European Recycling Platform (ERP) UK recently appointed textiles sustainability specialist Kavita Sarin Dass as Business Development Manager.
ERP UK helps businesses meet producer responsibility obligations. The decision to appoint a dedicated textiles position could signal that extended producer responsibilities for textiles in the UK could soon be an operational reality.
The legislative picture: UK and EU directives
Textiles EPR is not yet UK statutory law. However, under Schedule 4 and Schedule 5 of the UK Environment Act 2021, the Government has the power to introduce extended producer responsibility schemes through secondary legislation without needing a new Act of Parliament.
UK regulation rarely strays too far from European Law to avoid hindering cross border trade. The revised EU Waste Framework Directive (Directive 2008/98/EC) requires mandatory EPR schemes for textiles across all member states by June 2027. Based on the EU directive and the recent textiles ERP appointment, changes are probable.
Retailers who managed the rollout of packaging EPR experienced first-hand the speed at which policy signals become bottom-line impacting regulation. Manufacturers and retailers should have this on their agenda in anticipation of any upcoming changes.
France’s eco-contribution, not tax
To understand how a UK scheme may operate, retailers can look to France. France established mandatory producer responsibility for textiles under Article L541-10-3 of the French Environmental Code (Code de l'environnement).
The French model covers clothing, household linen and footwear. It relies on an eco-contribution paid by producers to an accredited body to fund garment collection, sorting, and recycling. The system is not a flat tax. It uses eco-modulation to adjust fees based on product design and environmental performance:
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Lower fees apply to garments built for durability and long wear.
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Discounts are awarded for textiles manufactured with certified recyclable materials.
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Financial penalties apply to items designed with mixed fibers that make recycling difficult.
Other European countries, such as the Netherlands, Hungary, and Latvia, run simplified schemes for textiles using a flat rate fee based on product weights. However, the EU will mandate eco-modulation in April 2028 meaning these schemes will need to be updated to reward sustainability and penalise difficult to recycle and short-life textiles.
A UK scheme would inevitably look at similar schemes run by our European counterparts and could end up following this structure. This would mean a focus on rewarding brands and manufacturers using recycled and recyclable materials, and designing products for longevity and end-of-life recovery.
How retailers should prepare
Waiting for Defra’s implementation before taking action could leave businesses with a short window to manage complex changes.
Retailers, brand owners and manufacturers can prepare for legislation changes by asking questions about the current state of operations and the supply chain. What products contain difficult to recycle or mixed fabric textiles? Do you have full traceability of materials from suppliers? Do you currently provide any product end-of-life services?
Designing sustainability into the manufacturing and lifecycle of materials is key.
ERP UK's decision to hire dedicated textile expertise confirms that market preparation has started. Companies who map their product, manufacturing, and supplier data now, will be best placed to protect their margins when mandatory fee structures arrive.
