Textile EPR: What Brands Will Pay

France collected EUR 162.7 million in textile EPR fees in 2025 on 3.6 billion items, an average of EUR 0.045 per item, and from 17 April 2028 every EU Member State must run a comparable scheme. Directive (EU) 2025/1892, the revised Waste Framework Directive, entered into force on 16 October 2025 and turns extended producer responsibility for clothing, footwear and household textiles from a French and Dutch peculiarity into a European obligation. The fee per garment is small. What makes textile EPR expensive is that it arrives through 27 national laws, each with its own register, its own producer responsibility organisation and its own rules for modulating the fee.

This article covers the economics and the mechanics rather than the background. The policy logic behind EPR and its place in the circular economy are explained in our article on circular economy in textiles, and the dates sit alongside every other EU textile rule in our textile regulation timeline. Here we look at what the directive actually says, what existing schemes charge, how eco-modulation converts product data into money, what the new Czech scheme will look like, and what a brand selling into several markets has to do before April 2028.

What does the revised Waste Framework Directive require for textiles?

The revised Waste Framework Directive requires every Member State to set up a mandatory extended producer responsibility scheme for textiles and footwear by 17 April 2028. Directive (EU) 2025/1892 of 10 September 2025 amends Directive 2008/98/EC and adds four new articles, 22a to 22d, dedicated to textiles. Member States must transpose it by 17 June 2027, and the Commission confirmed that they then have 30 months from entry into force to have schemes running.

Under the scheme, producers pay for the separate collection of used textiles, for sorting them for re-use and recycling, for awareness campaigns and for support to research on design and fibre-to-fibre recycling. Membership in a producer responsibility organisation (PRO) is mandatory, so a brand cannot simply self-comply by running its own take-back programme. Collected items are treated as waste from the moment of collection unless a trained operator assesses them as fit for re-use at that point.

The directive obliges producers to bear these costs from national transposition and no later than 17 April 2028, but each Member State sets its own rates, registration procedure and exact start date. Three details in the final text differ from what circulated during negotiations and still appears in many guides. First, micro-enterprises are not exempt, they are deferred to 17 April 2029. Second, the directive sets no binding re-use or recycling targets yet, and the Commission must only assess by 31 December 2029 whether to propose them. Third, there is no fixed percentage of fees earmarked for research or for social economy actors, although social enterprises gain a guaranteed right to collect and keep what they collect.

Key finding: 17 April 2028 is a deadline for Member States rather than one start date for brands, because France already charges fees while a state that misses transposition leaves brands with no scheme to join.

Who counts as a producer under textile EPR?

A producer is whoever first makes a textile product available on a given national market, regardless of the selling technique. Article 3 of the amended directive lists four cases. An EU company selling under its own name or trademark is a producer, as is a company that puts its own brand on products made by others. So is the first supplier who brings goods into a Member State from another Member State or from outside the EU. Finally, a distance seller who sells directly to consumers in a Member State from abroad counts as a producer there too.

The fourth case is the one most brands underestimate. A Czech e-shop that ships to customers in Germany, Austria and Slovakia is a producer in each of those three countries, not only at home. Distance sellers based in another Member State must appoint an authorised representative in each country where they sell, and Member States may require the same of sellers from outside the EU. In most markets the PRO itself can act as that representative.

Online marketplaces and fulfilment providers become enforcers. Before allowing a producer to sell, a platform must obtain its registration number and a self-certification of EPR compliance, and fulfilment service providers must verify the same and suspend service when the information is missing. In practice this means a brand without a valid registration in a given country will lose access to the large marketplaces there, which is a faster sanction than any administrative fine.

Two groups sit outside the producer definition. Sellers of used goods fit for re-use and of products made from them are excluded, which protects second-hand and upcycling businesses. Self-employed tailors who make customised products are excluded too.

Which products fall under textile EPR?

Textile EPR covers all clothing and clothing accessories, footwear, hats and most household textiles. Annex IVc of the directive defines scope by customs codes, which matters because it makes the classification objective. Part I covers CN chapters 61 and 62, which together contain all knitted and woven apparel and accessories, plus blankets, bed, table, toilet and kitchen linen, curtains, other furnishing articles, worn clothing and hats. Part II covers leather apparel and footwear under headings 6401 to 6405.

