Table of Contents
- The EU’s Textiles EPR Framework
- France: The Model for EU Textiles EPR
- The UK’s Expected Approach
- Key Differences Between EU and UK Approaches
- Implications for UK Exporters to the EU
- Dual Compliance: Managing Both Regimes
- What This Means for Your Business
Key Takeaways
- The EU’s revised Waste Framework Directive mandates textiles EPR across all member states, with schemes operational by April 2028.
- France’s Refashion scheme has been running since 2007 and serves as the primary model for the EU-wide approach.
- The UK’s textiles EPR is expected to follow a similar structure but will be developed independently through DEFRA.
- UK businesses exporting to the EU will need to comply with EU member state schemes regardless of whether a UK scheme exists.
- Dual compliance will require careful planning, particularly around data collection and reporting.
The EU’s Textiles EPR Framework
The revised Waste Framework Directive, which includes mandatory Extended Producer Responsibility for textiles across all EU member states, entered into force on 16 October 2025. This represents the most significant regulatory intervention in the European fashion and textiles industry to date.
Under the revised directive, every EU member state must transpose the textiles EPR requirements into national law by mid-2027 and have operational schemes in place by April 2028. The directive establishes minimum requirements that all national schemes must meet, while allowing member states flexibility in implementation details.
Scope of the EU Scheme
The EU framework covers a broad range of textile products:
- Clothing and accessories — all garments, including outerwear, underwear, swimwear, and sportswear
- Footwear — shoes, boots, sandals, and other footwear with textile components
- Household textiles — bedding, towels, table linen, curtains, and upholstery
- Technical and industrial textiles — where placed on the consumer market
- Carpet and floor coverings — textile-based flooring products
The directive takes an inclusive approach: if a product is predominantly made from textile fibres and is placed on the EU consumer market, it is likely to be in scope.
Key Requirements
The EU directive mandates several core elements that all member state schemes must include:
- Mandatory producer registration in each member state where products are sold
- Reporting of volumes placed on the market by weight and product category
- Fee payments to fund collection, sorting, reuse preparation, and recycling infrastructure
- Fee modulation based on environmental criteria including durability, recyclability, fibre composition, and the presence of hazardous substances
- Minimum collection targets for used textiles, increasing over time
- Support for reuse — schemes must prioritise reuse over recycling in line with the waste hierarchy
Timeline
| Milestone | Date |
|---|---|
| Directive entered into force | 16 October 2025 |
| Member state transposition deadline | Mid-2027 |
| Schemes operational | April 2028 |
| First modulated fees | From scheme launch |
| Collection target reviews | Every 3 years |
France: The Model for EU Textiles EPR
France has operated a textiles EPR scheme since 2007, making it the longest-running and most mature example in Europe. The scheme, administered by Refashion (formerly Eco-TLC), provides the blueprint that many EU member states and the EU directive itself have drawn upon.
How Refashion Works
Every business that places textile products, footwear, or household linen on the French market above a de minimis threshold must register with Refashion and pay an eco-contribution per item. The fees fund nationwide textile collection points, sorting centres, and recycling facilities.
Current fee rates (approximate):
- Standard clothing item: EUR 0.01 to EUR 0.06 depending on product category
- Footwear: varies by type
- Household linen: varies by weight
Crucially, fees are modulated based on eco-design criteria. Refashion applies eco-modulation through bonuses for durable, certified, and recycled-content products, and penalties for products that impede recyclability.
Results After Nearly Two Decades
France’s scheme has delivered measurable outcomes:
- Nearly 290,000 tonnes of used textiles collected annually (approximately 4.3 kg per capita)
- 57% reuse rate for collected textiles
- 32% recycling rate for items not suitable for reuse
- Network of over 47,900 collection points across France
- Significant investment in fibre-to-fibre recycling technology
These results demonstrate that textiles EPR can work at scale, though critics note that collection rates and recycling technology still have significant room for improvement, particularly for blended fibre garments.
The UK’s Expected Approach
The UK is developing its textiles EPR framework independently of the EU, though the approaches share common foundations. Here is what we know about the UK’s expected direction.
The Circular Economy Taskforce
The UK government’s Circular Economy Taskforce identified textiles as a priority product stream for EPR regulation. Their recommendations to DEFRA included:
- Introducing mandatory EPR for textiles placed on the UK market
- Establishing a producer-funded scheme modelled on the packaging EPR framework
- Incorporating eco-design incentives from the outset through fee modulation
- Aligning where practical with international approaches to reduce compliance burdens for businesses operating across multiple markets
Expected DEFRA Consultation
A formal DEFRA consultation on UK textiles EPR is anticipated. This consultation will set out the proposed scope, thresholds, obligations, and fee mechanisms. Based on the packaging EPR precedent and Taskforce recommendations, the UK scheme is expected to include:
- Registration requirements with a central scheme administrator
- Tonnage-based reporting broken down by product category and fibre composition
- Per-tonne fees modulated by durability, recyclability, and recycled content
- De minimis thresholds to exempt very small businesses
For a comprehensive overview of the UK’s expected approach, see our full guide to textiles EPR in the UK.
Likely Implementation Timeline
Based on typical UK regulatory timescales — and noting that packaging EPR took approximately three years from initial consultation to fee implementation — a UK textiles EPR scheme could realistically come into force between 2027 and 2029. The exact timing will depend on consultation outcomes and parliamentary scheduling.
Key Differences Between EU and UK Approaches
While the UK and EU schemes share the same underlying principle, several important differences are expected.
