The extended producer responsibility system for textiles should become a tool for transforming the market, not another source of fiscal revenue. Its purpose should be to encourage better product design, support reuse, finance collection and sorting infrastructure, and shift costs from municipalities to producers in a transparent way. The key principle is clear: EPR must not be treated as a tax-like mechanism, but as an instrument that genuinely changes how the textile sector operates. It should follow the waste hierarchy by reducing the problem at its source, especially at the product design stage, and by rewarding durability rather than merely financing waste management.
A well-designed EPR system should be based on the real involvement of businesses and the operation of multiple producer responsibility organizations. Fees paid under the system should have an investment character and be transparently reinvested in collection, sorting, reuse and recycling infrastructure. Eco-modulation should genuinely reward products that are durable, repairable and recyclable. The system should also introduce measurable targets for reuse, because recycling alone will not be enough to reduce the environmental impact of textiles.
EPR should support the textile industry
The textile industry is already facing major structural challenges, including the growing share of low-quality products and insufficient investment in infrastructure. In such conditions, a poorly designed EPR system could simply create additional burdens for companies without providing real support for market development. It is also important for the system to recognize all stages of the product life cycle, rather than being optimized only for recycling. Reuse should be treated as a key element of the model, because it often brings greater environmental benefits than recycling.
“The textile industry is already struggling with a growing share of low-quality products and underinvested infrastructure. In such conditions, a badly designed EPR system will only generate additional burdens without truly supporting infrastructure development. It is also necessary to take into account all stages of the life cycle, so that the system does not optimize itself solely for recycling, but also supports reuse, which delivers stronger environmental effects,” said Piotr Mazurek, an expert at Konfederacja Lewiatan.
Lewiatan supports a competitive model in which several producer responsibility organizations operate in parallel, under strong state supervision. Such an approach, unlike centralized models, can encourage cost efficiency and innovation while reducing the risk of market monopolization. Competition between organizations may also make the system more responsive to the real needs of producers, collectors, sorters and reuse operators. At the same time, effective public oversight would be necessary to ensure transparency and prevent the system from becoming fragmented or inefficient.
Effective textile EPR is an investment, not a cost
A key condition for the success of textile EPR is that funds collected under the system must support real operations. This means financing collection, transport, sorting and preparation for reuse, rather than disappearing into the general public finance system. The system should also make use of existing collection channels, including social economy entities that already play an important role in textile reuse. Simplicity and harmonization at EU level will also be important, including by defining the scope of the system on the basis of CN codes.
A properly designed EPR system could help the textile sector move toward a more circular and resilient model. It could support innovation, increase access to secondary raw materials and reduce long-term costs for municipalities, businesses and consumers. However, this will only happen if the system is designed as an investment mechanism, not as another administrative charge. The goal should be to build infrastructure, improve product quality and create incentives for a market in which textiles remain in use for longer.
“Effective EPR for textiles is not a cost, but an investment in the transformation of the industry, the development of innovation, greater raw material independence and lower costs in the long term,” Mazurek added.
