Table of Contents
- Why Prepare Now?
- Step 1: Audit Your Textile Product Range
- Step 2: Start Tracking Volumes Placed on Market
- Step 3: Map Your Materials and Supply Chain
- Step 4: Review Eco-Design Opportunities
- Step 5: Assess Labelling Requirements
- Step 6: Budget for Future Compliance Costs
- Step 7: Sign Up for Regulatory Alerts
- Bringing It All Together
Key Takeaways
- You do not need to wait for legislation to start preparing — the businesses that act earliest will have the lowest compliance costs and the smoothest transition.
- Data collection is the biggest lead-time item — building systems to track volumes and fibre composition takes months, not weeks.
- Eco-design changes made now will reduce your future EPR fees — and may also reduce material costs and improve brand positioning.
- Budgeting early avoids financial surprises — use France’s Refashion fees as a benchmark to estimate potential costs.
Why Prepare Now?
Textiles EPR is not yet law in the UK, but the regulatory direction is unmistakable. The Circular Economy Taskforce has recommended it, DEFRA is expected to consult on a formal scheme, and the EU is mandating textiles EPR across all member states by April 2028. For a full overview of the timeline and expected obligations, see our comprehensive textiles EPR UK guide.
Businesses that went through the packaging EPR rollout learned a hard lesson: preparing after regulations are published leaves too little time. Companies that had already been tracking their packaging data were ready to report when deadlines arrived. Those that had not scrambled to gather years of data under pressure.
Textiles EPR will follow the same pattern. The businesses that start building data systems, auditing products, and assessing their supply chains now will be ready. Here are seven practical steps to take today.
Step 1: Audit Your Textile Product Range
Before you can comply with any reporting scheme, you need a complete picture of what you place on the UK market. This goes beyond knowing your product catalogue — you need to understand every textile item from an EPR perspective.
What to include in your audit:
- All clothing items (outerwear, underwear, activewear, swimwear, formalwear)
- Footwear with textile components (trainers, fabric shoes, textile-lined boots)
- Accessories (scarves, hats, gloves, belts with textile components, bags)
- Household textiles (bedding, towels, cushion covers, tablecloths, curtains)
- Workwear and uniforms if you supply them
- Textile-based promotional items (branded tote bags, lanyards, merchandise)
For each product, record:
- Product name and SKU
- Product category
- Average unit weight in grams
- Primary fibre composition (e.g., 95% cotton, 5% elastane)
- Country of manufacture
- Annual units sold in the UK
Many businesses are surprised by the breadth of textile products they sell once they conduct a thorough audit. A homeware retailer, for example, may not immediately think of cushion covers and throws as falling within the scope of textiles EPR, but they almost certainly will.
Practical tip: Export your product database and filter for anything with textile content. Cross-reference against your purchasing records to catch items bought from suppliers that may not be clearly categorised as textiles in your system.
Step 2: Start Tracking Volumes Placed on Market
EPR obligations will be based on the volume — measured in tonnes — of textile products you place on the UK market. “Placed on the market” means sold to a UK customer (for retailers) or first made available in the UK (for importers and wholesalers).
What to track:
- Units sold per product line per month — broken down by UK sales specifically, excluding exports
- Weight per unit — either actual measured weights or reliable averages by product category
- Total tonnage per reporting period — units multiplied by average weight, aggregated across your product range
How to get accurate weights:
The simplest approach is to weigh a representative sample of each product type on a postal or kitchen scale. Record the weight in grams and store it against the product SKU in your system. For businesses with hundreds or thousands of SKUs, grouping similar items (e.g., “men’s t-shirts,” “women’s jeans,” “bath towels”) and using category averages is a practical starting point.
If you already manage packaging EPR compliance, you will recognise this process. The same discipline of weighing, recording, and aggregating applies — the subject is simply the product rather than its packaging.
Practical tip: Start a simple spreadsheet now, even if your product data system is not yet set up for textile tracking. Six months of real data will be invaluable when you need to estimate annual tonnages for registration and budgeting purposes.
