EU Textile EPR for Clothing Brands: Who Pays, When It Starts, and What to Ask Your Factory

EU textile extended producer responsibility (EPR) makes the business that first places clothing on each EU country's market pay towards collecting and recycling it. Directive (EU) 2025/1892 has been in force since 16 October 2025, every member state must have a scheme by 17 April 2028, and France and the Netherlands already run one.

Whether you pay turns on whether you count as the producer in each country, and how much turns on weight and material, which is data your factory holds and you should ask for now. This guide is written from the factory side for small brands, including brands based outside the EU that sell online to EU customers. It covers who counts as a producer, the dates as the directive states them, the two national schemes we checked against their official texts, what the fee is based on, and the two numbers a factory should hand you. It is not legal advice: national laws are still being written, so the last step for any brand is to confirm with each country's producer responsibility organisation or an adviser. Dates and fees were last verified against official sources on 23 September 2026.

What is EU textile EPR?

Extended producer responsibility means the business that puts a product on the market pays for what happens to it once it is discarded. For clothing, the EU made this mandatory through Directive (EU) 2025/1892, which amends the Waste Framework Directive (2008/98/EC). EUR-Lex records its entry into force as 16 October 2025, and the European Commission announced it on the same day.

The directive inserts Articles 22a to 22d into the Waste Framework Directive. Each member state must run a textile EPR scheme. Producers must register in a national register, entrust their obligations to a producer responsibility organisation (PRO), and pay fees that fund the collection, sorting, re-use and recycling of used textiles. Under Article 22a(8) the same money also pays for surveys of the textiles left in mixed household waste, information for the public, reporting to the authorities, and research and development aimed at scaling up fibre-to-fibre recycling. Clothing is in scope through Annex IVc, which lists every code in CN chapter 61 (knitted or crocheted apparel) and chapter 62 (apparel not knitted or crocheted), alongside headwear, household textiles and footwear.

Are you a producer, even from outside the EU?

Probably, if you sell under your own brand to customers in the EU. The definition in Article 3(4b) of the amended Waste Framework Directive looks at where a business is established and how the garment first reaches a country's market, not at where it was sewn, and it applies whatever the selling technique, web shops included. It names four kinds of producer:

• The brand owner selling at home. Established in a member state, and making textile products under its own name or trademark, or having them designed or made and supplying them there for the first time under that name.
• The own-label reseller. Established in a member state and reselling there, under its own name or trademark, products made by others whose brand does not appear on them.
• The importer. Established in a member state and supplying there for the first time, on a professional basis, products from another member state or from a country outside the EU.
• The distance seller. Selling by distance contract directly to end users in a member state while established in another member state or in a third country.

Two consequences matter for a small brand. A brand based in the United States, the United Kingdom or Australia that sells online straight to EU consumers is a producer in each member state where it sells directly to end users. And a brand that sells wholesale to a stockist established in the EU may find that the stockist, as the business first supplying the garments in its country, is the producer there instead. The definition excludes self-employed tailors making customised pieces and businesses supplying used garments assessed as fit for re-use.

Registration is country by country. Article 22b requires a producer to apply for registration in each member state where it makes garments available for the first time, and a producer may not sell there until it, or its authorised representative, is registered. On representation the directive draws a line. A distance seller established in another member state must appoint, by written mandate, an authorised representative established in each country it sells into. For a distance seller established outside the EU, each member state may impose the same requirement, and France and the Netherlands already do. A PRO can take on the representative role under a written mandate if the producer wishes.

Marketplaces and fulfilment services will ask for proof. Online marketplaces must collect your registration number for the customer's country, and a self-certification that you comply, before letting you sell to consumers there (Article 22a(13)). Fulfilment service providers receive the same information when they sign you up, must make best efforts to check it, and must suspend the service if you fail to correct information that is inaccurate or incomplete (Article 22a(15) and (16)).

The directive sets the frame and each country's law fills in the detail. Before relying on any of this for a specific market, confirm with the national producer responsibility organisation (PRO) or an adviser.

When does it start? The dates, and which ones are settled

Every date below is quoted from the text on EUR-Lex rather than worked out from month counts. The transposition deadline is in Article 2 of Directive (EU) 2025/1892. The scheme deadline is Article 22a(14) of the amended Waste Framework Directive, and the micro-enterprise date is the paragraph the directive adds to its Article 41. The Commission summarised the timetable as 20 months to transpose and 30 months to set up schemes; the table gives the calendar dates the law itself states.

