What is the EU’s Extended Producer Responsibility law for Textiles? This article explains what fashion brands need to know about this regulation adopted by the EU as a step towards circular economy.
Overview
The European Union has formally adopted Extended Producer Responsibility (EPR) for textiles as part of the revised Waste Framework Directive (WFD) on 16 October 2025. This is a landmark moment in the EU’s transition to a circular economy and a central mechanism to operationalize the EU Green Deal and the Circular Economy Action Plan. It shifts how future textile, apparel, and footwear products can be designed, documented, and managed at end of life it also introduces mandatory EPR fees (also known as eco-modulated fees) that all producers placing products on the EU market will be required to pay.
What EPR Means for Textiles:
EPR for textiles requires producers to take full financial and operational responsibility for products at the end of their life - including the collection, sorting, reuse, and recycling of post-consumer textiles. Under this model, producers, not consumers or public authorities, will fund these systems through mandatory EPR fees, which rise or fall depending on a product’s durability, recyclability, and material composition.
As national schemes are implemented, brands will increasingly see design, sourcing, and data accuracy directly reflected in their compliance costs. This is not a penalty, but a structural realignment: those who design and place products on the market are best positioned to influence how circular and recoverable those products can be. Preparing now - through improved material traceability, ecodesign, and robust supply chain data - will help brands manage costs and remain competitive as the EU accelerates its transition toward a circular economy.
EPR Timeline
The Directive is already in force, and implementation will unfold over the next several years. Member States are required to transpose the rules into national law by mid-2027, with mandatory EPR schemes for textiles operating across the EU from April 2028. A further expansion in 2029 will extend cost-coverage requirements to micro-enterprises.
Who is impacted?
The new EU rules apply broadly to any “producer” that makes new textile, textile-related or footwear products listed in Annex IVc available on the market of an EU Member State, including non-EU companies selling online into the EU.
Definition of Producer
A Producer of textile products means any manufacturer, importer, distributor, or other natural or legal person who, regardless of the sales method used (including distance selling), meets any of the following criteria:
- EU-based producers placing new textile, apparel, or footwear products on the market.
- Non-EU producers selling new textile products directly to EU consumers (must appoint an authorized representative)
- Online marketplaces selling new items which must ensure that third-party sellers are registered and compliant.
There are no exemptions to EPR based on company size, turnover, or sales model. E-commerce and traditional retail are equally covered.
WHO IS Not in scope of EPR for TextileS
Producers of second-hand or re-used textile, textile-related or footwear products.
How to Comply with EU EPR Schemes
To comply with the various EPR for Textiles schemes across EU member states, producers will need to register in each Member State where they sell products, participate in a Producer Responsibility Organization (PRO), and report annual data on volumes and composition. They will also be responsible for funding the collection and treatment of textile waste, either individually or through a PRO.
EPR schemes aim to activate ecodesign principles and greater transparency into the flow of textile products across EU markets. For many brands, the most significant shift will be the need to track product attributes - such as weight, material composition, and recyclability - with far greater accuracy than before.
How EPR Fees are Calculated for Textiles
EPR fees for textile are designed to cover the full life-cycle cost of managing textile waste, and under the new rules they will be “eco-modulated.” This means fees rise or fall based on a product’s environmental performance. While each Member State will set its own formula, eco-modulation across the EU generally considers:
- Material types (e.g., plastics, metals, textiles, composites)
- Recyclability, toxicity, and circular potential
- Product durability and reparability
- Ease of disassembly and traceability of components
- Presence of hazardous substances
Eco-modulated EPR fee structures reward brands that apply circular design principles with lower fees, while assigning higher costs to products that are more complex or difficult to recycle to reflect their greater end-of-life impact. Ensuring data accuracy and start aligning products with emerging EU Ecodesign initiatives, such as those introduced under ESPR and the PEF methodology can help you to prepare for EPR fee criteria that may evolve.
Image of the different factors that influence EPR or eco-modulation fee calculations
Risks of EPR Non-Compliance
As a producer, failure to comply with EPR obligations may, at national level, give rise to a range of consequences, including:
- The imposition of administrative fines or judicial penalties.
- A prohibition on placing products on the market in those Member States where compliance has not been ensured.
- Suspension or removal of products from online platforms or marketplaces.
- Reputational harm arising from failure to comply with increased transparency and disclosure requirements.
Risk Mitigation
To mitigate EPR risks, brands should start by reviewing their product portfolio for recyclability, durability, and material complexity, as these factors will influence future eco-modulated fees. Strengthening product data systems is equally important, as accurate reporting depends on reliable tracking of weights, compositions, recycled content, and market volumes across all EU markets. Monitoring national transposition, mapping supply chains, and engaging early with PROs or authorized representatives will help ensure a smooth transition as requirements take effect.
How Traceability Supports EPR Compliance
Supply Chain Traceability plays a critical role in meeting EPR obligations. The ability to verify materials, confirm recycled content, and report product chemical safety accurately is central to the new regulatory model. Without centralized and robust data flows, compliance becomes both risky and expensive.
Platforms like TrusTrace help fashion brands build this foundation. By automating data collection, enabling product-level visibility, end-to-end tracibility and digital compliance infrastructure, traceability systems provide the data backbone required for EPR and other legislation that supports EU’s Circular Economy vision.
About TrusTrace
Traceability is your foundation for compliance. With TrusTrace, you can build a robust, traceability and compliance program that turns EPR into a business opportunity.
- End-to-end traceability of material origin and recycled content.
- Automated data collection for volume, weight, and composition.
- Seamless integration with supply chain software partners — resale, repair, recycling.
- Digital regulatory compliance to simplify reporting efficiency across markets.
Contact the TrusTrace team to speak with an expert and explore our different solutions.
