Six leading associations from Germany’s fashion, textile, footwear, and retail sectors have launched a joint initiative to shape a future Extended Producer Responsibility (EPR) system for textiles.
The associations issued a declaration of intent and position paper, committing to sustainability and shared responsibility in developing an effective EPR framework. They emphasize that the upcoming EPR introduction will transform the textile and fashion industry across Germany and Europe in the coming years.
Participating associations include:
- German Retail Association (HDE)
- German Textile and Fashion Industry Association (textil+mode)
- BTE Federal Association of the German Textile, Shoe and Leather Goods Retailers
- Federal Association of the German Sporting Goods Industry (BSI)
- German Fashion Association Germany
- Federal Association of E-Commerce and Versandhandel Deutschland e.V. (bevh)
Six Core Demands for the EPR Model
The position paper outlines six key requirements:
- Organised and transparent system
- Clear legislative framework
- Market surveillance and enforcement
- Environmental goals with eco-modulation
- Consumer information and awareness campaigns
- Robust collection and recycling infrastructure
As required by the EU Waste Framework Directive, Germany must establish a system by 2028 that combines ecological effectiveness, resource conservation, and practical take-back structures while maintaining market competitiveness.
Responsibilities for Manufacturers
Under the future framework, manufacturers introducing textiles into the EU market will finance collection, sorting, and recycling, while also reporting precise quantities.
The associations call for a system that is private-sector led, competitive, low-bureaucracy, and environmentally effective.
Strong Market Surveillance and Fair Enforcement
The paper highlights the importance of consistent enforcement, particularly against third-country imports. Online platforms and foreign retailers must also face sanctions to ensure fair competition.
Additional requirements include:
- Collection quotas
- Eco-design standards
- Europe-wide eco-modulation system
- Transparent allocation of license fees
Building a Sustainable Infrastructure
The group stresses that a functioning EPR system requires a long-term, economically viable infrastructure at both national and European levels. Existing structures should be preserved and improved where they are ecologically and financially sound.
In the next step, the associations propose including waste management and recycling stakeholders to merge divergent positions into a common, workable solution.
