What is EPR and why does it matter in fashion?

According to the United Nations (UN) Extended Producer Responsibility (EPR) is a policy that holds producers accountable for their products throughout their entire lifecycle, including after consumers have used them. This environmental policy shifts the responsibility for handling specific end-of-life products from local governments and consumers to the companies that manufacture or sell these products, therefore introducing the Polluter Pays Principle to the post-consumer stage of a product’s life cycle. At the same time, it also leads a way into achieving environmental goals such as recycling targets.  

This concept, introduced in Europe in the early 1990s with the introduction of the GreenDot scheme, has gained significant relevance, being adopted worldwide. Since this initiative, EPR has been an integral part of European environmental policy, and continues to expand into industries, such as textiles. 

Typically,  EPR obligations are fulfilled with: 

• financial support: such as paying fees to authorities or external recycling and waste management services;  

• take-back programs: involving gathering used items and materials for recycling or proper disposal; and 

• product design: allowing for simpler approaches to recycle, repair, or reuse.

Why does EPR matter?

EPR is more than waste management,  it stimulates the end goal of waste reduction, and for producers to come up with greener alternatives for their products and packaging, going beyond end-of-life management by having a more active role in rethinking the product, ultimately aiming to cut waste and lessen environmental and health risks.  

Currently, the textile system is largely linear, relying on high volumes of new products made from virgin materials, used briefly, and then discarded. Over 80% of textiles end up incinerated, landfilled, or polluting the environment because dedicated collection systems are underdeveloped, and recycling is difficult. Products are often not designed for durability or recyclability, and separate collection, essential to prevent waste, remains economically unviable. Sorting and managing discarded textiles rarely cover costs, creating a major barrier to a circular textile economy. 

For the textiles industry, effective EPR policies can result in an enhanced financial balance for activities such as separate collection, sorting, reuse, repair, and recycling of used textiles. Additionally, EPR provides greater visibility and tracking of material movements worldwide and supports the attraction of investment for large-scale reuse and recycling infrastructure. 

EPR in textiles

EPR for textiles means that these producers are held accountable for the collection, sorting, and overall management of textiles throughout their entire life cycle once they are placed on the market.  

The textiles EPR legal landscape

France has led the way, introducing the legal concept of EPR in textiles by establishing measures for collection and recycling since 2007. The legislative framework (resulting from the Code de l’environnement)  first required producers to take responsibility for the end-of-life management of textiles, including clothing, household linens, and footwear. Currently, according to the French EPR system, companies that place textiles on the market must contribute to the funding of collection, sorting, and recycling operations.  

Other jurisdictions are moving to implement EPR schemes for textiles, but France’s case remains a reference to shape policies and provide guidance on how industry collaboration can support circular economy goals and reduce environmental impacts. 

The success of this influenced similar legislation in other European countries and set standards that are now being reflected in broader European Union (EU) policies, such as the new Directive (EU) 2025/1892. 

European Union (EU) law

Companies considered as producers of textiles in the EU, must be aware that, as of 26 September 2025 Directive (EU) 2025/1892 updates the existing rules around waste, particularly impacting the Extended Producer Responsibility (EPR) scheme for textiles.  

So, what does this mean? If a company is considered a textile producer, for example, placing products like blankets, bedding, curtains, used clothing, leather accessories, or even certain waterproof shoes on the EU market will have to begin to, according to Articles 22a to 22d, among others: 

• arrange and cover the costs of collecting and managing the waste of used textiles and shoes that are deposited at collection points when they reach the end of their life; and 

• share information with the public, through campaigns, about sustainable consumption, waste prevention, re-use, preparing for re-use, including repair, recycling, other recovery and disposal of textiles. 

Additionally, following Article 22b, these companies will have to register as a producer in every country where they sell these products for the first time, giving details like the company’s name, contact info, and product codes. 

Moreover, the new framework will define new record-keeping requirements, ensuring the product is accompanied by, among others, a description of the item or items present and any relevant characteristics that contribute to efficient re-use.  

In summary, despite requiring Member States’ transposition, Directive (EU) 2025/1892 will establish more stringent requirements for companies to have to comply with, following the extended EPR obligations in textiles. For instance, companies will have to join producer responsibility schemes, cover the costs of collecting, sorting, and recycling their products at end-of-life, and register in the national Register of Producers of textile products of each Member State where the company places the mentioned products on the market for the first time. 

This ultimately results in much stricter obligations for companies manufacturing and placing textiles in the EU market, by 17 June 2027.  

International frameworks

But how are EPR schemes developing on a global scale? As mentioned, there is currently a legislative impulse to implement EPR schemes across the globe and Chile and Mexico are two examples of how the international landscape is evolving for textiles EPR.  

In Chile, the data on textile consumption equates to each person using about 32 kilograms (kg) of textiles annually which results in over 572,000 tons of textile waste produced nationwide every year. This amount represents 7% of the country’s urban solid waste per capita.  

This brought the Chilean Government to adopt measures to include EPR requirements for textile manufactures and importers. The most recent amendment to Law 20920, which establishes a framework for waste management, extended producer responsibility and promotion of recycling (Ley 2092) establishes that these companies must register with the Pollutant Release and Transfer Register (PRTR) and annually declare the quantity of textile products they place on the Chilean market.  

In Mexico, companies could also have to comply with more stringent EPR requirements for textiles if the Proposed amendments for the General Law for the Prevention and Comprehensive Management of Waste are adopted. It could mean that companies that discard used or new textiles can be required to take responsibility for waste management and to formulate and implement the corresponding management plans. 

Otherwise, voluntary take-back textile schemes have also shown success cases recently, showcasing the potential as a circular economy solution.  

