EU Textile EPR: what it means for your brand
Your brand may already be a producer under EU law, whether you have registered or not. The revised EU Waste Framework Directive entered into force in October 2025. Every Member State must set up a mandatory Extended Producer Responsibility scheme for textiles and footwear by 2028. France, the Netherlands, Hungary and Latvia already run one. Spain, Italy and Belgium are close behind.
This catches more brands than people expect. If you place clothing, footwear or home textiles on the market in an EU country, you are likely a producer there, even when your company sits outside the EU and sells only online.
Does this apply to you?
Start with the first line. If it is true, work down the rest.
- You place clothing, footwear or home textiles on the market in at least one EU country.
- You sell online to customers in the EU, including from a company registered outside it.
- You import finished garments into the EU, or have them made for you under your own label.
- You are a brand rather than a retailer, but your name is on the care label.
- You sell through a marketplace and assume the marketplace takes care of this for you.
The last line is where most brands get caught. Marketplace liability differs by Member State and rarely covers everything you place on that market.
Where it already applies
Textile EPR · schemes in force
| Member State | Scheme |
|---|---|
| France | Running |
| Netherlands | Running |
| Hungary | Running |
| Latvia | Running |
| Spain, Italy, Belgium | In preparation |
| Every other Member State | Required by 2028 |
Registration happens country by country. There is no single EU filing, and being registered in France does nothing for you in Spain.
What the obligations actually are
Registration in each Member State where you sell, not once for the whole EU. An appointed authorised representative where you have no legal entity. Annual reporting of the volumes you place on that market. Fees, usually calculated per item and increasingly modulated by how the product is designed. Record keeping that has to survive an audit.
The fee modulation is the part worth paying attention to, because it is the part a designer can change. Schemes are moving toward charging less for products that are durable, repairable and made of a single recoverable fibre, and more for those that are not. That turns a compliance cost into a design decision.
Three regulations, one set of product data
EPR
Registration, reporting and fees in each Member State, increasingly modulated by how the product is designed.
DPP
A machine-readable record of what a garment is made of, where it came from and what can be done with it at end of life.
ESPR
Performance requirements for the product itself: durability, repairability, recycled content.
All three draw on the same information: fibre composition, supplier identity, traceability, documentation. Build that data once and it serves all three. Treat them as three separate compliance projects and you pay for it three times. The Digital Product Passport page covers the data side in detail.
Where a design studio fits
Most of the help available here comes from compliance platforms, scheme operators and law firms. They are good at registration and reporting, which happens after the product exists.
The decisions that set your fees, your passport data and your ESPR position are made much earlier: in the fibre, in the construction, in which supplier gets the order and what documentation that supplier can actually produce. This studio works at that point, from the product side rather than the legal side.
Start here
We wrote the practical guide: The Fashion Guide to EU Textile EPR: A Practical Compliance Playbook. It covers what applies to you, what to do first, and in which order.
If you would rather talk it through against your own range, the first 30 minutes are free. A Sustainability Consultation goes deeper: 60, 90 or 120 minutes, from 150 EUR.
This page explains publicly available EU regulation and is not legal advice. Obligations differ by Member State and by what you place on each market.
