A Quick Guide to the Waste Framework Directive and CN Codes in Scope

The Waste Framework Directive (WFD) is the European Union's cornerstone legislation for waste management—and as of October 2025, it's reshaping how your textile and footwear business must operate across EU markets.

What is the EU Waste Framework Directive?

The WFD (Directive 2008/98/EC) establishes the legal framework for how waste is defined, managed, and processed across all EU Member States. Think of it as the EU's master rulebook for waste policy. It sets recycling targets, defines the waste hierarchy (prioritizing prevention, reuse, and recycling over disposal), and—critically—authorizes Extended Producer Responsibility (EPR) schemes.

WFD and EPR: How They Connect

The WFD is the law; EPR is the mechanism. Recent amendments to the WFD, which entered into force on October 16, 2025, introduced mandatory EPR for textiles, footwear, and related products. This means the WFD now requires EU Member States to establish EPR schemes that make you, the producer, financially and operationally responsible for your products' end-of-life management.

If you place textile or footwear products on the EU market, EPR is no longer optional. The WFD mandates it, and Member States must implement their own national schemes by April 2028.

Which Products Are in Scope?

The WFD's Annex IVc provides the definitive list of products subject to EPR obligations. Understanding these Combined Nomenclature (CN) codes is essential—they determine whether your products fall under the new requirements. Download the CN Codes list for textiles here.

Part I: Textile Products and Apparel

Apparel and Clothing Accessories:

• CN 61 (all codes): Articles of apparel and clothing accessories, knitted or crocheted
• CN 62 (all codes): Articles of apparel and clothing accessories, not knitted or crocheted

Home Textiles:

• CN 6301: Blankets and travelling rugs (except 6301 10 00)
• CN 6302: Bed linen, table linen, toilet linen, and kitchen linen
• CN 6303: Curtains (including drapes) and interior blinds; curtain or bed valances
• CN 6304: Other furnishing articles (excluding those of heading 9404)

Other Textile Products:

• CN 6309: Worn clothing and other worn articles
• CN 6504: Hats and other headgear, plaited or made by assembling strips of any material
• CN 6505: Hats and other headgear, knitted or crocheted, or made up from lace, felt, or other textile fabric

Part II: Footwear and Non-Textile Apparel Accessories

Leather Accessories:

• CN 4203: Articles of apparel and clothing accessories, of leather or composition leather (excludes footwear, headgear and parts thereof, and goods of chapter 95)

Footwear (All Types):

• CN 6401: Waterproof footwear with outer soles and uppers of rubber or plastics, where uppers are not fixed to the sole by stitching, riveting, nailing, screwing, plugging, or similar processes
• CN 6402: Other footwear with outer soles and uppers of rubber or plastics
• CN 6403: Footwear with outer soles of rubber, plastics, leather, or composition leather and uppers of leather
• CN 6404: Footwear with outer soles of rubber, plastics, leather, or composition leather and uppers of textile materials
• CN 6405: Other footwear

Important Note: If your product falls under any of these CN codes and you place it on the EU market for the first time, you must register and comply with EPR obligations in each Member State where you sell.

WFD Requirements

Under the WFD's EPR provisions (Articles 8, 8a, and 22a-22d), you must:

• Register in each Member State where you place products on the market
• Join a Producer Responsibility Organization (PRO) or establish individual compliance
• Report product data annually (volumes, weights, material composition)
• Pay eco-modulated fees that reflect your products' environmental performance
• Fund collection and treatment infrastructure for textile waste management
  

Timeline

• October 16, 2025: WFD amendments entered into force
• June 2027: Member States must transpose WFD into national legislation
• April 2028: Mandatory textile EPR schemes operational across all EU Member States
• April 2029: Micro-enterprises must comply (one-year extension)
  

Why This Matters

The WFD's expansion into textile EPR represents a fundamental shift from voluntary sustainability initiatives to mandatory compliance obligations. The CN codes listed above define the legal scope—if your products are listed, you're obligated to act.

This isn't just about avoiding penalties. The WFD's eco-modulation framework means your compliance costs will directly reflect your product design choices. Products that are durable, recyclable, and use simpler material compositions will benefit from lower fees. Products that are difficult to recycle or contain hazardous substances will face higher costs.

Ready to Build Your Compliance Strategy?

Understanding which products fall under the WFD is your first step. Next, you'll need to establish traceability systems that can verify material composition, track recycled content, and report accurate product data across your entire portfolio.

Learn more about Extended Producer Responsibility (EPR) compliance requirements and discover how TrusTrace helps brands build the data foundation required for WFD compliance. Download the WFD Guide.

Ready to address your specific WFD and EPR questions? Connect with TrusTrace to explore how our platform and expert guidance can help you build efficient, effective compliance programs tailored to fashion and textile supply chains.

Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.