Scope and Product Coverage
The EU directive takes a deliberately broad scope, covering essentially all textile products placed on the consumer market. The UK may adopt a narrower initial scope, potentially starting with clothing, footwear, and household textiles before extending to other product categories in later phases. This phased approach would mirror how packaging EPR was implemented, starting with the most significant waste streams.
Fee Structure and Modulation
Both regimes will use modulated fees, but the modulation criteria may differ. The EU directive specifies minimum environmental criteria that fees must reflect, including durability, reusability, repairability, recyclability, and the presence of substances of concern. The UK may adopt similar criteria but could weight them differently based on UK-specific waste management infrastructure and priorities.
France’s existing per-item fee model is well-established but relatively low cost. The UK, following the packaging EPR model, may opt for per-tonne fees that more closely reflect the actual cost of end-of-life management — potentially resulting in higher per-item costs but a more accurate reflection of environmental impact.
Eco-Design Requirements
The EU is coupling textiles EPR with the broader Ecodesign for Sustainable Products Regulation (ESPR), which will introduce mandatory product requirements including minimum durability, repairability standards, recycled content targets, and restrictions on destruction of unsold goods. The UK has not yet signalled whether it will introduce equivalent standalone eco-design legislation for textiles or whether these requirements will be embedded within the EPR fee modulation framework.
Administration and Enforcement
EU member states must each establish or designate a Producer Responsibility Organisation (PRO). Businesses selling across multiple EU countries may need to register with and report to multiple national PROs. The UK will likely have a single scheme administrator covering England, Scotland, Wales, and Northern Ireland — similar to PackUK’s role in packaging EPR — simplifying compliance for businesses operating across the UK nations.
Collection Infrastructure
The EU directive sets binding collection targets for used textiles, requiring member states to achieve minimum collection rates that increase over time. The UK may take a more flexible approach, setting targets through secondary legislation that can be adjusted based on infrastructure development and market conditions.
Implications for UK Exporters to the EU
For UK businesses that sell textile products into EU member states, the EU’s textiles EPR framework creates immediate compliance obligations — regardless of whether a UK scheme exists.
You Must Comply with EU Schemes
If your business exports clothing, footwear, or household textiles to EU customers, you will need to register as a producer in each member state where your products are sold. This applies whether you sell directly to consumers (e.g., through your own website shipping to EU addresses) or through wholesale channels.
Post-Brexit, UK businesses are treated as non-EU producers. In most cases, you will need to appoint an Authorised Representative in each relevant member state to handle registration and reporting on your behalf. This is similar to requirements that already exist for WEEE (waste electrical equipment) compliance.
Data Requirements for EU Reporting
EU member state schemes will require detailed data on the textile products you place on each national market, including:
- Product quantities (by unit and weight)
- Product categories
- Fibre composition breakdowns
- Information relevant to fee modulation (durability certifications, recycled content, etc.)
If you do not already collect this data at the level of granularity required, you will need to invest in systems and processes to do so. Starting now will avoid a scramble as the April 2028 deadline approaches.
Cost Implications
EU textiles EPR fees will add to the cost of selling into European markets. While individual per-item fees may appear modest (France’s current rates are a useful benchmark), they accumulate quickly for businesses placing large volumes on the market. Factor these costs into your pricing and margin analysis for EU sales.
Dual Compliance: Managing Both Regimes
UK businesses that sell textiles both domestically and into the EU will ultimately need to comply with two separate EPR regimes. Here are practical considerations for managing dual compliance effectively.
Centralise your product data. Both the UK and EU schemes will require detailed information about the products you sell — volumes, weights, fibre composition, and environmental characteristics. Building a single, comprehensive product database now will serve both regimes and avoid duplicating data collection efforts.
Map your sales by market. You will need to report separately on products placed on the UK market and products placed on each EU member state market. Ensure your sales and distribution data can be broken down by destination country.
Align with the stricter standard. Where the UK and EU have different requirements, designing your products and processes to meet the stricter standard means you will automatically comply with both. This is more efficient than maintaining separate approaches for each market.
Monitor both regulatory pipelines. The EU and UK will develop their schemes on different timelines. Subscribe to updates from DEFRA, the European Commission, and relevant member state authorities to stay ahead of requirements in both jurisdictions.
Consider appointing specialist advisors. Dual-regime compliance can be complex, particularly for businesses selling into multiple EU member states. Specialist EPR compliance advisors or producer responsibility organisations can manage registrations and reporting across multiple jurisdictions.
What This Means for Your Business
The convergence of EU and UK textiles EPR creates both challenges and opportunities. Businesses that prepare early — building data systems, understanding their product portfolios, and engaging with consultations — will transition smoothly when obligations take effect. Those that wait until regulations are finalised risk costly, rushed compliance efforts.
If you sell textiles into the EU, the April 2028 deadline is firm. Start preparing now.
If you sell only within the UK, you have more time, but the direction is clear. Use the intervening period to audit your products, start collecting composition data, and explore eco-design improvements that will reduce your future fees. Our guide on how to prepare for textiles EPR sets out seven practical steps you can take immediately.
For businesses already navigating packaging EPR, many of the compliance concepts and data management disciplines will transfer directly to textiles EPR. The experience you have built managing packaging obligations will be valuable when textiles obligations arrive.
Visit our textiles EPR page for the latest updates on both UK and EU regulatory developments, and sign up to be notified when DEFRA opens its consultation.