Extended Producer Responsibility: a step forward towards a circular textiles system
© Oeko-Institut
Today, four EU Member-States (France, the Netherlands, Hungary, and Latvia) have a mandatory EPR policy for textiles, and the US State of California recently adopted a first-in-the-nation EPR law covering textiles. By the end of the decade, EPR schemes will likely be established and harmonised in practice across all 27 EU countries. Australia and Colombia are currently piloting EPR schemes for textiles on a voluntary basis, while Chile will see formal development of EPR legislation for textiles in the coming year. Finally, discussions on EPR policy design for textiles are happening from Ghana to the UK, from Canada to Kenya, and in many other places around the world.
The concept of EPR
EPR for textiles is rising on the policy agenda because it is a crucial policy tool to ensure discarded textiles are collected and put back in circulation at scale. EPR policy is a financing instrument, which places responsibility on producers with regard to the collection, sorting and recirculation of the products they place on the market. As such, mandatory EPR policy generates funding that is dedicated, ongoing, and sufficient to manage textile products when they are discarded. Without EPR policy, the collection, reuse, and recycling of textiles is unlikely to be meaningfully scaled and tens of millions of tonnes of textiles will continue to be landfilled, incinerated, or will leak into the environment every year. In a world of finite resources, EPR policy helps create new sectors and employment dedicated to reverse cycle activities, such as collection, sorting, reuse, repair, and recycling. As such, it can help shift the economic balance away from the production of new products and materials.
Action required across the globe
But to maximise this impact, it is important that (sub)national EPR systems seek exchange and alignment on the objectives they pursue. Achieving a widespread uptake of EPR policies, in an aligned manner across borders and jurisdictions, is crucial to build a global circular economy for textiles. Without a coordinated approach, national and subnational EPR policies risk fragmentation and ineffectiveness. Brands and retailers — the obligated producers under EPR schemes — have reach into consumer markets spanning multiple countries, while textile products flow across borders after use. Against this backdrop, a coordinated approach to EPR policy ensures aligned reporting, measurement across governments and the distribution of fees collected through EPR among countries and/or projects participating in the end-of-life management of textiles. Importantly, a common approach to EPR can ease reporting requirements for obligated producers, enhancing compliance and effectiveness of the system in place. This is particularly relevant for SMEs that lack the resources and capacity to navigate compliance across multiple markets.
What is the status of EPR for textiles in Germany?
Germany has not formally started to build an EPR scheme for textiles. Germany’s collection rate of textiles, at their end of use, is slightly higher compared to the EU average, but exact figures differ. Currently, collection and sorting is financed based on the export of garments for reuse. Due to obstacles such as the low quality of textiles or declining sales in receiving countries, collectors and sorters in Germany will sooner or later require financial contributions of those that are made responsible under EPR policy – brands and retailers. The German Federal Environment Agency recently brought forward options for an EPR scheme in Germany, while future obligated producers are preparing their vision of what such a future system could look like. However, it remains to be seen whether Germany will implement an EPR system for textiles before the deadline set by the EU Waste Framework Directive.
Germany looks back on a complicated track record when it comes to the modulation of fees within EPR. The German EPR system for packaging has been experiencing several difficulties on this front for some time now. One of the reasons for this is, is the fragmented landscape with multiple PRO’s - in competition amongst one another - that each design ecomodulated fees in a different manner. This leads to a system where ecodesign incentives lead to a reduction in revenues for the PRO, while the positive effects on recovery costs benefit all systems equally. If a system demands high surcharges for environmentally less advantageous packaging, there is a risk that customers will switch to a different, less stringent PRO. In Germany, it is important to learn from these experiences and ensure they inform the decision-making on the future EPR system for textiles.
Valérie Boiten is a senior policy officer at the Ellen MacArthur Foundation. The Ellen MacArthur Foundation develops and promotes the idea of a circular economy, inspiring and working with business, academia, policymakers, and institutions across the globe. In her work, Valérie is focused on the powerful role that public policies can play to accelerate the transition to a circular economy for fashion. Clara Löw is a senior researcher on Circular Economy and Global Value Chains in the Oeko-Institut’s Sustainable Products & Material Flows division in Freiburg. She is currently involved in the development of ecodesign requirements for textiles as well as in textile recycling projects. She also advises in the development of the German National Circular Economy Strategy.
Further Information
Presentation “Policy instruments to ensure reuse in the EU”
