Textile EPR draft expected before year-end following policy proposal

On 27 March, the Federal Environment Ministry (BMUKN) released a policy framework paper (“Eckpunktepapier”) setting out the Ministry’s proposed approach for implementing an EPR-based textiles waste management regime in Germany and invited stakeholder comments by 24 April. The paper is not draft legislation and its provisions remain proposals.

The policy paper proposes a regime covering clothing, clothing accessories, household textiles and footwear, mirroring the product scope of Directive 2025/1892.

The framework defines a producer as any undertaking that first offers textiles on the German market (manufacturer, importer or distributor), while obligating foreign entities to appoint an Authorised Representative (AR) and requiring online marketplaces and fulfilment service providers to verify producer registration.

It also requires producers to register and participate in an authorised PRO and envisages multiple competing PROs, which would:

• require approval and meet requirements relating to nationwide coverage and financial capacity/financial guarantees
• be held responsible for nationwide collection and reimburse collectors for collection activities, with collecting parties able to choose the PRO in which they participate
• be required to achieve a 70% collection target (calculated against the weight placed on the market in the previous year), a 95% recovery target for collected waste textiles and an 85% target for preparation for reuse and recycling combined

Germany does not currently operate a statutory textile EPR-based waste management regime and collection is carried out through municipal, charitable and commercial collection systems without a dedicated producer-financed EPR framework.

The forthcoming draft Textiles Act is expected in summer 2026. Germany must transpose the textile EPR requirements of Directive (EU) 2025/1892 by 17 June 2027 and establish its textile EPR regime by 17 April 2028.

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