Step 3: Map Your Materials and Supply Chain
Textiles EPR fees are expected to be modulated by fibre composition. Products made from easily recyclable mono-fibres (100% cotton, 100% polyester) will likely attract lower fees than products made from blended fibres that are difficult to separate and recycle.
What to document for each product:
- Full fibre composition — not just the primary fibre, but all components (e.g., “97% cotton, 3% elastane” rather than just “cotton”)
- Trim and hardware materials — zips, buttons, labels, and other non-textile components that affect recyclability
- Chemical treatments — water-repellent coatings, flame retardants, anti-wrinkle finishes, and other treatments that may affect recyclability or attract fee surcharges
- Supplier details — who manufactures each product, where, and what certifications they hold
Why this matters:
A fashion brand selling 100,000 units of a 100% cotton t-shirt will almost certainly pay lower EPR fees per tonne than a brand selling the same volume of a polyester-cotton-elastane blend top. The fee differential is designed to incentivise material choices that make end-of-life processing easier and cheaper.
Understanding your material mix also reveals opportunities. If you discover that 40% of your range uses blended fibres that could be reformulated as mono-fibres without affecting performance or customer appeal, that is a direct route to lower future EPR costs.
Practical tip: Request fibre composition certificates from your suppliers if you do not already have them. Most garment manufacturers can provide these as part of their standard quality documentation.
Step 4: Review Eco-Design Opportunities
Eco-design is not just about compliance — it is about reducing costs, improving product quality, and meeting growing consumer demand for sustainable products. Changes you make now will pay dividends when EPR fees arrive.
High-impact eco-design improvements:
-
Simplify fibre composition. Where possible, move from blended fabrics to mono-fibre alternatives. A 100% polyester fleece is far more recyclable than a polyester-cotton blend. Every blend you eliminate is a future fee reduction.
-
Improve durability. Products that last longer generate less waste per year of use. Higher-quality stitching, reinforced stress points, and better fabric selection all contribute. Consider offering repair services or publishing repair guides — some EPR schemes reward producers who actively support product longevity.
-
Design for disassembly. Make it easier to separate different materials at end of life. Use removable rather than sewn-in labels, avoid bonded multi-material trims, and choose hardware (zips, buttons) that can be easily detached from fabric.
-
Eliminate problematic chemicals. PFAS-based water-repellent treatments, certain flame retardants, and other substances of concern may attract EPR surcharges and are increasingly restricted under separate chemical regulations. Switching to safer alternatives now avoids future reformulation costs.
-
Incorporate recycled content. Using recycled polyester, recycled cotton, or other post-consumer fibres may qualify for fee reductions under modulated EPR schemes. It also strengthens your sustainability credentials with consumers.
Practical tip: Pick your three highest-volume products and assess them against these criteria. Improvements to your best sellers will have the greatest impact on your total EPR costs.
Step 5: Assess Labelling Requirements
Textiles EPR is expected to bring enhanced labelling requirements. While current UK regulations already mandate fibre composition labelling, EPR schemes may require additional information to support collection, sorting, and recycling.
Anticipated labelling elements:
- Detailed fibre composition — potentially more granular than current requirements, especially for blended fabrics
- Care instructions for longevity — guidance on washing, drying, and storage that extends product life
- End-of-life guidance — information on how to dispose of, donate, or recycle the product
- Digital product passports — QR codes linking to online databases with comprehensive product information, including materials, manufacturing origin, and recycling instructions
The EU’s Digital Product Passport initiative is already requiring this for textiles sold in the European market. If you sell into the EU, you will need digital product passports by the time EU textiles EPR is operational in April 2028. Even if you sell only in the UK, preparing for similar requirements makes sense.
Practical tip: Review your current product labels. Ensure fibre composition information is accurate and complete. If you are planning a label redesign, allocate space for a QR code that could link to a digital product passport in the future. Redesigning labels is a long lead-time activity — doing it proactively is far cheaper than doing it reactively.
Step 6: Budget for Future Compliance Costs
While UK textiles EPR fee rates have not been set, you can use international benchmarks to build rough estimates and avoid financial surprises.