Mattresses are optional, so each Member State decides whether to include them. Professional textiles are in scope when they are similar in nature and composition to household textiles, so corporate workwear and hospitality linen generally fall under the scheme. The directive allows exclusions for professional and military products where hygiene, safety or security risks make standard collection inappropriate.

How much will textile EPR cost per garment?

Textile EPR fees are measured in cents per item, typically between EUR 0.02 and EUR 0.20 for a standard piece of clothing in the most mature scheme. France is the only market with a long fee history. Refashion's 2026 fee guide sets a fee per product line and segment, starting at EUR 0.0190 for gloves, hats and women's briefs and reaching EUR 0.1933 for a men's suit. A men's T-shirt costs EUR 0.0396, men's jeans EUR 0.1098, a women's coat EUR 0.1582 and men's sneakers EUR 0.1243.

The average tells the same story. According to Refashion's 2025 key figures, 3.6 billion items weighing 917,604 tonnes were placed on the French market and generated EUR 162.7 million in fees. That works out to EUR 0.045 per item, or roughly EUR 0.18 per kilogram. The Commission's own impact assessment estimated EU-wide costs at about 0.6% of product cost, or EUR 0.12 per T-shirt, which is higher than the French figure because it modelled full coverage of collection and sorting in countries that start with far less infrastructure.

Weight-based schemes produce comparable numbers. Hungary charges 164 forints per kilogram of textile product since 1 October 2025, according to KPMG, which is roughly EUR 0.40 per kilogram. In the Netherlands, the PRO ERP Nederland charges a 2026 service fee of EUR 0.24 per kilogram placed on the market in 2025.

These figures need one correction for consistency with what we wrote earlier. Our circular economy article illustrated eco-modulation with a garment paying EUR 0.50 in fees against one paying EUR 2.00. Those were illustrative values to show the margin logic, and the base fees actually charged today are an order of magnitude lower. The spread between a well-designed and a poorly designed product can still exceed EUR 1.50, but in France that spread now comes from the bonus and penalty system described below rather than from the base fee.

The per-item fee therefore stays small, so what does it add up to for a real brand? Take a company that sells 300,000 pieces a year in France, split between 200,000 men's T-shirts, 80,000 men's jeans and 20,000 women's coats. On the 2026 French grid it pays EUR 7,920 for the T-shirts, EUR 8,784 for the jeans and EUR 3,164 for the coats, a total of EUR 19,868 or EUR 0.066 per piece. Multiply that across six or eight markets with different grids and the fee becomes a five or six figure line item, but still not the largest cost of compliance.

Small sellers face a trap. French producers placing fewer than 5,000 pieces a year can use a simplified declaration with a flat rate of EUR 0.5799 per clothing item, which is more than ten times the standard fee for a T-shirt. The simplified route saves administration and costs money, so a small brand with a clean product list can be better off filing the full declaration.

Key finding: A brand selling 300,000 pieces in France pays about EUR 20,000 a year in base fees, while the administrative work of registering and reporting in each market usually costs more than the fee itself.

How does eco-modulation change the fee?

Eco-modulation adjusts the base fee up or down according to how durable, repairable and recyclable a product is. The directive anchors it in Article 22c(5). Fees are based on weight, and where appropriate on quantity, and they are modulated on the basis of the ecodesign requirements adopted under the ESPR regulation (Ecodesign for Sustainable Products Regulation) that are most relevant to waste prevention and treatment, or on other harmonised EU sustainability criteria.

The directive itself does not list durability, repairability or recycled content as fee criteria. Those criteria enter indirectly, through the ESPR textile delegated act, which will set exactly those ecodesign requirements. The Commission may also adopt implementing acts on fee modulation to keep national systems consistent, and the European Outdoor Group reports that this work will not conclude before the textile delegated act is finalised in 2027. Until then, each Member State modulates by its own criteria.