The first three rows are settled. The rest are deadlines the directive sets, but the date a brand actually has to register and pay in a given country comes from that country's own law, which can apply earlier than the EU deadline, as it already does in France and the Netherlands.

Micro-enterprises get a phase-in: the obligations reach them from 17 April 2029, twelve months after the scheme deadline. There is a catch. Recital 33 says a member state may keep an EPR scheme for waste textiles that already covers micro-enterprises when the directive entered into force. France's rule has applied since 2007 to every natural or legal person who professionally places these products on the French market, the Dutch decree applies to anyone who professionally places textiles on the Dutch market, and Refashion's 2026 schedule already offers a simplified declaration to marketers placing fewer than 5,000 pieces a year. A micro-brand selling into either country should ask the PRO there rather than assume the 2029 date applies. Once micro-enterprises are brought in, Article 22c(20) limits their annual report to the amount of product they placed on the market.

France and the Netherlands already run schemes

France has run textile EPR the longest. The Code de l'environnement text on Légifrance required anyone professionally placing new clothing, footwear or household linen for households on the French market to contribute to its recycling and treatment from 1 January 2007, and the product scope now sits in Article L541-10-1, point 11. A law of 8 July 2026 (Loi n° 2026-602) added Article L541-10-9-1, which requires a business not established in France that is subject to EPR to appoint, by written mandate, a representative established in France. Légifrance shows it in force from 10 July 2026.

Refashion is approved as an eco-organisation for clothing, household linen and footwear by an order of 23 December 2022, until 31 December 2028. Its own guidance says online sellers are covered even when they are based abroad. Marketers declare to it the pieces they place on the market, and its explainer says a unique identifier number (IDU) shows that a marketer is registered and paying its contribution.

The Netherlands followed with the Besluit uitgebreide producentenverantwoordelijkheid textiel, a decree of 14 April 2023 that wetten.overheid.nl shows in force from 1 July 2023. It treats as a producer anyone who professionally places textile products on the Dutch market for the first time, whatever the selling technique, and covers clothing in CN chapters 61 and 62 plus household linen. A producer not established in the Netherlands must appoint an authorised representative established there (Article 2). Article 3 sets targets by weight: of the textiles a producer placed on the Dutch market the year before, 55% must be prepared for re-use or recycled in 2026, rising to 75% from 2030. A report on the previous calendar year is due each year before 1 August (Article 7). Stichting UPV Textiel runs a collective scheme: participants forecast in kilograms before 1 April and settle against actual volumes the following year.

This guide checked only these two national schemes. Sweden's government, for example, published an assignment on 15 December 2025 asking Naturvårdsverket to propose how the directive's textile requirements should enter Swedish law, with a final report due by 13 November 2026; our Swedish brands page follows it. For any other member state, check its current law before assuming nothing applies yet. Our pages for French, Dutch and European brands cover duty, labelling and the other rules for selling into those markets.

What is the fee based on?

The directive does not set a fee. Article 22c(5) sets the method every national scheme must follow and leaves the amount to each PRO:

• Weight first. Contributions are based on the weight and, where appropriate, the quantity of products placed on the market.
• Adjusted for design. They are modulated by the ecodesign requirements adopted under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 that matter most for preventing and treating textile waste, or by other EU law setting harmonised sustainability criteria. The Commission names durability and recyclability as examples and calls this eco-modulation.
• Net of what the waste earns. They take account of the PRO's revenue from re-use and from recycled materials.
• Equal whatever your origin or size. Producers must be treated alike wherever they come from and however big they are, without disproportionate burdens on small and medium-sized businesses that sell small quantities.

Two further powers matter. Under Article 22c(6), a country may modulate fees to address ultra-fast and fast-fashion practices, looking at product life span, how long products stay in use beyond the first user, and whether waste is turned back into raw material. Under Article 22c(7), the Commission sets common modulation criteria by implementing act where that is needed to avoid distorting the internal market, and those acts do not fix the level of fees.