France’s Refashion fees as a benchmark:
- Standard clothing item: EUR 0.01 to EUR 0.06 depending on product category (roughly 1p to 5p per item)
- Refashion applies eco-modulation through bonuses for durable, certified, and recycled-content products
- Products that impede recyclability face penalties through higher fees
Worked example:
A mid-sized fashion brand placing 500,000 garments on the UK market annually, at an average of approximately 3p per item, would face around GBP 15,000 per year in textiles EPR fees. If their products are predominantly made from hard-to-recycle blended fabrics attracting penalties, this could be significantly higher. If they invest in eco-design and qualify for bonuses, it could fall further.
The UK scheme may adopt different fee levels — potentially higher if it follows the packaging EPR model of recovering full end-of-life management costs. Budget conservatively and treat eco-design improvements as cost-reduction investments.
Other costs to budget for:
- Data systems — software or process changes to track textile volumes and composition (one-off investment)
- Registration and administration — time and resource to manage registration, reporting, and payment
- Labelling changes — updating product labels to meet new requirements
- Specialist advice — legal or compliance consultancy for initial setup, especially if you also sell into the EU
Practical tip: Add a line item for “textiles EPR” to your budget forecasts now, even as an estimated range. This ensures the cost is visible to decision-makers and does not come as a surprise when regulations are finalised. If your business already budgets for packaging EPR fees, use a similar approach.
Step 7: Sign Up for Regulatory Alerts
The textiles EPR landscape is evolving rapidly. Staying informed ensures you can adjust your preparation as details become clearer and avoid being caught off guard by timeline changes.
Sources to monitor:
- DEFRA — for UK consultation announcements and policy updates. Subscribe to DEFRA’s email alerts for waste and recycling policy.
- WRAP and the UK Textiles Pact — for industry data, best practice guidance, and voluntary commitment frameworks. WRAP’s UK Textiles Pact (formerly Textiles 2030) brings together brands, retailers, and recyclers to drive circular practices.
- European Commission — for EU directive implementation updates, especially if you export to the EU. The Commission publishes all legislative developments on its EUR-Lex portal.
- Trade bodies — the British Fashion Council (BFC), UK Fashion and Textile Association (UKFT), and British Retail Consortium (BRC) all track regulatory developments and coordinate industry responses to consultations.
- EPR Compliance — our textiles EPR page covers all UK and EU developments as they happen, with practical analysis of what each update means for businesses.
When consultations open, respond. Government consultations are your opportunity to shape regulations before they are finalised. Provide practical feedback on proposed thresholds, reporting requirements, and timelines. The more businesses that engage, the more workable the final scheme will be.
Practical tip: Set a calendar reminder to check for textiles EPR updates quarterly. Regulatory timelines can shift — what was expected in 2027 might move to 2028, or vice versa. Regular check-ins ensure you are always working to the current timeline.
Bringing It All Together
Preparing for textiles EPR does not require enormous investment today. It requires consistent, incremental action across these seven steps. The businesses that start with a product audit this month, begin tracking volumes next month, and progressively build their data and design capabilities will be fully prepared when obligations arrive.
Here is a suggested timeline for working through the seven steps:
| Step | When to Start | Time Required |
|---|---|---|
| 1. Audit product range | Immediately | 2-4 weeks |
| 2. Track volumes | Within 1 month | Ongoing |
| 3. Map materials and supply chain | Within 2 months | 4-6 weeks |
| 4. Review eco-design | Within 3 months | Ongoing |
| 5. Assess labelling | Within 4 months | 2-3 weeks |
| 6. Budget for costs | Within 3 months | 1-2 weeks |
| 7. Sign up for alerts | Immediately | 30 minutes |
The cost of preparation is a fraction of the cost of reactive compliance. Businesses that rushed to meet packaging EPR deadlines spent significantly more on data collection and system changes than those who had prepared in advance. Learn from that experience and start now.
For the full background on what textiles EPR will involve and who will be affected, read our comprehensive textiles EPR UK guide. If you also sell into the EU, our guide to EU vs UK textiles EPR differences covers the dual compliance considerations you need to understand.
Visit our textiles EPR page for the latest regulatory updates and to sign up for alerts when DEFRA opens its consultation.