Member States may also go further against fast fashion. Article 22c(6) allows them to require modulation that addresses ultra-fast and fast-fashion practices, judged by product life span, use beyond the first owner and contribution to closing the loop. Recital 40 names the indicators, including the width of the product range, the frequency of new offers and incentives for repair such as the ratio of repair cost to product price.

France shows what eco-modulation looks like in practice. Refashion's 2026 eco-modulation guide pays a durability bonus of EUR 0.70 per piece for the first 100,000 qualifying pieces and EUR 0.07 above that, with higher rates for intimates, outerwear and bath linen. An environmental labelling bonus adds EUR 0.30 per piece on the same tiered basis, and recycled content earns EUR 1,000 per tonne for post-consumer textile feedstock. A durability bonus of EUR 0.70 is about 18 times the base fee for a men's T-shirt, which shows that in a mature scheme the modulation, not the base fee, drives the economics.

The penalty side grew sharply in 2026. French law no. 2026-602 of 8 July 2026 introduced a penalty per product for ultra-fast fashion that applies from 1 September 2026, ranging from EUR 0.25 to EUR 12 in 2026 and rising to EUR 2 to EUR 20 from 2030. On a reasoned request from the producer it is capped at 50% of the pre-tax price, and penalised products cannot receive any bonus. The same law bans advertising of ultra-fast-fashion products from 1 January 2027, including through influencers.

Key finding: In France a durable T-shirt can earn a bonus 18 times larger than its base fee, while an ultra-fast-fashion item can pay a penalty of up to EUR 12, so product data now decides the fee more than volume does.

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Eco-modulated fees start from fibre composition and weight, the same data a footprint calculation needs. Calculate your bestseller's footprint in our free calculator →

What can brands learn from France, the Netherlands and Hungary?

Existing schemes show that the fee is predictable while the obligations around it keep growing. Our regulation timeline gives the one-line status of each market, so this section focuses on what each one teaches.

France has run textile EPR since 1 January 2007, with the industry body Eco TLC founded at the end of 2008 and approved in 2009 before becoming Refashion. In 2025 the scheme collected 272,479 tonnes, or 3.96 kg per inhabitant, and sorted 216,264 tonnes. The lesson is that collection volumes stay far below what is placed on the market, at under a third of the 917,604 tonnes sold, and that the scheme responds by tightening modulation every year. France also runs a repair bonus that subsidised 628,268 repairs in 2025, mostly of shoes, through 1,586 labelled repairers.

The Netherlands started on 1 July 2023 and is the first scheme with binding targets on producers. According to the Dutch government business portal, 50% of textiles placed on the market had to be prepared for re-use or recycled in 2025, rising by five percentage points a year to 75% in 2030, with fibre-to-fibre recycling reaching 33% by 2030. Three PROs compete for producers, which keeps fees competitive but means a brand has to compare offers rather than accept a single tariff.

Hungary started on 1 July 2023 with a simple per-kilogram fee and no meaningful eco-modulation. It shows the other end of the spectrum, where the scheme behaves like a tax on weight and gives a brand no financial reason to invest in better design.

The countries now drafting their schemes are taking these models as templates. Germany published key points for a new textile law on 27 March 2026, Sweden opened consultation on its proposal on 25 September 2026 with responses due by 30 December 2026, and Italy's draft decree passed its intergovernmental conference in July 2026 with final approval expected by the end of 2026.

What will textile EPR look like in the Czech Republic?

Czechia has no law transposing textile EPR as of November 2026, so a Czech brand has no textile EPR obligation at home today and it is not yet known when it will. The only proposal that would have introduced it was amendment no. 1809 to bill no. 58, an amendment of Act No. 542/2020 Coll. on end-of-life products. The Chamber of Deputies rejected it on 14 October 2026 by 33 votes to 94, with both the environment committee and the minister recommending rejection, and passed the rest of the bill without textiles.

The Ministry of the Environment has its own concept, which it presented on 12 October 2026. It proposes a single mandatory collective system for the whole country, run as a joint-stock company and designated as a service of general economic interest. To obtain authorisation, the company would have to represent more than 50% by weight of textiles and more than 50% of footwear placed on the Czech market and cover 90% of municipalities and of the population with its collection network. The concept has not yet entered the legislative process, so the final model remains open.

