Textile EPR: What Is In Scope, When, and What It Costs
Your French entity already pays Refashion. Your Dutch importer pays a different scheme on a different basis. Hungary bills by the kilo. Spain bills nothing at all. And someone in finance has just asked what the other Member States will charge from 2027.
That question now has a floor under it. The EU amended its waste law in September 2025. Textile EPR is now compulsory in every Member State. The minimum scope is written in customs codes. The scope still varies by market. The fees vary far more.
At a glance:
- Directive (EU) 2025/1892 entered into force on 16 October 2025. Every Member State must have textile EPR rules in force by 17 June 2027.
- The schemes themselves must be established by 17 April 2028, under Article 22a(14). They are compulsory, not conditional.
- Annex IVc sets the minimum scope by CN code: chapters 61 and 62, household textiles, headgear, leather apparel 4203, footwear 6401 to 6405, and worn clothing 6309.
- National scope still differs. France excludes professional-use items. The Netherlands covers consumer and occupational textiles but leaves footwear out.
- Refashion's published 2025 scale runs from about €0.0173 to €0.1977 per item. Latvia charges €0.13 per kilo inside a scheme. Harmonised eco-modulation criteria do not exist yet.
What textile EPR is, and what the EU set in 2025
Textile EPR is the rule that makes one party pay for the waste. That party is whoever puts the goods on a national market first. The goods are clothing, household textiles and footwear. The bill covers collecting, sorting and treating them. It starts once they are thrown out. You register. You report what you placed there. Then you pay per item or per kilo.
The EU does not charge that fee. Duties arise under each Member State's own law. In 2025 the EU made those laws mandatory.
Directive (EU) 2025/1892 is the amendment that does it. The EU adopted it on 10 September 2025. The Official Journal published it on 26 September 2025. Under its Article 3 it entered into force twenty days later. That was 16 October 2025. It amends Directive 2008/98/EC on waste. So the operative text now sits inside that older law. Article 2 sets the transposition clock:
"Member States shall bring into force the laws, regulations and administrative provisions necessary to comply with this Directive by 17 June 2027 at the latest".
The scheme deadline sits in a separate rule. New Article 22a(14) says Member States "shall ensure that the extended producer responsibility schemes laid down in paragraph 1 of this Article are established by 17 April 2028". A scheme is compulsory in every market. The line usually quoted for that date is "at the latest, from 17 April 2028". That line is Article 22a(11)(b). It does something narrower. It scopes which products fall into the cost base.
Small firms get a delay. Article 41 now applies Articles 22a to 22d from 17 April 2029 to the smallest firms. Those are enterprises employing fewer than 10 persons. Their annual turnover and annual balance sheet do not exceed EUR 2 million.
June 2027 is when legal has 27 national texts to read. April 2028 is when finance starts paying in markets with no scheme today. The mechanics are in what EPR is. The sign-up side is in EPR registration.
The Annex IVc scope, read as CN codes
Annex IVc is the list of products every national scheme must cover at minimum. It is written in Combined Nomenclature codes, in two Parts. Member States may extend it. They may not shrink it.
Both Parts carry a qualifier the summaries usually drop. They cover products "for household use or other uses, where such products are similar in nature and composition to those for household use". Part II adds a second filter. It is for products "whose main composition is not textile".
| CN code | What it covers, in the Annex IVc wording |
|---|---|
| 61 | Articles of apparel and clothing accessories, knitted or crocheted |
| 62 | Articles of apparel and clothing accessories, not knitted or crocheted |
| 6301 | Blankets and travelling rugs (except 6301 10 00) |
| 6302 | Bed linen, table linen, toilet linen and kitchen linen |
| 6303 | Curtains, interior blinds, curtain or bed valances |
| 6304 | Other furnishing articles, excluding those of heading 9404 |
| 6309 | Worn clothing and other worn articles |
| 6504, 6505 | Hats and other headgear |
| 4203 | Apparel and accessories of leather or composition leather (excl. footwear and headgear and parts thereof, and goods of chapter 95) |
| 6401 to 6405 | Footwear, all five headings |
Read the exclusions. Heading 9404 is what keeps mattresses and duvets outside the floor. It keeps quilts and filled pillows out too. Chapter 95 keeps sports goods out of 4203. That covers goods such as shin guards and fencing masks.
