what is extended producer responsibility for textiles and does it relate to the product passport
EPR for textiles is a separate regulation alongside the product passport
Extended Producer Responsibility (EPR) for textiles is a system in which producers and importers of textiles contribute to the collection, sorting and recycling of textiles that end up as waste. The idea: whoever brings clothing or textiles to market also bears responsibility for what happens when the product is thrown away. This is separate from the digital product passport, but the two emerge from the same movement towards a circular textile sector and touch on practical points. The product passport concerns information that a product carries throughout its entire lifespan; EPR concerns the financing and organisation of the waste phase at the end of that lifespan.
For whom EPR applies and for what it does not
EPR obligations for textiles are directed, like the product passport, generally at the party that first places the product on a national market: the producer, or in the case of imports, the importer. The exact implementation — who exactly falls under the regulation, which product categories count, and what contribution is requested — is worked out at national level within the European framework of the Waste Framework Directive. That directive (Directive 2008/98/EC) provides the general framework for producer responsibility for waste streams, textiles included, but the concrete regulation per country can differ. This means that the question of whether and how EPR for textiles precisely applies must be answered on the basis of the national implementation, not only on the basis of the European directive itself. EPR does not concern product information or a QR code, and therefore says nothing about the question of whether specific clothing falls under the product passport — that question is answered separately, among other things on the page on which clothing and textile products fall under the ESPR.
When EPR enters into force and what applies until then
For EPR textiles, member states are required under the Waste Framework Directive to organise separate collection of textiles, and producer responsibility is an instrument that countries can and increasingly do deploy for this purpose. The exact date on which a mandatory EPR contribution for textiles enters into force in a specific country is not fixed here and differs per country: this depends on national legislation based on the European Waste Framework Directive. Until such a national regulation actually comes into force, the general obligation to organise separate collection of textiles applies, without there necessarily being a financial producer contribution attached to it yet. This process runs separately from the date on which the digital product passport becomes mandatory; that date is determined separately via a delegated act under the ESPR and is described on the page on when the product passport becomes mandatory for clothing and textiles. Anyone who wants to know what a delegated act precisely is and why it determines what a company is expected to do will find more about this on the page on what a delegated act is.
What this means in practice
For a clothing brand or importer, EPR and the product passport are two separate administrative obligations that can become interconnected. First, it is important to know whether and which national EPR regulation applies to the countries where products are placed on the market — this is determined per country and the national implementing organisation or government authority is the appropriate source for this. After that, it is useful to look at the specific product category: does it fall under the ESPR rules for textiles, and if so, what information must then go into a passport in the future. That question is set out on the page on whether the product passport applies to specific clothing and textiles. In practice, information collected for a digital product passport — material composition, origin, recyclability — may also be relevant for an EPR contribution, because many EPR systems make the contribution amount depend on exactly that kind of material properties. Companies that treat these two processes separately run the risk of doing duplicate work; those that consider them together can use data collected once for two purposes. For smaller companies, it is useful to know that exemptions or lighter regimes in one regulation do not automatically apply in the other — the page on whether the product passport also applies to small companies addresses this specifically.
The legal basis: the Waste Framework Directive
The foundation for producer responsibility for textiles lies in Directive 2008/98/EC, the Waste Framework Directive. This directive requires Member States to introduce separate collection of textiles and provides the framework within which countries can introduce extended producer responsibility schemes, including the possibility of requiring producers to contribute to collection and treatment. The directive itself does not establish a uniform, EU-wide EPR obligation with fixed amounts or dates; the concrete implementation is left to national legislation. This is an important difference from the digital product passport, which follows directly from the ESPR Regulation and its accompanying delegated acts and therefore will apply throughout the EU at the same time and with the same content.
If you currently place clothing or textiles on the market, it is advisable to follow national EPR developments in your own sales markets via official government channels there, and in parallel use the ESPR pages on this platform to determine what the digital product passport will concretely mean for your own product category.
What this is based on
The regulation itself is available on EUR-Lex. We provide references for each statement; you do not need to take our word for it.
