Textile EPR: France, the Netherlands and the EU Scheme

For a long time extended producer responsibility (EPR) for textiles was a single country's practice: France. The picture is changing. The Netherlands launched its own scheme in 2023, and the revision of the Waste Framework Directive adopted in 2025 extends textile EPR to every Member State. For a Turkish exporter there are two questions: who pays the fee, and what sets it? The answer to the second leads straight to the Digital Product Passport (DPP).

How EPR works in textiles

The logic is the same as for other product groups: whoever places the product on the market reports the quantities and pays a fee per product; the scheme finances collection, sorting and recycling. What distinguishes textiles is that fees vary with product characteristics through eco-modulation. For the general mechanism see extended producer responsibility and the DPP.

Three schemes, three stages

The table shows two things. France's fifteen-plus years of modulation experience serve as the model for the EU scheme, while the Netherlands manages through targets more than fees. The EU scheme will take elements from both, but national schemes will keep differing in tariff and scope for some time.

What changes for a non-EU exporter

The obligation sits with the "placer on the market": the EU importer, brand or first seller. If you sell from Türkiye as a contract manufacturer or under your own brand, registration and the fee are usually borne by your EU customer, but three things come back to you:

1. Cost pass-through: the fee becomes a per-product line in the price negotiation.
2. Data demand: the data that proves the modulation criteria (composition, durability, recycled content) is requested from you.
3. Direct sales: if you sell to EU consumers through your own e-commerce, you may be the obligated party; scheme registration and a representative are needed. See economic operators and their responsibilities.

Eco-modulation and the passport

Modulation asks: how many wash cycles does the product withstand, what is the recycled-fibre share, is it a single fibre or a blend, are there separable trims? Each of these is a passport field. The scheme wants evidence behind the declaration: a test report, a certificate, a transaction document. The passport holds that evidence field by field and versions it; when the EPR declaration and the passport are fed from the same source, you do not run two separate exercises.

• For durability evidence see textile durability tests and DPP data.
• For recycled content see proving recycled fibre: GRS, RCS and the DPP and how to prove recycled content.

The link to separate collection and the destruction ban

EPR does not arrive alone. Since 1 January 2025 Member States must collect textile waste separately; the scheme finances that collection, and the sorter needs the composition data in the passport. See separate textile waste collection and the DPP. The ban on destroying unsold goods pushes surplus stock towards resale and donation rather than destruction; EPR reporting and the destruction disclosure draw on the same quantity data. See the destruction ban.

What to do

1. Establish in writing with your importer which schemes apply in the EU markets you sell into and who the obligated party is.
2. Add the fields that correspond to modulation criteria (composition, durability, recycled content) to the product master record.
3. Keep the evidence (test reports, transaction certificates, product certificates) per product and batch.
4. Produce the same data for the passport and the EPR declaration from one source.
5. If you sell into France, pass Refashion's modulation criteria to your design team; in the next collection the fee difference becomes a design decision.

For the wider framework see the textile DPP guide.

Frequently asked questions