The rest of the ministry's draft follows the directive. Fees would depend on product type, weight and eco-modulation, a public register of producers would be created, foreign producers would have to appoint an authorised representative and online platforms would have to verify seller registration. Collective compliance itself is not a Czech choice, since Article 22c(1) of the directive makes membership in a producer responsibility organisation mandatory everywhere.

The starting point is modest. The ministry's questions and answers from 23 March 2026 estimate Czech textile waste at 120,000 to 140,000 tonnes a year, while municipalities sorted about 23,000 tonnes in 2024 under the separate collection obligation that applies since 1 January 2025. Until an EPR scheme exists, the ministry supports collection with an operating subsidy of CZK 2 per kilogram from a CZK 80 million pool.

The transposition deadline of 17 June 2027 now looks very tight for Czechia, but the uncertainty at home does not delay obligations abroad. A Czech e-shop shipping to France or the Netherlands is a producer there today. The legislation overview on our website tracks the national status as it changes.

Key finding: Czechia has no textile EPR law after the Chamber rejected the only proposal on 14 October 2026, but Czech brands selling into France or the Netherlands are already producers in those markets.

Which product data determines your EPR fee?

Your EPR fee is determined by four groups of data, namely product classification, weight, material composition and durability evidence. Classification by customs code decides whether a product is in scope and which fee line applies. Weight drives the fee in every per-kilogram scheme and in the directive's default basis. Composition and durability evidence decide eco-modulation, which in mature schemes outweighs the base fee.

Most brands hold the first two in their ERP and the last two nowhere. Fibre composition sits on the care label but rarely in a structured field with percentages by weight. Durability test results sit in supplier PDFs, if they exist at all, and recycled content claims rest on transaction certificates that nobody has linked to individual products. This is the same data gap we described in our article on the data fields proposed for the textile DPP, and it is not a coincidence.

A brand that builds one structured product record serves both obligations. The environmental footprint calculation needs the same weight and composition data, and the durability evidence that earns a French bonus is the evidence the ESPR delegated act will ask for.

Key finding: Six of the seven data points that set an EPR fee are also Digital Product Passport fields, so collecting them once serves both obligations.

How do EPR fees relate to the Digital Product Passport?

EPR fees and the Digital Product Passport draw on the same product data but arrive on different dates. Every Member State must have a textile EPR scheme running by 17 April 2028. The ESPR regulation has applied since 18 July 2024, but for textiles the Commission is still preparing the delegated act. Its working plan COM(2025) 187 schedules adoption for 2027, and the obligation follows roughly 18 months later, indicatively in 2029, because Article 4(4) of ESPR prevents requirements from applying earlier than 18 months after the act enters into force except in duly justified cases. EPR fees will therefore reach most brands a year or more before the mandatory textile DPP.

Some of our earlier articles, and much of the industry, still date the mandatory textile DPP to 2028. That date assumed faster adoption of the delegated act than the working plan now indicates, and we will update the older texts. The practical consequence for this article is clear. EPR, not the DPP, is the first obligation that makes a brand pay for missing product data, because a product without durability or composition evidence cannot claim a bonus and may attract a penalty.

The link becomes formal once the delegated act exists. The directive ties eco-modulation to ESPR ecodesign requirements, so the attributes the textile DPP records will become the basis on which fees are modulated across the EU. A brand that structures its data now for EPR reporting is building the Digital Product Passport in advance, while a brand that waits for the DPP will meet EPR first with no data.

What does a brand selling in several EU markets have to do?

A brand selling in several EU markets has to register, join a PRO and report volumes separately in each one. There is no single EU registration, although the Commission must adopt a harmonised registration format by 17 April 2027, which will at least make national registers ask for the same fields.

The work falls into four tasks. The first is a market register that lists every country where you place products, the legal entity that counts as producer there and whether you need an authorised representative. The second is a product master with a CN code, net weight and fibre composition for every SKU, because every scheme reports in these units. The third is a reporting process that turns sales data into volumes per country, per product line and per weight, usually monthly or quarterly. The fourth is an evidence file per product for any bonus you want to claim, with test reports and certificates that a PRO can audit.

