serve different purposes. While some information may overlap, DPP implementation is not currently expected to replace Textile EPR reporting obligations.

What should businesses do now?

Businesses should begin preparing data now because Spain textile EPR is likely to create registration, reporting, marketplace, and financing requirements once the final framework is adopted.

A practical readiness checklist should include:

• Map product categories and CN codes. Identify textile and footwear products placed on the Spanish market.
• Track units and weight. Record the number of items and total weight sold or distributed in Spain.
• Confirm product origin. Distinguish goods sourced from EU Member States from third-country imports.
• Identify producer entities. Document company information, brands, trademarks, and responsible market actors.
• Review sales channels. Map direct sales, distributors, online marketplaces, logistics providers, and cross-border e-commerce flows.
• Collect material and design data. Prepare information on material composition, durability, repairability, recyclability, hazardous substances, and microplastic risk.
• Assess representative needs. Determine whether a Spain-based authorised representative may be required for distance sales.

Early data preparation will reduce the operational burden once reporting deadlines begin.

The brands best prepared for Spain textile EPR will be the ones that already understand what they sell, where it enters the market, and which entity is responsible.

How does Spain textile EPR connect to DPP and traceability?

Spain’s textile EPR highlights the growing importance of product data, traceability, and Digital Product Passport readiness.

As textile EPR schemes and product transparency requirements expand across Europe, brands are expected to strengthen how they manage product-level information. While Textile EPR reporting and the future Digital Product Passport serve different regulatory purposes, many of the same data management, traceability and product information capabilities can support both EPR readiness and DPP implementation.

SML can support these efforts through:

• Item-level RFID solutions that enhance product traceability and transparency.
• SML Digital Product Passport solutions that help brands manage, connect, and share product information.
• Traceability and circularity solutions that support future transparency, circularity, and regulatory initiatives.

Product identification is becoming part of compliance infrastructure.

DPP readiness and EPR readiness increasingly depend on the same foundation: accurate, structured, and shareable product data.

Key dates for Spain textile EPR

Date	Event	Why it matters
11 September 2026	Spain submitted its formal response to the European Commission’s Detailed Opinion and comments during the TRIS standstill period	Spanish authorities will amend the draft Royal Decree to align with the response document and ensure compatibility with EU law.
28 September 2026	Extended TRIS standstill period referenced in the source material	Spain’s adoption process is delayed while the draft remains under review.
17 June 2027	EU Waste Framework Directive transposition deadline	Member States must transpose the revised textile EPR requirements.
17 April 2028	EU deadline to establish textile and footwear EPR schemes	Spain’s national scheme is expected to align with this wider EU requirement.

Businesses should treat these dates as planning markers, not substitutes for reviewing the final adopted decree.

This article provides a general overview and reflects our understanding at the time of publication. For specific legal, regulatory, or compliance decisions, please refer to the relevant official sources.

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