FAQ EPR Textiles

FAQs

General questions about EPR Textiles

You can find answers to the most frequently asked questions in our General Questions section.

Can’t find your question?

Feel free to contact us at netherlands@erp-recycling.org.

We are European Recycling Platform (ERP) Netherlands, a government recognised producer responsibility organisation. This means we support companies in complying with their legal obligations under EPR for textiles.

As a producer responsibility organisation, we take care of the compliance process on behalf of our members. Our services include:

  • Registration with the appropriate authorities
  • Preparing and submitting reports
  • Organising collection and recycling

Instead of each producer managing these tasks individually, we handle them on behalf of all our affiliated members. This approach is efficient, clear, and removes the administrative burden. By working with us, you can be confident that your company is fully compliant with the legislation.

Want to know more about us? Visit our ”About Us”.

EPR stands for Extended Producer Responsibility. It is an environmental policy approach whereby producers are made responsible for the entire lifecycle of the products they place on the market, including the post-consumer waste phase. This includes both financial and organisational obligations related to the collection, recycling, and proper disposal of those products once they become waste.

The Dutch government aims to achieve a fully circular textile industry by 2050. At present, around 50% of textiles are still discarded as non-recyclable waste. To change this, new regulations have been introduced to promote reuse and recycling.

As a result, Extended Producer Responsibility (EPR) for Textiles came into effect on 1 July 2023. This legislation requires companies that place textiles on the market to contribute to collection, reuse, and recycling efforts. Producers are also expected to adopt more sustainable production practices and increase the use of recycled materials.

The regulations apply to producers who place new clothing and household textiles on the Dutch market. This includes manufacturers, importers, and foreign suppliers. It does not matter how or to whom the textiles are initially sold — whether to a retailer, business, or consumer. Examples of relevant products include clothing, bed linen, table linen, and towels.

On our ‘Become a Member’ page, you can easily complete the membership form.

After registering, you will receive:

  • A membership guide
  • An agreement outlining all terms and conditions

If you agree, simply sign the agreement and we will take care of the rest. This way, we handle all your legal EPR obligations on your behalf.

A textile product includes all materials composed entirely of textile fibres. This may range from raw to finished products, including semi-processed and manufactured items, regardless of the blending or assembly techniques used.

What is a textile fibre?

A textile fibre is defined as:

  • A flexible, fine element with a high length-to-diameter ratio, suitable for textile applications;
  • A narrow strip or tube (maximum width of 5 mm), including strips produced from wider materials or film, made from raw materials listed in Annex I, Table 2 of Regulation (EU) No 1007/2011, and intended for use in textile products.

These definitions are set out in Regulation (EU) No 1007/2011 of 27 September 2011, on textile fibre names, labelling, and marking of textile products.

EPR for Textiles applies to producers who place specific textile products on the market, namely:

Clothing

  • Consumer clothing (Customs codes 61 and 62)
  • Workwear (Customs codes 61 and 62)

Household textiles

  • Bed linen (Customs code 6302)
  • Table linen (Customs code 6302)
  • Other household linen, such as towels and tea towels (Customs code 6302)

Only new products are included — second-hand items are excluded. The choice of material, whether virgin or recycled textile fibres, does not affect inclusion.

Only textile products with the listed customs codes, as defined in Section XI of Part II of Annex I to Regulation (EEC) No 2658/87, fall within the scope of EPR for Textiles. Products with other codes are excluded.

A potential future expansion of EPR for Textiles is under consideration, for example to include footwear.

EPR for Textiles applies only to producers who place new clothing (both consumer and workwear) and new household textiles (such as bed linen, table linen, and other household linen) on the market.

The sale of second-hand clothing or household textiles does not fall under EPR obligations.

The following textile products are not within the scope of EPR for Textiles:

  • Bags and belts (Customs code 42)
  • Footwear (Customs code 64)
  • Headwear (Customs code 65)
  • Blankets (Customs code 6301)
  • Curtains, net curtains, and blinds (Customs code 6303)
  • Bedspreads (Customs code 6304)
  • Sacks and bags (Customs code 6305)
  • Covers, tarpaulins, and tents (Customs code 6306)
  • Mops, dishcloths, cleaning cloths, and dusters (Customs code 6307)

And other similar products (this list is non-exhaustive)

The customs codes (shown in brackets) refer to Section XI of Part II of Annex I of Regulation (EEC) No 2658/87.

  • One-time registration: Between 1 July and 12 August 2023, producers must register and declare the amount of textiles they expect to place on the market in the coming year.

  • Collection system: Producers are required to establish an accessible system for the free collection of discarded textile products.
  • Use of recycled fibres: Producers must incorporate a higher proportion of recycled textile fibres into their products.
  • Reuse and recycling targets: From 2025 onwards, annual minimum targets for reuse and recycling will apply. For example, by 2025, 50% of textiles must be reused or recycled; this target will rise to 75% by 2030.
  • Annual reporting: Each year, producers must submit a report outlining how they have met their obligations and stating the volume of textiles they have sold.

Are you subject to EPR for Textiles? If so, you are required to submit an annual report on the textile products you have placed on the market.

Are you affiliated with our producer responsibility organisation? Then you need not worry — we take care of the entire reporting process on your behalf.

As the legal targets do not come into force until 2025, the reporting requirements for 2024 and 2025 (covering 2023 and 2024 respectively) are limited. During these years, reporting is restricted to the type and quantity of textiles placed on the market.

