Product Responsibility Models for Textiles

Clothing, shoes, and more – textiles that are part of our daily lives. However, as numerous studies and analyses show, textile consumption within the EU is considerable and has significant impacts on climate change as well as the use of important resources such as water and land. Additionally, so far, there has been no central legal framework for the collection, sorting, reusing, and recycling of old textiles in Europe and Germany. This is where product responsibility models for textiles come in – with the aim of holding textile product manufacturers accountable throughout the entire value chain.

In March 2022, the EPR ProTex was initiated. So far, the initiators have analyzed various product responsibility models for textiles. The German Federal Environment Agency has now published the 200-page final report of the EPR for textiles. The conclusion: The “Manufacturer-Led Model” is likely the best solution, followed by the “Competitive Systems.”

But what do the EPR models for textiles mean exactly for retailers? We have taken a closer look at this in this post.

As part of the EU Textile Strategy published in March 2022, manufacturers are required to take comprehensive responsibility for their products across the entire value chain. This strategy aims to harmonize extended producer responsibility (EPR) in the textile industry across the EU and to embed it in the revised Waste Framework Directive. This approach aims to increase sustainability in textile production and use. The research project on extended producer responsibility ProTex focuses on developing and evaluating specific product responsibility models for textiles for Germany. The introduction of EPR models for textiles aims to create a framework that obliges producers to improve their resource efficiency and reduce waste generation.

Why Product Responsibility Models for Textiles?

Before March 30, 2022, when the European Commission initiated drafting a sustainable and circular strategy for textiles, there was no standardized approach for handling old textiles in Germany or the EU.

Given that textile consumption in Germany reached around 1.56 million tons in 2018, with approximately 1.0 million tons of old textiles collected in containers, action was imperative. However, there’s significant untapped potential in collecting, recycling, and reusing these textiles, despite challenges in the current system’s financial sustainability and market dependence.

Various product responsibility models for textiles were developed and assessed, including defining “old textiles,” preparing regulations like the European Textile Labeling Regulation, and studying regulations from other countries like France and Sweden.

What is EPR after ProTex all about?

In 2022, the European Commission introduced the proposal for the Eco-design Regulation as part of the EU Textile Strategy, aiming to reduce textile consumption by promoting repair, reuse, and recycling of recyclable materials and goods, fostering a circular economy for textiles. With the EU Waste Framework Directive (EU COM 2018/851), separate collection of waste, including old textiles, becomes obligatory from 2025 onwards, with German law implementing this obligation as early as October 2020, overseen by public-law waste disposal companies.

In July 2023, the European Commission’s revised draft marked progress in extended producer responsibility (EPR) for textiles, focusing on holding manufacturers accountable for implementing separate collection obligations and promoting a circular economy.

Who does the extended producer responsibility ProTex concern?

The extended producer responsibility ProTex applies to all manufacturers and businesses responsible for textiles. This includes those who also handle EPR for packaging, batteries, and electrical equipment.

Within the guidelines and product responsibility models for textiles, the requirements of EPR are defined, mandating manufacturers to fulfill responsibilities directly or through system participation. This includes the collection, sorting, preparation, reuse, and recycling of old textiles.

What EPR models are conceivable for EPR textiles according to the final report?

After considering all factors, experts from the Federal Environment Agency developed several feasible product responsibility models for textiles in Germany. These include the Fund, Manufacturer-Borne, Competition Systems, and Contract Models.

The final report on EPR textiles suggests that the Manufacturer-Borne Model and, alternatively, the Competition Systems Model would be viable solutions.

The “Manufacturer-Borne Model”

In this model, manufacturers shoulder both the organizational and financial responsibilities to meet legal requirements. They can fulfill these obligations through direct retrieval of their textile products or participation in a collective, nonprofit retrieval system. A central register ensures comprehensive management and oversight, with all involved parties—including manufacturers, collectors, sorters, and recyclers—registered and required to submit necessary data and documentation.

For direct retrieval, manufacturers must adhere to specific requirements for collection, preparation for reuse, recycling, and documentation. If conducted through a collective system, the operator ensures compliance with necessary measures. This model also allows for a shared variant.

Competition Systems Model

The “Competition Systems” model for textile product responsibility aims to facilitate the establishment of multiple competitive retrieval systems. Manufacturers are required to participate with corresponding quantities in one or more systems to meet legal obligations. Direct retrieval by producers is limited due to competition among operators, with exceptions possible with central register approval, responsible for data consolidation and monitoring.

This model also offers shared responsibility, where public waste disposal entities primarily handle collection, shifting to manufacturer responsibility post-initial collection. However, clear legal delineation is needed for organizational and financial responsibilities regarding collection. Financing could stem from textile sales or system operator contributions.

Additionally, commercial and nonprofit collections remain feasible, requiring coordination with waste disposal entities.

Reliable Support for Textile Product Responsibility

Our textile product responsibility support offers insight into implementing EPR for textiles in Germany, guiding towards a sustainable textile industry. As an obligated manufacturer, proactive engagement with upcoming EPR ProTex guidelines is crucial, but you’re not alone in this endeavor.

At Deutsche Recycling GmbH, we provide comprehensive assistance, from compliance checks to implementing EPR measures, tailored to your needs. Whether it’s the Manufacturer-Borne Model or Competition Systems, we help you navigate textile product responsibility models, allowing you to focus on your core business and future success.