BRUSSELS – Two major pieces of EU legislation are moving into implementation at the same time, and textiles sit at their intersection.
Member States must transpose the revised Waste Framework Directive, which requires textile Extended Producer Responsibility (EPR) schemes to be established by April 2028. Meanwhile, the European Commission is developing textile-specific rules under the Ecodesign for Sustainable Products Regulation (ESPR), including requirements for a Digital Product Passport (DPP).
The two frameworks are designed to work together. Under the Waste Framework Directive, producer contributions are based on product weight and, where appropriate, quantity – the number of products placed on the market. These contributions finance collection, sorting, reuse, recycling and other end-of-life responsibilities. Fees must then be eco-modulated using relevant sustainability and circularity criteria developed under ESPR or other harmonised EU rules.
This is an important step. But there is still a missing piece: evidence of what happens to garments in real life.
Ecodesign rules are necessarily set before a product is sold. They therefore use tests, product characteristics and assumptions to predict durability, recyclability and likely lifetime. Yet technically durable clothing is not always worn for a long time. Fit, care, fashion cycles, price, resale and many other factors influence when a garment leaves use. Prediction is necessary, but it should not be mistaken for proof.
A practical feedback loop
IWTO proposes adding the year of production to the textile Digital Product Passport. Combined with statistically robust waste audits, this would allow authorities to see how quickly – or slowly – different categories of garments enter collection and waste streams.
A production date would not reveal every wear, and waste audits would need safeguards for representative sampling, exports and products still in use. But over time, they could provide independent evidence of age at discard, reuse potential, recycling routes and treatment costs.
That evidence could complement ESPR’s forward-looking criteria when EPR fees are reviewed. Producers whose garments consistently appear in waste streams unusually quickly, or create higher end-of-life costs, should face higher eco-modulated contributions. Products associated with longer service and verified reuse or recycling outcomes should be recognised accordingly. Recyclability and biological end-of-life performance should count where they are verified and consistent with the waste hierarchy, rather than claimed as theoretical possibilities.
This is how the polluter-pays principle can become more than an assumption: link responsibility to measured outcomes.
With Member States designing their EPR schemes and the textile ESPR Delegated Act now being developed, the opportunity is immediate. Put the year of production in the Digital Product Passport, build credible waste audits into national systems, and let real evidence help shape future fees.
About IWTO
The International Wool Textile Organisation represents the interests of the global wool trade. IWTO is a founding member of the Make The Label Count (MTLC) campaign, an international coalition of natural fibre organisations working to ensure that natural fibres receive fair treatment in EU sustainability policy. MTLC is actively engaging in the EPR legislative process. Reach out to us to get involved.
This proposal draws on research and method development by Consumption Research Norway (SIFO) and its partners. The Research Briefing on Clothing Consumption explains why technical durability alone cannot predict actual use; Used, But Not Used Up sets out how waste audits could inform EPR and other textile policies; and Waste Audit Interviews describes a method for connecting garment characteristics with observed lifespans.