Home textiles are in. So a bedding or curtain range that never touched an apparel scheme now is. So is worn clothing under 6309. That code reaches resale and export flows long treated as outside EPR.
Recital 28 says how far "other uses" reaches. Professional uses are included unless dedicated separate collection is already required elsewhere. Products for professional use, including military use, that "can pose safety, health and hygiene risks or raise security concerns should be excluded".
So a national scheme that leaves professional items out is not automatically below the floor.
Scope follows the code, not the product name in your catalogue. Your item master may have no reliable code per line. Then classification is the first job. Start with how an HS code is built. The CN then extends it to eight digits.
National schemes are drawn very differently
The findings below come from the TRUSTex deliverables D4.1 (June 2025) and D4.5 (June 2026). Both are EU Horizon documents published at ecosystex.eu. Both carry the stamp "This draft deliverable has not yet been validated by the granting authorities". Treat them as research findings, not legal authority.
| Country | Status | In scope | Out of scope |
|---|---|---|---|
| France | Live since 2007 | New clothing textiles, household linen and footwear placed on the French market, sold or donated, new or upcycled, rental-scheme products, and clothing and accessories for animals | Clothing that is entirely leather or natural fur, second-hand items imported from foreign markets, upcycled products made entirely from previously marketed used textiles, professional-use items unless ultimately intended for consumer use |
| Netherlands | Live | Consumer and occupational clothing, household linen, curtains | Footwear and leather goods |
| Hungary | Live, widest live scope | Apparel, accessories, household linens, curtains, rugs, footwear, carpets | |
| Latvia | Live | Clothing, hats, household textiles, second-hand and worn clothing, leather shoes with rubber soles | |
| Italy | Draft regulation, opinion given 23 July 2026 | Clothing, footwear, accessories, leather goods, home textiles, mattresses | |
| Spain | No EPR scheme | Voluntary consortia only | |
| Belgium | No textile EPR yet |
France and the Netherlands are near mirror images. France takes footwear and leaves professional garments out. The Netherlands does the reverse. So the same range can be in scope in one market and out in the next.
Other states may borrow the French logic. Professional and post-industrial textiles are, in the research's words, "easier to valorise due to known inputs and well-identified markets, hence are excluded from the EPR scope since EPR systems focus on sectors with valorisation challenges".
Italy repays a closer look. Leather apparel and home textiles already sit inside Annex IVc. So drafting them adds nothing. Mattresses are the real addition. Article 22a(2) leaves a mattress scheme to each Member State's discretion. Nothing is in force there yet. Italy's environment ministry records only a favourable opinion on the draft regulation, dated 23 July 2026.
What textile EPR actually costs
An eco-contribution is the fee a producer pays a scheme, per item or per kilo placed on the market. France publishes its scale in full. Most other markets publish far less.
| Country | Basis | Published rate | Year |
|---|---|---|---|
| France | Per item | €0.0173 to €0.1977 across the standard scale | 2025 |
| Netherlands | Per kilo | €0.20 then €0.24 at one of three PROs, each setting its own rate | 2025 |
| Latvia | Per kilo | €0.13 inside a scheme, €0.50 outside one | As reported |
| Hungary | Per kilo | HUF 145, flat | As reported |
Refashion's 2025 standard scale includes the repair and reuse funds. It runs from €0.0173 for women's underwear and stockings to €0.1977 for blankets. Clothing tops out lower, at €0.1757 for a men's two or three piece suit. A women's T-shirt is €0.0294. Men's denim trousers are €0.0998. No garment line reaches €0.20.
A French national authority quoted in the research calls the current level "considered too low to cover costs. Expected to rise gradually to meet 2028 targets". That is an anonymous remark in an unvalidated draft, not a tariff. Plan for the direction it points, not for the figure.
The Dutch number needs the same care. One Dutch PRO set a 2025 service fee of €0.20 per kilogram on 2024 volumes. It charged nothing from 1 January to 1 July 2025. After that it moved to €0.24 per kilogram on 2025 volumes. Three PROs operate there. Each one sets its own fee. So there is no single national rate. Latvia's €0.50 per kilogram is the Natural Resources Tax. It is due when a producer does not join a licensed scheme. Join one and the rate is €0.13 per kilogram.
Why eco-modulation is mostly not live yet
Eco-modulation is the practice of varying a producer's fee with how the product is designed. Durable, repairable, recyclable items pay less. The rest pay more. So far it mostly has not started.