Two official schedules show what that looks like, both read on 23 September 2026. Stichting UPV Textiel set its 2026 contribution at €0.24 per kilo of textile placed on the Dutch market. Refashion's 2026 schedule charges per piece by product line: in the detailed declaration a T-shirt-type top is €0.0396 for adult men and €0.0323 for adult women, including the repair and re-use funds. A simplified declaration, open to marketers who declare no products eligible for eco-modulation and place fewer than 5,000 pieces a year, costs €0.5799 per clothing piece; Refashion says the higher rate covers the missing eco-modulation data and traceability. Refashion's eco-fee page adds administrative costs and an ADEME fee to the calculation.

In France, Refashion's 2026 eco-modulations award bonuses for durability, for certification to environmental labels and for recycled content, and charge a recyclability penalty on garments containing metallised-plastic fibres or electronic or electrical components other than tracking tags such as RFID. For a small brand selling into France, the choice of declaration is a real decision. The simplified route means less paperwork and costs more than ten times as much per T-shirt. The detailed route needs every style assigned to a product line, is open at any volume and is compulsory for anyone declaring products eligible for eco-modulation. Either way, the quantities the fee multiplies are yours to supply, and part of the data behind them comes from your factory.

What your factory can give you

Two inputs to an EPR declaration come from the factory, and both are easy to get if you ask before bulk production rather than after. The first is net weight per piece for every SKU: each style, colour and size weighed as a finished garment without its packaging, because a weight-based fee multiplies it and an XL does not weigh what an XS does. The second is the fibre or material composition of each style, taken from the mill specification, because recyclability, one of the criteria fees are modulated on, depends on what a garment is made of.

What the factory cannot give you is the number the fee is charged on: how many units, and how many kilos, you placed on each member state's market. Once an order leaves the factory, where each piece is sold is known only to the brand. Keep that count by country and by style from your first EU sale, because the schemes already running ask for it, in pieces by product line in France and in kilos in the Netherlands.

Keep weight and composition in one sheet per style, next to the tech pack. Ask for both when you approve the pre-production sample, and have the weights re-checked on bulk pieces, since those are the garments you will declare. Most of the rest of a garment's data, from the country of each processing stage to chemical records, belongs to the Digital Product Passport rather than to EPR, and the passport guide's data table shows who holds each item. If you are planning a range for customers in Europe, our page for European brands explains how we work, from 100 pieces per style, per colour.

How EPR sits next to GPSR, the passport and packaging rules

EPR is one of several EU regimes that reach a clothing brand, and each asks a different question. The General Product Safety Regulation asks who answers for the garment's safety, which our GPSR guide covers. The Digital Product Passport will ask what the garment is made of and where; see the DPP guide. Fibre composition on the label, in the official language of each country of sale, is a separate duty again under Regulation (EU) No 1007/2011, set out in labelling requirements by country. Packaging has its own producer responsibility under the Packaging and Packaging Waste Regulation (EU) 2025/40, so polybags and cartons sit outside textile EPR; labels, hang tags and packaging covers the physical choices. Chemical limits are a separate question again: REACH restricts PFHxA in clothing, and our PFAS guide sets out what that restriction and the French and Danish bans require.

The EPR authorised representative and the GPSR responsible economic operator are separate roles under separate laws, and an EPR representative is appointed country by country. When a service provider offers to act for you in the EU, ask which role it is taking on, and in which countries.

A checklist for 2026 and 2027

Sources

Last verified: 23 September 2026. Every date, article number and fee on this page was checked against the sources below on that day. National rules will change as countries transpose the directive, so check the current text before making a compliance decision.

• EUR-Lex — Directive (EU) 2025/1892 amending Directive 2008/98/EC on waste
• EUR-Lex — Directive (EU) 2025/1892, document information and dates
• EUR-Lex — Directive 2008/98/EC on waste, consolidated text of 16 October 2025
• Légifrance — Code de l'environnement, Article L541-10-1
• Légifrance — Code de l'environnement, Article L541-10-9-1
• Légifrance — Arrêté du 23 décembre 2022 approving Eco TLC - Refashion as eco-organisation
• Refashion — 2026 eco-contribution schedule (PDF)
• wetten.overheid.nl — Besluit uitgebreide producentenverantwoordelijkheid textiel
• Stichting UPV Textiel — producers and importers, 2026 contribution

The full list, including the Commission's announcement, the earlier French text, Refashion's own guidance and Sweden's assignment, is at the foot of this page.