Sustainability Insights #22

In September 2025, the European Parliament gave its final approval to new measures aimed at reducing waste from food and textiles across the EU. Among these, the introduction of mandatory Extended Producer Responsibility (EPR) schemes for textiles under the revised Waste Framework Directive (Directive 2008/98/EC) represents a major development for the apparel and textile industry.

These changes mark a significant shift in how textile products are managed throughout their lifecycle from design to disposal and will directly impact producers, retailers, and supply chain partners.

Mandatory Extended Producer Responsibility (EPR) Schemes

Under this revised directive, EU Member States must establish harmonized EPR schemes for textiles. These schemes require producers to cover the full costs of collection, sorting, reuse and recycling. This applies to all producers including the non-EU companies that market products within the EU and E-commerce sellers.

What Brands Need to Know About EPR Possible Deadlines

Product Scope: What’s Covered?

The EPR obligation covers a wide range of textile-related products:

• Clothing and accessories

• Footwear

• Blankets

• Bed and kitchen linen

• Curtains

• Hats

Optional inclusion: Mattresses (Member States may choose to include them)

Additional Measures Brand Owners Should Know

1. Clarification of “Waste” vs “Reusable” Textiles

2. Alignment with ESPR & Ecodesign Requirements

Textile EPR is closely linked to the Ecodesign for Sustainable Products Regulation (ESPR), which sets out requirements for product durability, repairability, and recycled content. Together, ESPR and the revised Waste Framework Directive form a complementary policy framework that addresses both waste prevention and waste management: 

• ESPR prevents waste creation by banning the destruction of unsold consumer products (including textiles and footwear), encouraging reuse and remanufacturing.
• The Waste Framework Directive ensures responsible handling of textile waste once it enters the system, through mandatory EPR schemes that cover collection, sorting, reuse, and recycling.

In case you missed it: Check out our Sustainability Insights from last month on the ESPR ban on destroying unsold textile products.

3. Centralized Eco-Modulation Criteria

The revised Waste Framework Directive introduces eco-modulated EPR fees, where producers may pay more or less depending on the environmental performance of their products. While Member States can require Producer Responsibility Organisations (PROs) to apply these modulated fees, the criteria for calculating the fees will be defined at the EU level via the adoption of implementing acts.

The revised Waste Framework Directive introduces a new era of accountability for textile producers, mandating Extended Producer Responsibility (EPR) schemes across the EU. With clearer definitions, harmonized obligations, and upcoming eco-modulation criteria, brands must act now to align with evolving national requirements and prepare for a more circular, transparent textile value chain.

Source:
European Parliament

Following the adoption of the revised Waste Framework Directive, all EU Member States are required to establish national textile EPR schemes. While timelines for national implementation may vary, here’s a quick snapshot of where selected countries currently stand:

Already Implemented

In Development / To Be Finalized

While the rest of the EU Member States have yet to formally announce national textile EPR frameworks, some have initiated voluntary or pilot schemes as early steps toward compliance. However, these are not yet mandatory or legislated at the national level. All EU countries are legally required to establish operational EPR schemes for textiles no later than early 2028. Brands placing textile products on the EU market should stay informed of national developments to ensure timely compliance across all relevant markets.

What This Means for Brands:

While all EU Member States are required to implement textile EPR schemes, the pace and structure of national rollouts vary. Brands must stay alert to country-specific developments to ensure timely compliance when placing products on different EU markets.

SML’s RFID leadership enables item-level traceability that helps brands operationalize EPR with accurate data for collection, sorting, reuse, and recycling. Through factory-level printing and encoding, service bureaus, and rigorous global QA, we connect billions of products with reliable digital IDs that can streamline producer registration, reporting, and readiness for potential future eco‑modulated fees.

Our embedded RFID tags, InfuseRFID – washable and durable – are designed to remain with garments across wear and care cycles, preserving a persistent identifier that supports take-back, refurbishment, reverse logistics, and more precise end‑of‑life routing. As European Union (EU) rules evolve, we continue to invest in interoperable data and traceability capabilities, and we expect to align our solutions as implementing details on Digital Product Passports (DPPs) are clarified. These capabilities help build a more circular and transparent supply chain and may complement efforts to meet emerging textile EPR requirements.