Distance sellers carry the heaviest load. A Czech e-shop delivering to customers in five Member States needs five registrations, five authorised representatives and five reporting streams, and the marketplaces it sells through will block listings without valid registration numbers. Using a PRO that offers representative services in several countries reduces the number of contracts, but not the reporting work.

What are the most common mistakes in preparing for textile EPR?

The most common mistake is treating EPR as a tax to be paid rather than a data obligation to be met. The fee is small, so finance teams budget it and move on, and nobody notices that the brand cannot report weights per SKU or prove a single bonus criterion.

The second mistake is assuming home-market registration is enough. Under the producer definition, a distance seller is a producer in every country it ships to, and marketplaces will enforce this before national authorities do.

The third mistake is estimating weight. Several schemes calculate the fee by kilogram, and reported weights can be audited. A brand that uses category averages instead of measured weights either overpays or exposes itself to corrections and penalties.

The fourth mistake is waiting for harmonised eco-modulation. EU-level modulation criteria will follow the ESPR textile delegated act, but France already modulates today and other schemes will set their own criteria in 2027 and 2028. Durability testing and supplier certificates take six to twelve months to collect, so a brand that waits for harmonisation will pay unmodulated or penalised fees for its first years.

The fifth mistake is ignoring the simplified declaration trap. Flat rates for small volumes, such as the French EUR 0.5799 per clothing item, can cost a small brand far more than a full declaration based on actual product lines.

FAQ

Is 17 April 2028 the date when brands start paying everywhere?

No. It is the date by which every Member State must have a working scheme, and the directive requires producers to pay no later than that, but the actual start in each country depends on its national law. France, the Netherlands, Hungary and Latvia already charge fees today, while countries that transpose late may start later, and enterprises with fewer than 10 employees and under EUR 2 million in turnover or balance sheet join on 17 April 2029.

Does a non-EU brand selling online pay textile EPR?

Yes. A distance seller supplying consumers directly in a Member State counts as a producer there, regardless of where it is established. Member States may require it to appoint an authorised representative, and online platforms must check its EPR registration before allowing sales.

Is footwear included in textile EPR?

Yes, footwear under customs headings 6401 to 6405 is mandatory in every scheme, alongside leather apparel. The ESPR working plan foresees only a study for footwear rather than ecodesign requirements, so footwear fees cannot yet be modulated on ESPR criteria and will depend on national rules.

Can a brand meet textile EPR with its own take-back programme?

No. The directive makes membership in a producer responsibility organisation mandatory, so a brand's own take-back or resale programme does not replace the scheme. It can still reduce the fee indirectly where a scheme rewards repair, re-use or recycled content.

Does a Czech brand have a textile EPR obligation today?

Not under Czech law. The only proposal that would have transposed textile EPR, an amendment to bill no. 58, was rejected by the Chamber of Deputies on 14 October 2026, and the Ministry of the Environment's own concept of a single collective system has not yet entered the legislative process. A Czech brand that sells into France or the Netherlands is already a producer there, regardless of the Czech situation.

Which data should a brand collect first for EPR?

Start with the customs code, measured net weight and fibre composition by weight for every SKU, because every scheme needs them for the basic declaration. Durability test reports and recycled content certificates come next, since they decide whether you can claim a bonus.

Three steps to get ready for textile EPR

1. Check the data behind your bestseller. Run it through our free footprint calculator, which works from the fibre composition and product data you have today. Every gap it reveals in composition or weight is also a gap in your future EPR declaration.

2. Connect EPR with your wider regulatory plan. EPR is one of several obligations that draw on the same product record, and our regulation timeline shows how it fits alongside the destruction ban, green claims rules and the DPP. Plan them as one data project rather than five compliance projects.

3. Build one market register before national registers open. List every country where you place products, the legal entity that counts as producer there and the volumes per product line, because each scheme will ask for exactly this. If you sell into several markets and want to go through your product data with us, get in touch.