What you must do concretely
What is expected of you
Extended producer responsibility, usually abbreviated to EPR, is not a new invention for textiles. The principle originates from the Waste Framework Directive (Directive 2008/98/EC) and in short means that the party placing a product on the market is also held responsible for what happens to that product when it becomes waste. For textiles, this means that a company selling clothing or textile products becomes involved in the collection, sorting, reuse or recycling of those products at the end of their life — usually through contributions to a collective system that performs these tasks.
Registration and membership of a system
In practice, a company placing textiles on the market is required to register and join a producer organisation or similar system that manages the collection and treatment of textile waste. For a company with 10 to 100 employees, this usually means recurring administrative burden: keeping track of how much textiles (often in kilograms) have been placed on the market, and paying a contribution based on that amount. This is separate from the question of whether a company does anything about collection itself — the contribution finances the collective system.
Reporting on quantities placed on the market
In addition to joining a system, companies are expected to report periodically on the quantities of textiles they sell. These figures form the basis for the EPR contribution and are used to monitor national targets for collection and recycling. For administration, this means that sales data by category (for example, clothing, household textiles, accessories) must be transparent, which especially for companies with a broad range or multiple brands adds an extra registration layer on top of existing inventory and sales administration.
Contributions to separate collection
Since January 2025, the EU has a mandatory requirement for separate collection of textiles by municipalities and Member States. EPR systems are the financial mechanism through which this collection is funded: producers and importers contribute in proportion to what they place on the market. This does not directly affect business operations on the shop floor, but it does affect the cost structure — the contribution becomes part of the product's cost price, comparable to how packaging fees have worked for some time.
Where things go wrong in practice
A common situation is that a company confuses EPR and the digital product passport with each other, or assumes that one replaces the other. This is not the case: EPR governs the financing and organisation of waste management, the product passport concerns information during the product's lifetime. Anyone who has already looked into what a digital product passport for clothing and textiles entails, will see that the two obligations stem from different legislation and serve different purposes, even if they touch on each other in some respects — for example, where passport information can be relevant for sorting at the end of the product's life.
A second situation arises with companies that assume EPR only applies to large clothing brands. The waste framework directive does not in itself make a distinction based on company size in the principle of producer responsibility; how this is precisely implemented differs per Member State, because the directive provides a framework that is implemented at national level. This is a different mechanism than the thresholds that apply, for example, in the question whether the product passport also applies to small companies — the two regulations do not automatically have the same exemptions.
A third situation occurs with companies that, in addition to clothing, also sell accessories, shoes or interior textiles and assume that EPR obligations are identical for all these categories. The scope of EPR systems and the fees differ per product category and per Member State. Something similar applies to the product passport, where the question whether this also applies to shoes, bags and belts or to household textiles such as curtains and sheets is answered separately — it is not a matter of one answer for all textile products at once.
A fourth situation is that companies wait to register with EPR until the product passport becomes mandatory, on the assumption that both take effect at the same time. EPR for textiles is already operational or in preparation in various Member States, whereas the product passport follows a separate timeline that is described on the page about when the product passport becomes mandatory for clothing and textiles. If you confuse these two dates, you risk missing an obligation that applies earlier.
A fifth situation concerns workwear and occupational clothing, where it is assumed that internal supply to staff falls outside EPR because there is no "sale" to a consumer. Whether and how this is precisely handled depends on the national implementation of the EPR scheme; this is a question that touches on the same category of uncertainty as with workwear and uniforms and the product passport, where the classification is also not self-evident.
What you can record
- Registration certificate from the national EPR system, with date of registration and assigned registration number.
- Overview of quantities of textiles placed on the market per period, broken down by product category, as a basis for periodic reporting.
- Correspondence with the producer organisation regarding tariff setting, category classification and any exemptions.
- Internal assignment of responsibility: who within the organisation prepares and submits the reporting, and at what point in the year.
- Distinction between product categories in the company's own records (clothing, accessories, interior textiles, workwear), so that if there is doubt about classification, the rules applied per category can be quickly checked.
- An overview of the connection with other obligations, so that EPR is not isolated from broader ESPR-related matters; the page on the distinction between the ESPR and the European textile strategy provides a starting point for placing these two tracks — waste management and product information — side by side without confusing them.
This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something not right? Let us know — corrections are given priority.