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Extended Producer Responsibility (EPR) is one of the main compliance mechanisms used in Europe to finance the collection, sorting, recycling, and management of products and materials once they become waste.
While the principle is established at EU level, EPR obligations are often implemented through national schemes. Registration requirements, reporting obligations, and producer responsibilities can therefore differ between countries.
Recent developments, including the revision of the Waste Framework Directive, are extending Extended Producer Responsibility to textiles and footwear across the European Union.
This guide explains how EPR works, the latest developments at EU level, and how EPR relates to packaging, textiles, and Digital Product Passport preparation.
Extended Producer Responsibility is a policy approach established under the EU Waste Framework Directive.
Under EPR, producers may be required to assume financial or organisational responsibility for the management of products at the end of their life cycle.
Depending on the product category and market, this can include:
The exact obligations vary by product category and Member State.
The European Union is increasingly using EPR as a tool to support circular economy objectives and improve waste management performance across Member States.
One of the most significant recent developments is the revision of the Waste Framework Directive, which introduces mandatory Extended Producer Responsibility schemes for textiles and footwear across the European Union.
This means EPR is no longer limited to packaging, electronics, batteries, or other established categories. Textile products are now becoming part of the framework as well.
The latest changes to the Waste Framework Directive introduce several important milestones.
- 16 October 2025: Revised Waste Framework Directive enters into force
- 20 months after entry into force (June 2027): Member States must transpose the revised Directive into national law
- 30 months after entry into force (April 2028): Member States must establish EPR schemes for textiles and footwear
These deadlines, introduced by the Directive mark the beginning of a significant expansion of EPR obligations across the textile sector.
Although implementation differs between countries and product categories, most EPR schemes involve a similar set of obligations.
Obligation Examples
Registration Registration with national EPR schemes or producer responsibility organisations
Reporting Declaration of products placed on the market
Financial contributions Fees supporting collection and recycling systems
Documentation Maintaining supporting records and declarations
Ongoing updates Updating registrations and reporting information over time
The exact reporting requirements, fee structures, and compliance processes depend on the applicable scheme.
The introduction of mandatory textile EPR schemes across the EU represents one of the most significant recent developments for the fashion sector.
Under the revised Waste Framework Directive, producers placing textile and footwear products on the market will contribute to the costs associated with:
The Directive also introduces the concept of eco-modulated fees: producer contributions may vary depending on sustainability-related product characteristics, including criteria linked to durability, repairability, and recyclability.
For fashion brands, this creates a direct connection between product characteristics and future compliance costs.
EPR and the Packaging and Packaging Waste Regulation (PPWR) address different aspects of compliance.
The PPWR introduces requirements related to packaging design, recyclability, recycled content, labelling, and documentation.
EPR focuses on the responsibilities associated with products and packaging after they are placed on the market.
However, many of the information categories required under both frameworks overlap.
Examples include:
As a result, organisations increasingly need reliable packaging information that can support multiple regulatory obligations simultaneously.
For a detailed overview of PPWR obligations, registrations, and reporting requirements, see our dedicated PPWR guide.
The strongest connection between EPR and Digital Product Passports is not the regulatory framework itself, but the information needed to support compliance.
Across multiple EU initiatives, organisations are increasingly expected to maintain structured information about products, materials, composition, and lifecycle characteristics.
This trend becomes particularly relevant as EPR schemes begin incorporating eco-modulated fees linked to sustainability criteria such as durability, repairability, and recyclability.
Many of the product characteristics discussed in EPR policy developments are also becoming relevant within broader Digital Product Passport and ESPR discussions.
Although implementation details will continue to develop at national level, organisations can already begin preparing.
This includes:
Early preparation can help reduce future compliance complexity while providing greater visibility over existing obligations.
The revision of the Waste Framework Directive marks an important step in the expansion of Extended Producer Responsibility across Europe, particularly through the introduction of textile EPR requirements.
While implementation will continue at national level, organisations can already begin monitoring applicable EPR schemes, reporting obligations, and the information needed to support compliance activities across different markets.
Understanding these requirements early can help teams prepare for future obligations while building a clearer view of existing product and packaging compliance responsibilities.
Get in touch to discuss upcoming requirements and how they may affect your organisation.
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