Foreign suppliers who sell directly to Dutch consumers (for example, via webshops) are required to appoint a representative in the Netherlands. This representative is responsible for handling tasks such as registration and compliance with waste management obligations.

The Human Environment and Transport Inspectorate (ILT) is responsible for enforcing the EPR Textiles Decree and the accompanying regulations, including the reporting obligation and, from 2025, the minimum targets.

Companies that fail to register, do not submit required data, or do not comply with the legal requirements risk enforcement action and fines.

Sellers of second-hand clothing or household textiles are not subject to any obligations. EPR obligations apply only to producers who are the first to place newly manufactured clothing and household textiles on the Dutch market. Second-hand textiles have already been placed on the market one or more times.

The introduction of EPR for Textiles therefore has no direct impact on the sale of second-hand clothing via shops or online platforms.

The reason for this is that the sale of second-hand clothing and household textiles actively contributes to the reuse of these products — a key objective of EPR for Textiles. Requiring second-hand retailers to bear the costs of collection and recycling would be counterproductive to that goal.

The question is whether retailers who sell new clothing or household textiles to end users, such as consumers, should be considered “producers”. The answer to this depends on the specific situation.

A retailer may be classified as a producer if they are the first to place the textile product on the Dutch market. This would be the case, for example, if the retailer imports trousers or bed sheets from abroad. In such instances, the retailer acts as an importer.

Conversely, a retailer is not considered a producer if they purchase trousers or bed sheets from a wholesaler based in the Netherlands. In that case, it is the wholesaler who first places the textile on the Dutch market and, in principle, has already fulfilled the EPR for Textiles obligations. The retailer is then offering the product as a second or third party and is not subject to EPR requirements.

As purchasing routes may vary by product, it is possible that a retailer may be subject to EPR obligations for some products but not for others.

Click & Comply is an online service by ERP Netherlands that allows companies to easily register and automatically comply with their EPR obligations. This webshop has been specifically developed for businesses that place less than 10,000 kg of textile products on the market each year. ERP Netherlands manages the entire compliance process — from registration to reporting — so you can be fully relieved of administrative burdens.

https://nl.click-and-comply.com/

The EU Batteries Directive compels battery producers to pay for the collection and recycling of depleted batteries.

Compliance schemes are organisations that producers use to manage recycling obligations. All schemes are registered and controlled by the relevant authorities.

The term “Battery Producer” extends beyond battery manufacturers to any company imports batteries or products that contain batteries. Retailers that import their own brand batteries or batteries within products are also classified as battery producers.

In Spain all battery producers need to comply with the regulation, regardless the amount of batteries they put on the market. Becoming a member of a compliance scheme is the alternative the vast majority of producers use to comply with this regulation.

Battery compliance schemes make arrangements to collect batteries from collection points such as local authority sites, shops, offices and schools, often using existing collection rounds where possible to minimise costs and carbon emissions.

If batteries are discarded with household waste, the cost of collection and disposal is borne by local authorities. Landfill is an increasingly expensive method of disposal, as landfill sites become full and landfill taxes increase. Recycling will shift the cost of disposal to battery producers. Producers have an obligation to collect and treat batteries in proportion to the amount they sell each year. The legislation has set increasing targets until 2021, when 50% of batteries must be recycled.

Local authorities collect waste batteries at their recycling centres and other municipal facilities. Battery compliance schemes then collect from these sites for free and sort and treat the batteries. There will be no cost to local authorities and no effect on council taxes, as battery producers will be paying for this service.

Consumers can take their waste batteries to any collection point, such as local authority recycling centres or shops that sell batteries. Moreover, workplaces, libraries and schools will also collect waste batteries.

Distributors have to accept the return of spent portable batteries and accumulators at no cost for the holders or end users of such, and they cannot require them to purchase new portable batteries or accumulators.

Battery recycling is good for the environment. Some batteries contain toxic metals (such as nickel, cadmium or mercury) that cause pollution if they end up in landfills or incinerators. Recycling batteries also means that the valuable metals can be re-used and saves energy by reducing the need for raw materials.

Yes. All types of batteries can be recycled, both disposable and rechargeable. The only batteries that are exempt from this Directive are those used in equipment related to national security interests, arms, munitions and war material.

There are approximately 43,500 AA alkaline batteries to one tonne.

It was the first Directive that addressed a series of measures which main target was to limit the generation of packaging waste and promote recycling, reuse and other ways of valorization for these waste; considering elimination as the less valuable and last alternative.

  • Collect and separate household waste.
  • Deposit used batteries in appropriate containers.
  • Take old household appliances to civic amenity sites or retailers when buying a new one equivalent.
  • Acquire new eco-friendly products.

  • Respect the “producer responsibility principle”.
  • Factor recycling into total product cost.
  • Declare quantities of produced/imported items.
  • Meet all legal obligations through compliance schemes such as ERP.

  • Select products from reliable importers and producers and who can provide their registration number.
  • Provide or support collection points for WEEE and Batteries.
  • Raise awareness about recycling.

  • Promote recycling of local household waste.
  • Provide collection points for WEEE and Batteries.
  • Cooperate with schemes to manage waste through appropriate channels.
  • Raise awareness about recycling.

  • Manage compliance obligations and declarations for producers.
  • Organise collection and treatment of waste.
  • Separate waste for treatment and re-use.
  • Optimize the recycling/waste cycle.
  • Organize recycling days and other events to raise awareness about recycling.
  • Inform Autonomous Communities of the waste management results each year.