Voluntary take-back schemes

Voluntary programs consist of an additional way for companies to actively address the effects their products have at the end of their lifecycle, while standing out as sustainable competitors, and attracting stakeholder value. 

These voluntary schemes may be organized by governments, like the UK’s “UK Textile Pack,” which is a voluntary agreement that unites businesses to promote a circular approach to textiles. They can also be set up by individual companies, which may create their own take-back programs to gather unwanted textiles for reuse or recycling. 

Voluntary schemes have been gaining awareness in the past decade. However, momentum is shifting toward regulation, and companies must be prepared for compliance challenges.  

EPR challenges for companies

Having seen the increasing regulatory landscape of EPR for companies in the textile industry, it is clear they now face an intense scrutiny accompanied with a fair share of challenges to align with EPR requirements and policies, balancing sustainability goals with operational realities. Mainly, these challenging operational realities can be summed up in four aspects: increased costs for companies, infrastructure or lack thereof, traceability issues, and the limited market for recycled textiles.  

Cost 

Transitioning to circular models, such as EPR, requires a high upfront investment in innovative technology, infrastructure, and training within businesses. Without regulatory incentives or consumer willingness to actively participate in take-back schemes and EPR schemes to be put in place, many brands struggle to justify these costs internally. Consequently, companies deem EPR as not economically viable.  

Infrastructure (recycling facilities and machinery) 

As per the infrastructure present within the textile industry, there is a clear lack of physical and technological infrastructure needed for real and effective large-scale circularity. Textiles businesses can put in place their own collection systems; however, as sorting and disassembly technologies are still emerging, many businesses lack adequate collection networks and systems, still relying heavily on manual sorting, which is inefficient and costly. This lack of innovative technology, paired with the vast amount of used and discarded textiles, makes the current EPR systems faulty.  

Moreover, the effectiveness of EPR is further constrained by technical hurdles such as proper fiber separation and contamination during processing. Without available incentives and funds to develop chemical and enzymatic recycling technologies, adequate recycling and repurposing of textile waste is nearly inconceivable.  

Traceability 

Traceability is essential for EPR to work, but unfortunately, current systems are fragmented and opaque. Many businesses struggle to trace beyond their immediate suppliers, which creates significant blind spots deeper in the supply chain. This lack of visibility makes it challenging for companies to verify the sourcing materials, confirm material origins, and proceed to proper recycling of the product.  

Emerging technologies such as blockchain or the EU Digital Product Passport (DPP) promise greater transparency, but adoption remains slow and depends on industry-wide collaboration. Progress is further hindered by the absence of standardized data models and poor interoperability between systems, making it difficult to achieve a truly connected and accountable supply chain, and therefore, hindering operative recycling after the product has been recovered.

Market for recycled textiles 

Lastly, companies face limited market demand and usability of recycled textiles. Recycled fibers often suffer from quality issues such as reduced strength and poor color retention, making them unsuitable for high-performance garments. While consumer awareness of sustainability is growing, many still prefer new garments or are unaware of recycling options, creating a gap between availability and adoption. 

Risks  

Together with the challenges companies face, failing to keep pace with evolving regulations exposes them to significant risks, from financial penalties and reputational damage to losing competitive advantage in a market that demands transparency. In consequence, the risks are multifaceted, spanning from reputational, or regulatory penalties, to stakeholder expectations.  

Considering the impact textiles have on the planet and our society, both consumers and investors increasingly expect brands to take responsibility for their waste, decent labor practices, and the big environmental impact. Misleading sustainability and EPR related claims paired with excessive textile waste can escalate into a public relations crisis for businesses, damaging their reputation. Social media amplifies this risk, allowing negative narrative to spread rapidly and widely. Once the reputation is undermined, it can be difficult and particularly costly to rebuild, risking suffering long-term damage to the company’s image and customer loyalty.  

As the regulatory landscape keeps evolving and tightening, textiles companies are under growing pressure to comply with complex and evolving legal frameworks. Non-compliance with EPR laws can result in substantial fines, legal sanctions, or even exclusion from key markets. Additionally, regulations like the EU Corporate Sustainability Due Diligence Directive (CSDDD) and national laws such as Germany’s Lieferkettengesetz (Supply Chain Act) mandate rigorous oversight of supply chains. Companies that fail to meet these standards risk not only penalties but also losing access to public procurement opportunities and investor confidence. 

Furthermore, beyond regulators and consumers, companies are increasingly held accountable by a broader range of stakeholders, such as investors, NGOs, and business partners. Investors are integrating more ESG criteria into their decision-making processes, meaning that poor EPR implementations can limit access to capital or reduce valuation. This multi-directional pressure creates a complex landscape where companies must balance compliance, innovation, and transparency to maintain stakeholder trust and competitive advantage. 

This means that the vast majority of textiles remain outside the circular economy, representing a missed opportunity to recover valuable resources and reduce greenhouse gas emissions. Unrecovered textile waste equates to billions of lost raw material value annually, underscoring the urgent need for scalable recycling technologies and stronger policies to promote circularity. 

Navigating EPR complexity with Enhesa

EPR is not just a compliance issue; it’s a strategic one. Companies must stay ahead of evolving legislation, especially in multi-jurisdictional contexts. Enhesa’s global regulatory intelligence helps businesses monitor, interpret, and act on EPR requirements across markets. 

EPR holds transformative potential for the fashion and textile industry, but only if companies embrace it as a strategic opportunity rather than a box-ticking exercise. By investing in legal foresight and sustainable design, businesses can stay ahead of regulation, reduce their environmental impact, and build long-term resilience. Those who act early and ambitiously won’t just be meeting legal requirements, but they will lead the shift toward a sustainable and circular textile economy.