EU Finalises New Waste Rules: Textile EPR Obligations and the Next ESG Compliance Frontier

The European Union (“EU”) is accelerating its circular economy agenda with sweeping new waste legislation focused on reducing waste and shifting responsibility to producers. In September 2025, the European Parliament gave final approval to updates of the Waste Framework Directive that introduce mandatory Extended Producer Responsibility (“EPR”) for textiles and set binding food waste reduction targets. These measures form part of a broader regulatory push to make producers financially and operationally responsible for the end-of-life impact of their products, a trend that also bears significant implications for non-EU producers including those based in Türkiye.

Extended Producer Responsibility for Textiles

Under the revised Waste Framework Directive, textile producers will, for the first time at EU level, be required to fund and manage the recycling of textile waste. All companies that make textiles available on the EU market must cover the costs of collecting, sorting, and recycling post-consumer textiles through EPR schemes to be established in every Member State. Notably, this obligation applies equally to producers outside the EU who sell into the EU, ensuring no regulatory loopholes for imports.

ems, footwear, hats, accessories, as well as home textiles like blankets, bed linen, kitchen linens, and curtains. Member States may even choose to extend their schemes to additional categories such as mattresses, reflecting a comprehensive approach to textile waste.

In practice, textile producers will fulfil their obligations by joining or funding Producer Responsibility Organizations (“PROs”); collective schemes that manage waste collection and recycling on behalf of producers. The Commission’s proposal and Parliament’s text emphasize that financial contributions will be “eco-modulated” based on the product’s environmental performance. In other words, producers will pay more for products that are harder to recycle or have a bigger environmental footprint, and less for more sustainable designs. This eco-modulation creates financial incentives to design textiles that are more durable, reusable, and recyclable from the start. This mechanism is especially relevant for Türkiye’s textile sector, which has an opportunity to differentiate itself through design innovation and greener product lines. Additionally, Member States are urged to address fast fashion practices when setting EPR fee structures. Shifting the costs of waste management away from taxpayers and municipalities and onto producers, thereby encouraging producers to reduce waste at the source, which aligns with the polluter-pays principle.

While this EU-wide textile EPR mandate is new, several Member States have already taken early steps, offering precedents and lessons. France pioneered a textile EPR program back in 2007, requiring fashion companies to finance collection and recycling of clothing, linens, and shoes. The Netherlands introduced EPR for textiles in July 2023, obliging producers to register and arrange take-back systems, and setting concrete targets. Other countries like Sweden, Latvia, Hungary, Belgium, Spain, and Italy have launched or are developing national textile EPR measures in anticipation of the EU directive. This patchwork of early national schemes will soon be harmonized under the EU directive, creating a level playing field. Companies already complying in these frontrunner countries have a head start.

Binding Food Waste Reduction Targets

The new Waste Framework Directive also introduces the EU’s first binding food waste reduction targets. By 2030, Member States must cut per-capita food waste by 30% in retail, restaurants, and households, and by 10% in food processing and manufacturing, compared to 2021–2023 levels. These targets, enforced at national level, will require food businesses to step up efforts to measure, prevent, and redistribute food waste, with a particular emphasis on facilitating donation of edible surplus. While the targets are less ambitious than the United Nations’ Global Goals of 50% reduction, they provide clear legal obligations and a sense of urgency. Food sector companies should now review their supply chains for waste “hotspots” and invest in prevention measures such as improved inventory management, portion control, partnerships with food banks, and packaging innovations to meet the 2030 benchmarks.

Other Developments in EU Circular Economy Policy

Recent EU circular economy policies, including new rules on textiles and food waste, are part of a broader push under the EU Green Deal to reshape business obligations around waste and sustainability. A key example includes the Packaging and Packaging Waste Regulation, which introduces stricter lifecycle rules, recycling targets, and modulated producer fees, mostly effective from August 2026. Turkish companies exporting goods with packaging should prepare for integrated ESG compliance strategies covering both product and packaging lifecycles. The above-mentioned measures reinforce the EU’s goal of designing waste out of the system, signalling a cohesive movement towards sustainable product design, material circularity, and transparent waste management for all sectors.

Implications for Businesses and Next Steps

• Determine if you qualify as a “producer” under the new EPR rules. To clarify once more: this includes also non-EU and e-commerce operators.
• Identify affected product lines and prepare for differentiated national schemes.
• Allocate EPR-related liabilities clearly in distribution and e-commerce agreements.
• Track how Member States implement rules, especially variations in fee structures and scope.
• Use EPR reporting for the Corporate Sustainability Reporting Directive (“CSRD”) and position compliance as a competitive advantage.

Conclusion: Turkish Stakeholders should Prepare for a New Compliance Reality in Circularity

The finalisation of the revised Waste Framework Directive marks a decisive shift in EU environmental compliance. For the first time, producers will bear direct and enforceable responsibility for textile waste management across the entire EU market. In practice, this means not only aligning product design with eco-modulated EPR fees but also reassessing contractual structures in distribution and e-commerce chains.

For Turkish companies this legislative shift carries direct consequences. With Türkiye ranking among the EU’s top textile trade partners, the new EPR obligations will not only reshape cost structures but also require proactive engagement with EU-based PROs and careful contract allocation of liabilities in supply chains. Local exporters, manufacturers, and online retailers must closely monitor how each Member State transposes these rules, as divergent national approaches may impact market access and cost competitiveness.

Companies should treat this development not as a siloed environmental obligation, but as part of a converging compliance landscape; textile EPR schemes will directly inform reporting under the Corporate Sustainability Reporting Directive (“CSRD”) and may feed into risk disclosures under the Corporate Sustainability Due Diligence Directive (“CSDDD”). Embedding circularity strategies today is therefore not just about regulatory alignment, it is a forward-looking opportunity to position compliance as value creation.

To sum up, textile EPR is no longer an isolated initiative. It is the next ESG compliance frontier, and early strategic integration by Turkish stakeholders will distinguish leaders from laggards as circular economy enforcement becomes mainstream across the EU.

For further information on these developments and their implications for your business, please contact your CMS sustainability and regulatory law expert or your local CMS advisor: Dr. Döne Yalçın.