EU textile EPR: what should UK firms with sites in Europe know?

What did the European Parliament vote on?

Under EU EPR rules, producers that place products on an EU market have to help pay for collecting, sorting and recycling them once they become waste. A producer selling into another EU country where it is not established also has to appoint an authorised representative in that country to handle its EPR duties there.

In December 2025 the European Commission proposed suspending that authorised representative requirement until 1 January 2035 for batteries, packaging, textiles, footwear, electrical and electronic equipment and some single-use plastics. The Parliament's Environment Committee backed a narrower version on 5 October, and the full Parliament confirmed it in Strasbourg on 20 October.

The textiles, footwear, electronics and single-use plastics position passed by 612 votes to 8, with 39 abstentions. Under it:

• the suspension would apply only to micro and small producers established in the EU, meaning fewer than 50 staff and turnover or balance sheet under 10 million euros
• companies established outside the EU would still have to appoint representatives
• the suspension would end on 1 January 2035, or earlier if new EU circular economy rules take over
• producers would still have their other EPR duties, including paying towards collection and recycling

The vote sets Parliament's position for negotiations with EU governments. It does not change the law on its own.

Where do things stand now?

The two sides are some way apart. Recycling Europe, the EU recycling industry body, said on 27 October that the Council's position covers packaging only, for producers placing under one tonne a year in a member state, while Parliament's covers more product types but only small firms. Recycling Europe wants the requirement kept for everyone. According to the textile trade site TEXtalks, a Council position on the textiles side was still outstanding as of 23 October.

None of this moves the main dates. The revised EU Waste Framework Directive entered into force on 16 October 2025. EU countries must write it into national law by 17 June 2027 and have textile and footwear EPR schemes in place by 17 April 2028.

Does EU textile EPR apply to your old uniforms?

For most businesses, no. EPR under the directive falls on producers that make textile and footwear products available on an EU market for the first time, such as brands, manufacturers and importers. A logistics firm, hotel group or security company that buys uniforms for its own staff and later retires them is a user of those products, not the producer selling them.

That does not make old workwear risk free. Logo'd jackets, hi-vis and security uniforms can be used to impersonate your staff, which is why we covered why old branded uniforms should not go in textile banks. That risk is the same at a depot in Lille as at one in Leeds.

Countries will set their own national rules when they write the directive into law, so check local requirements for each site you run. We do not set out French or Belgian rules here.

What this means for your business

1. Work out if you are a producer. If your group also sells branded clothing or footwear into EU markets, for example merchandise, talk to your compliance adviser about EPR. If you only buy uniforms for staff, EPR is unlikely to be your duty.
2. List your workwear by site. Note where branded uniforms, PPE and hi-vis are used and stored, in the UK and abroad.
3. Use one secure route. Avoid each site doing its own thing with skips, textile banks or charity bags. Choose one secure process and record each disposal.
4. Plan for EU sites. Collections are only part of the picture if you have sites outside the UK, so agree how those items will be sent securely.
5. Watch the dates. Keep 17 June 2027 and 17 April 2028 in your diary, and check back once the EU negotiations finish.

Frequently asked questions