In April 2026, HEJSupport submitted its comments on the German Federal Ministry for the Environment’s (BMUKN) draft framework for introducing Extended Producer Responsibility (EPR) for textiles.
We welcome the initiative as an important step toward addressing the environmental and social impacts of the textile sector. However, the current proposal risks falling short of its transformative potential.
EPR Must Go Beyond Waste
The draft places strong emphasis on collection, sorting, and recycling. While necessary, this approach focuses too narrowly on the end-of-life phase. The most significant environmental and health impacts of textiles occur earlier—through overproduction, the use of harmful chemicals, unsustainable design, and short product lifespans.
EPR should therefore be designed as a product policy instrument, not merely a waste management system. This includes binding targets for waste prevention, reuse, durability, and the reduction of hazardous chemicals.
Reuse and Global Responsibility
Reuse and the establishment of local, transparent reuse systems remain underdeveloped within the current framework. Without clear targets and financial support, reuse systems risk being sidelined by recycling and disposal structures. HEJSupport calls for ambitious reuse targets and investment in transparent, local reuse systems that avoid the export of low-quality textiles disguised as second-hand goods.
At the same time, the global dimension of textile production must be addressed. Environmental and health burdens are often externalized to production and importing countries. EPR must explicitly account for these impacts and avoid reinforcing existing inequalities.
Chemicals and Circularity
Textiles contain complex mixtures of chemicals that can hinder recycling, pose health risks, and spread throughout global value chains. A safe circular economy is not possible without addressing these substances.
HEJSupport emphasizes that:
- The topic of harmful chemicals must be systematically integrated into eco-modulation schemes
- Existing EU frameworks such as REACH Regulation and the future Digital Product Passport should be fully leveraged
- Substances of concern must be transparently tracked across the value chain
No Delay on Eco-modulation and Transparency
Eco-modulation—adjusting producer fees based on product sustainability—is central to EPR effectiveness. Delaying its implementation would significantly weaken the system. It must be mandatory from the outset, based on clear, harmonized criteria.
Equally important is transparency and traceability. Standardized, product-level data on materials, chemicals, repairability, and origin should be made available across value chains. The upcoming EU Digital Product Passport offers a key opportunity to enable this.
Enforcement Matters
Strong enforcement mechanisms are essential. Without effective monitoring, sanctions, and adequate resources, EPR risks being undermined by free riders and inconsistent implementation—particularly in online markets.
A Systemic Opportunity
The BMUKN proposal provides a crucial foundation. But to truly transform the textile sector, EPR must:
- Drive upstream changes in product design and chemical safety
- Prioritize reuse and waste prevention
- Ensure transparency and traceability, especially of harmful chemicals
- Address global impacts and justice
Handled correctly, EPR can become a cornerstone of a fair, circular, and non-toxic textile economy.
