Textile EPR in the EU: who is the producer, which products, and when

If you sell clothing, footwear or household textiles by distance contract to buyers in an EU country and your business is outside that country, you are the producer there. You register in that country’s scheme, join its producer responsibility organisation, and pay a fee based on the weight and, where appropriate, the quantity of the products.

What you do:

1. Find the CN code of each product and match it to the Annex IVc table below. Clothing and clothing accessories (chapters 61 and 62), home linen, curtains, hats, leather clothing and footwear are in. Handbags and carpets are not.
2. Mark each EU country where you sell directly to end users. There you are the producer if you are established in another EU country or in a third country (Art. 3(4b)(d)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (d)Click opens the article on EUR-Lex.). A business that imports your goods and resells them in that country is the producer for those goods instead (Art. 3(4b)(c)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (c)Click opens the article on EUR-Lex.).
3. Check whether that country’s scheme runs. France, the Netherlands and Hungary run one now (table below). Every other country must establish its scheme by 17 April 2028 (Art. 22a(14)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 14Click opens the article on EUR-Lex.).
4. Where the scheme runs, register as a producer in that country before your first sale (Art. 22b(2)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22b, paragraph 2Click opens the article on EUR-Lex., Art. 22b(3)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22b, paragraph 3Click opens the article on EUR-Lex.).
5. Join a producer responsibility organisation. For textiles it is compulsory (Art. 22c(1)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22c, paragraph 1Click opens the article on EUR-Lex.).
6. Appoint an authorised representative in that country if you are established in another EU country. From a third country, the country decides whether it requires one (Art. 22a(3)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 3Click opens the article on EUR-Lex.). France does (France section below).
7. Give each marketplace and fulfilment service provider your registration number and your self-certification for that country (Art. 22a(13)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 13Click opens the article on EUR-Lex., Art. 22a(15)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 15Click opens the article on EUR-Lex.).

Leave it, and a country with a scheme may only allow you to make the products available when you or your representative are registered (Art. 22b(3)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22b, paragraph 3Click opens the article on EUR-Lex.). A marketplace within Section 4 of Chapter III of the Digital Services Act must obtain your registration number before it lets you sell (Art. 22a(13)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 13Click opens the article on EUR-Lex.). A fulfilment service provider that has reason to believe your details are wrong must ask you to correct them, and suspend its service for these products if you do not (Art. 22a(16)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 16Click opens the article on EUR-Lex.). In France, Refashion states a fine of up to EUR 7,500 per product unit (below).

Who counts as the producer

The Directive defines the producer by where you are established and how you sell, “irrespective of the selling technique used, including by means of distance contracts” (Art. 3(4b)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4bClick opens the article on EUR-Lex.). Four cases make you the producer:

• (a) You are established in an EU country and make the products under your own name or trademark there, or have them designed or made and supply them there for the first time under your own name or trademark (Art. 3(4b)(a)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (a)Click opens the article on EUR-Lex.).
• (b) You are established in an EU country and resell there, under your own name or trademark, products made by others on which the maker’s name, brand or trademark does not appear (Art. 3(4b)(b)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (b)Click opens the article on EUR-Lex.).
• (c) You are established in an EU country and supply there, for the first time and on a professional basis, products from another EU country or from a third country (Art. 3(4b)(c)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (c)Click opens the article on EUR-Lex.).
• (d) You sell the products by distance contract directly to end users in an EU country, “whether or not they are private households”, and you are established in another EU country or in a third country (Art. 3(4b)(d)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 3, paragraph 4b, point (d)Click opens the article on EUR-Lex.).

Case (d) is the one for a seller outside the EU. A seller in the UK, the US or China is established in a third country. You are the producer in each EU country where your buyers are, and the buyer may be a household or a business that uses the products. A business that buys to resell is not an end user: it falls under case (c).

The products Annex IVc covers

Annex IVc lists the products by CN code. It covers textile products and apparel “for household use or other uses, where such products are similar in nature and composition to those for household use”. Find your CN code and compare it with the table.

The table follows Annex IVc of Directive (EU) 2025/1892Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)The whole regulationClick opens the law on the EU Publications Office., Parts I and II. A product whose CN code is not in the Annex is outside the Directive’s scheme. The Directive also lets an EU country set up an EPR scheme for mattresses (Art. 22a(2)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 2Click opens the article on EUR-Lex.). An EU country may go further than the Directive in its own law, and Hungary’s list does: see the national section below.

The dates, from entry into force in 2025 to micro-enterprises in 2029

The Directive was published in the Official Journal on 26 September 2025 and entered into force on the twentieth day after publication (Article 3Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)The whole regulationClick opens the law on the EU Publications Office. of Directive (EU) 2025/1892Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)The whole regulationClick opens the law on the EU Publications Office.), which is 16 October 2025. The Directive itself uses that date in Art. 22a(10)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 10Click opens the article on EUR-Lex.. The date for the schemes, 17 April 2028, is about 30 months later. The text names the date, not the months.

A country may start before 17 April 2028, and three already have. Where a scheme was already established on 16 October 2025, its producers cover the collection and treatment costs for products first made available from that date (Art. 22a(10)Directive 2008/98/EC on waste, as amended by Directive (EU) 2025/1892 (textiles and footwear)Article 22a, paragraph 10Click opens the article on EUR-Lex.).

