Introducing EPR for Textiles in the UK

Summary

EPR for Textiles: The circular economy for textiles is coming. Early action delivers better outcomes. Make sure you're ready.

Buttoning up your EU and UK textiles EPR capabilities

With the European Union pushing forward ambitious new textile waste rules, the fashion sector is on the cusp of a transformative shake-up. In October 2025, the EU's revised Waste Framework Directive entered into force, making textiles Extended Producer Responsibility (tEPR) mandatory across all EU member states. For UK clothing producers (manufacturers, importers, retailers, including online sellers) selling into European markets, this creates immediate compliance obligations that cannot be ignored.

But what about the UK domestic market? While formal legislation hasn't yet landed, the direction of travel is unmistakable. Industry bodies, compliance specialists and government publications all point to the same conclusion: UK textiles EPR is coming, and clothing producers should prepare now, rather than sit and wait for final regulations.

Where the UK stands today on tEPR

UK governments have been exploring extending EPR to new waste streams, including textiles. Some related consultations have taken place. The Circular Economy Taskforce had textiles as one of its themes, and we expect a Circular Economy Growth Strategy

Early in 2026 – setting a timetable for the development and implementation of key policy initiatives such as tEPR. However, unlike the EU's finalised directive, the UK has not yet started legislative steps towards a textiles EPR scheme.

This doesn't mean inaction is an option. The EU directive has created a two-track reality for UK retailers. Those selling into European markets must immediately prepare for EU compliance, with member states required to transpose rules into national law by June 2027 and operate fully functional schemes by April 2028. Meanwhile, domestic UK operations face an increasingly likely tEPR requirement within the next five years or so.

The practical implication? UK clothing producers need to build capabilities that work across both regulatory regimes. Waiting for final UK legislation means playing catch-up when obligations arrive, facing compressed implementation timelines and potentially higher costs.

Learning from European research and implementation

The average capture rate for textile waste in Europe is only 12%, meaning 88% ends up in mixed municipal waste, to be landfilled or incinerated. This is stated in the European Environment Agency’s report, Textile waste management in Europe’s circular economy[2] (2024). The aim of textiles EPR is to vastly cut down such waste, by incentivising more efficient production in the first place, and encouraging reuse, resale and recycling, post-retail.

Under a textiles EPR system, producers are required to pay fees based on the volume and environmental impact of the products they place on the market, and these fees are then used to fund the separate collection, sorting, reuse and recycling of textile waste. It has been estimated that a comprehensive EU-wide EPR system could generate €3.5 to €4.5 billion annually for collection and recycling efforts, according to OECD analysis.

The OECD has also emphasised that EPR needs to be complemented by additional policy measures, including:

• EU-wide harmonised definitions of what constitutes clothing waste, recycled content and suitability for reuse;
• Tax incentives for used clothing;
• Stricter product design rules; and
• Targeted funding for recycling innovation.

Progress is already being made towards the textiles EPR goal. The Netherlands and France offer valuable insights into how textiles EPR works in practice. Both countries have moved beyond policy discussion to operational implementation, revealing the real-world requirements that UK producers should anticipate.

In Italy and the Netherlands, our parent organisation, the Landbell Group has been operating textiles compliance schemes that demonstrate the scale of change required.

In the Republic of Ireland, the government has been considering the first steps towards designing a national Textiles Extended Producer Responsibility scheme, and looking at three core design principles: First, leveraging existing EPR systems to reduce administrative burden. Second, prioritizing prevention and reuse over recycling in line with the waste hierarchy. Third, recognising and supporting the role of the existing used textiles sector.

The reverse supply chain revolution

Traditional retail supply chains move in one direction: from manufacturer to distribution centre, to store, to customer. Textiles EPR flips this model, requiring everyone in the chain to think about what happens after purchase.

Collections need to be convenient for customers – this should embrace existing networks such as textiles banks and charity shops – but might also include kerbside collections and in-store take back. The goal is straightforward: fewer textiles to landfill or incineration, more directed toward reuse and recycling.

But collection is only part of the story. Collected textiles are currently sorted and sold for reuse or recycling – with unsuitable items destined for disposal through energy from waste.

With traditional markets under pressure due to the changing nature of collected textiles and volumes needing to increase to make any significant impact on the issue there will need to be significant investment in new types of sorting facilities as well as reprocessing and manufacturing sites capable of turning today’s used textiles into tomorrow’s garments or other products.

Many commentators see the real transformation happening in data and tracking capabilities. Digital product identifiers in garments, including RFID tags and QR codes, could move from supply chain efficiency tools to reverse supply chain necessities.

The Landbell Group's textiles expertise demonstrates how this reverse supply chain operates at scale. Their infrastructure across multiple European markets shows that whilst the logistics are complex, they're entirely manageable with proper planning and the right partnerships.

The textiles EPR compliance landscape ahead

Exact timelines remain uncertain, but the broad shape of a UK textiles EPR is emerging. Manufacturers, importers and retailers will need to register as obligated producers, report sales data by material type and volume, contribute financially to collection and recycling infrastructure and potentially meet labelling and consumer information requirements.

Fee structures will likely follow the EU model of modulated charges, where environmentally preferable products attract lower costs. This creates direct financial incentives for sustainable design, while funding the infrastructure needed to collect and process textile waste at scale.

The scope of obligations will be defined in final regulations, but expect broad coverage of apparel and footwear. Thresholds may exempt very small producers, but any retailer with significant textile sales should assume they'll be obligated.

Penalties for non-compliance typically include financial sanctions, back-dated fees and reputational damage. Businesses that prepare thoroughly will avoid these risks whilst potentially benefiting from first-mover advantages in circular business models.

Why early action matters

Treating textiles EPR as inevitable, rather than speculative, changes the strategic calculus. The capabilities required for compliance - detailed product data, reverse logistics, digital tracking, circular design - also enable new business models around rental, resale, repair and remanufacturing.

UK producers building these capabilities now gain operational advantages beyond regulatory compliance. Better product data improves inventory management and reduces waste. Take-back programmes create customer touchpoints and loyalty opportunities. Circular design reduces material costs and appeals to environmentally conscious consumers.

Inaction while waiting for final legislation means compressed timelines, higher implementation costs and missed opportunities to influence how schemes operate. Early engagement with compliance providers, industry bodies and government will help shape the practical reality of how EPR works, ensuring producers’ voices inform workable solutions.

How ERP UK can help

ERP UK brings deep expertise in Extended Producer Responsibility across multiple waste streams, backed by the Landbell Group's proven textiles network across European markets. This combination of UK expertise and international connectivity positions us to support companies with both EU and UK compliance requirements.

Whether you're facing immediate EU obligations or planning for future UK requirements, we provide updates on legislative developments, international insights, warnings about deadlines and bespoke support tailored to your business needs.

Ready to prepare for textiles EPR?

Contact ERP UK's expert team to discuss your readiness assessment and compliance strategy.

Related services

EPR for Textiles - visit our webpage here

Extended Producer Responsibility - visit the webpage here

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