The Netherlands records eco-modulated fees as "not yet in place". Hungary charges a flat rate per kilo. Latvia has effectively no modulation either. The detailed criteria that do exist sit in drafts, or outside the EU.
Italy's draft covers durability, reparability and reusability. It also covers recyclability and recycled content. It adds a malus for hazardous substances. California's SB 707 leaves the criteria to each scheme's approved plan. Fees there are expected to reward mono-material construction. They are also expected to reward the absence of substances such as PFAS. They are also expected to penalise complex blends.
Article 22c(5)(a) ties fee modulation to the ecodesign requirements adopted under the ESPR. None have been adopted for textiles. Article 22c(7) then leaves the modulation criteria themselves to future Commission implementing acts. Until both land, every national scheme is improvising.
The same research quotes people in the trade. They say why the fees are not biting on the ground. These are views, not findings.
- A Dutch producer responsibility organisation: "Fee discounts need to be substantial to justify R&D investment. A 1% reduction is insufficient to change producer behaviour" (D4.1, 2025).
- A Dutch consultant, on the arithmetic at the other end: "If 80% of products meet eco-standards, the remaining 20% will bear unsustainable fees" (D4.1, 2025).
- The same consultant, on the missing plumbing: "Eco-modulation sounds great but needs Digital Product Passports to work".
- A recycler in the DACH region, on the Dutch level of about €0.20 per kilo: it "is inadequate to cover sorting and recycling costs, which are labour-intensive and require preprocessing".
- An industry network, on France: the scheme is "Still evolving, with annual rule changes". Separately, on the EU picture: "Current fragmented national criteria make alignment challenging for companies".
One complete chain from product design to fee does exist. France's Arrêté du 23 novembre 2022 sets durability criteria per textile product type. It also sets the tests that prove them. And it sets the fee those results feed. That is the shape the rest will take. First a measurable attribute, then a named test, then a tariff line. It is also why one set of data does double duty. A textile Digital Product Passport will ask for largely the same fields.
Where Bindu fits. Bindu holds one record per product, carrying the CN code, the material composition and the durability evidence. The same data answers a scheme registration, a fee declaration and a passport page. When a new scheme opens, you filter the catalogue by code. See how the textile passport record works.
FAQ
When does textile EPR start in the EU? Directive (EU) 2025/1892 entered into force on 16 October 2025. Member States must bring textile EPR laws into force by 17 June 2027. Article 22a(14) requires the schemes to exist by 17 April 2028. They are compulsory, not conditional. France and Hungary already charge today.
Source: EUR-Lex: Directive (EU) 2025/1892
Which products are in textile EPR scope? Annex IVc sets the EU minimum by CN code. It covers household use or other uses similar in nature and composition. Part I covers chapters 61 and 62. It covers blankets under 6301 except 6301 10 00, plus linen and curtains under 6302 and 6303. It also covers other furnishing articles under 6304, excluding heading 9404. Worn articles under 6309 are in, and so is headgear under 6504 and 6505. Part II covers leather apparel under 4203 and footwear from 6401 to 6405.
Source: EUR-Lex: Directive (EU) 2025/1892
Is second-hand clothing covered by textile EPR? Worn clothing and other worn articles, CN 6309, are inside the EU minimum. So every scheme must cover them. Treatment already differs. Latvia's live scheme includes second-hand and worn clothing. France excludes second-hand items imported from foreign markets.
Source: EUR-Lex: Directive (EU) 2025/1892
How much does textile EPR cost per item? In France, Refashion's 2025 standard scale runs from €0.0173 to €0.1977 per item. Clothing there tops out at €0.1757. Latvia charges €0.13 per kilogram inside a licensed scheme. Outside a licensed scheme the Latvian rate is €0.50 per kilogram. Hungary charges a flat HUF 145 per kilogram. Dutch fees are set per PRO. One of them moved from €0.20 to €0.24.
Source: Refashion: 2025 eco-fee guide
Do textile EPR fees already reward better product design? Mostly not. Harmonised EU criteria do not exist yet. Article 22c(5)(a) ties modulation to ecodesign requirements not yet adopted for textiles. Article 22c(7) leaves the criteria to Commission implementing acts. The Netherlands records eco-modulated fees as not yet in place. France is the exception. It links durability test results to its fees.