The schemes already running

Three EU countries already run a textile EPR scheme in their own law. Their rules are their own: the product list, the register, the representative and the fee all differ.

France: Refashion and the IDU

France’s textile stream is called TLC: clothing (textiles d’habillement), household linen (linge de maison) and footwear (chaussures). Refashion, the stream’s eco-organisation, says EPR in the sector became a regulatory requirement on 1 January 2007 and that Refashion is the only approved eco-organisation for clothing, household linen and footwear (Refashion). The French administration lists the stream as “produits textiles d’habillement, les chaussures ou le linge de maison neufs destinés aux particuliers et produits textiles neufs pour la maison”; unofficial translation: new clothing, footwear and household linen for private individuals and new textile products for the home (Service Public Entreprendre).

Refashion describes a marketer as a company invoicing French VAT for the first time on a clothing, household linen or footwear product intended for end consumers, and says an online seller or marketplace is covered “even if based abroad, for your own sales and those of third-party sellers not registered with the system” (Refashion). The steps are: request registration on Refashion’s member extranet, sign the contract, declare the products placed on the market, pay the eco-fee on the invoice, and receive the IDU, which ADEME generates. The IDU proves you are registered, up to date with the fee and compliant. A company whose activity started before the year it registers must regularise the current year and up to four earlier years (Refashion).

A seller not established in France has one more step. Under the law of 8 July 2026, a person not established in France that is subject to EPR for these products “désigne, par mandat écrit, une personne physique ou morale établie en France en tant que mandataire”; unofficial translation: appoints, by written mandate, a person established in France as its representative to carry out its EPR duties. The representative takes over all the obligations of the mandate it accepts. The duty to appoint one is treated as met for products for which a marketplace established in France carries the EPR obligations (Article 5, new Article L541-10-9-1 of the Environment Code) (Loi n° 2026-602). What France sets for the fee, the ultra-fast-fashion penalty and the place of manufacture is on textile EPR in France.

The Netherlands: the textile decree of 2023

The Dutch rule is the Besluit uitgebreide producentenverantwoordelijkheid textiel, a decree of 14 April 2023 in force from 1 July 2023, with a ministerial regulation of 15 June 2023 under it. It defines the producer as “degene die beroepsmatig, ongeacht de gebruikte verkooptechniek, textielproducten in de handel brengt”; unofficial translation: whoever, in the course of a business and irrespective of the selling technique used, places textile products on the market. “In de handel brengen” is defined as making a product available on the market in the Netherlands for the first time (“op de markt aanbieden”: supplying a product for distribution, consumption or use in the course of a commercial activity, whether or not for payment) (Besluit, Art. 1).

The decree covers newly made clothing (consumer and business clothing of chapters 61 and 62 of the Combined Nomenclature) and household textiles (table, bed and household linen of heading 6302). Its Article 2(1) reads: “Een producent die niet in Nederland is gevestigd, wijst een in Nederland gevestigde rechtspersoon of natuurlijke persoon aan als gemachtigd vertegenwoordiger”; unofficial translation: a producer not established in the Netherlands appoints a legal or natural person established in the Netherlands as its authorised representative for carrying out the producer’s obligations.

Hungary: Government Decree 80/2023

Hungary’s textile products sit inside its general EPR decree, 80/2023 (III. 14.), in force from 1 April 2023 with most operating provisions from 1 July 2023 (§ 36). Producers meet their duties through a designated concession company, or individually under a contract with it (§ 3, § 8). The decree’s Annex 1, point 1.10, names the textile products by CN code, and Annex 2, point 10, sets the textile fee codes, which apply from 1 July 2023 (§ 37/C) (Decree 80/2023).

Selling into Hungary from abroad is covered twice. The fee duty arises when a product is first placed on the market, and that includes transferring it from abroad “as an electronic commerce service” to households or other users (§ 16(1), § 16(2)). And § 10(2) reads: “A külföldön letelepedett és belföldön elektronikus kereskedelmi szolgáltatásként körforgásos terméket forgalomba hozó gyártó az e rendeletben meghatározott kötelezettségeit meghatalmazott képviselő útján teljesíti”; unofficial translation: a producer established abroad that places a circular product on the domestic market as an electronic commerce service meets its obligations under this decree through an authorised representative. The representative is liable for the producer’s duties (§ 10(3)).

Spain: a law that orders a scheme

Spain’s Law 7/2022 does not set up a textile scheme itself. Its final provision 7(1) says that, within three years of the law entering into force, EPR regimes for textiles, furniture and household goods, and agricultural plastics other than packaging, are to be developed by regulation (BOE, Ley 7/2022). The law was published on 9 April 2022 and entered into force the next day, so the three years ran out on 10 April 2025. We found no textile EPR regulation published in the Official State Gazette (BOE) since. The producer duties would come from that regulation, not from the law, so there is no Spanish textile scheme to join yet.

Other EU countries may also run or plan schemes. The EU rule above applies in each of them from the date its national law sets, and the scheme is due by 17 April 2028. The by-country view of all EPR streams is on EPR.

What you can skip

A separate EU rule, not part of EPR, bars large businesses from destroying unsold clothing and footwear. It is on the ESPR ecodesign guide.