Extended Producer Responsibility for Textiles
What is Extended Producer Responsibility?
Extended Producer Responsibility (EPR) holds producers and importers accountable for the entire cycle of a product, up to and including the waste phase. By doing so, the government wants to encourage companies to raise an increasing percentage of waste for reuse and recycling and make it available as a new raw material. Other industries such as car tires, cars, mattresses, packaging and electrical appliances also work with EPR. Similar regulations are already in place in other EU countries and EPR legislation will be mandatory in the EU from 2025.
Individual obligations for producers and importers
The EPR for Textiles Decree is a legal obligation and entered into force on July 1 2023. With the Decree, producers and importers of clothing and household textiles become responsible for the waste phase of products they release on the Dutch market.
The EPR for Textiles Decree holds producers and importers individually accountable for:
- organizing an appropriate separate collection system and financing it.
- the obligation to ensure recycling and reuse of collected textiles.
The government has defined targets to this: 50% of the release on the Dutch market must be recycled/reused in 2025, gradually increasing to 75% in 2030. Currently, approximately 35% is reused and recycled.
Objectives
The EPR for Textiles Decree holds producers/importers of textiles they release on the Dutch market accountable for separate collection, reuse and recycling and organizing and financing an appropriate collection system.
by 2025
- At least 50% reuse and recycling, of which:
- at least 20% reuse
- at least 10% reuse in The Netherlands
- at least 25% of the recycling is fiber-to-fiber recycling
by 2030
- At least 75% reuse and recycling, of which:
- at least 25% reuse
- at least 15% reuse in The Netherlands
- at least 33% of the recycling is fiber-to-fiber recycling
Note: % targets refer to textiles placed on the market in the Netherlands in the previous year (i.e. not discarded textiles).
What does this mean for my organization?
The EPR for Textiles Decree applies to producers and importers who professionally release consumer clothing, work & corporate wear, table, bed-, table and household linen on the Dutch market. This also applies to textiles with recycled content. It does not matter to whom the product is offered; this can be to a company, or directly to a consumer.
Are you a producer or importer in accordance with the EPR for Textiles Decree? Then you are responsible for the separate collection and processing of discarded textiles. You must ensure that consumers and other end users can always hand in your products at a collection point, anywhere in the Netherlands and free of charge. You must also be able to demonstrate what happens to the textile waste. And you report annually on the quantity of textiles you have released on the Dutch market and whether and how the collection, recycling and reuse targets have been met.
As a producer and importer of clothing and textiles, you formally have an individual responsibility, but you may have it carried out collectively by a producer organization.
Stichting UPV Textiel is happy to help you comply with the law. Together we make the textile industry more sustainable.
Why participate in the collective?
Organizing an appropriate, effective and affordable collection system and achieving reuse and recycling targets is complex and costly. Especially when you have to take care of this individually. It is therefore important to join forces and share financial burdens. On behalf of you and other participating companies, Stichting UPV Textiel makes agreements with municipalities, collectors, sorters, recycling shops, recyclers and with companies that develop new initiatives for the collection and processing of textiles. With the annual fee, which you pay from 2024 on the weight of clothes and textiles you release on the Dutch market every year, the costs of collection and processing are covered and part of this can be invested in innovations and knowledge sharing in the field of high-quality recycling. In this way, companies can take responsibility together and realize the set objectives.
By participating in Stichting UPV Textiel, you comply with your EPR obligations in a simple and affordable way. Together we make the textile industry more sustainable.
Frequently asked questions
EPR for Textiles Decree
The EPR for Textiles Decree applies to producers and importers who professionally release consumer clothing, work & corporate wear, bed-, table-, and household linen on the Dutch market. This also applies to textiles with recycled content. It does not matter to whom the product is offered; this can be to a company, or directly to a consumer. More information on scope EPR for Textiles, can be found here.
A producer/importer is the one who puts textiles on the market in the Netherlands for the first time. Putting on the market: making textile products available on the market in the Netherlands for the first time. Usually this is the same as the moment when VAT is charged for the first time. More information on who the EPR for Textiles applies to can be found here.
For example:
- A label/brand owner or private label producer based in the Netherlands who controls the production itself and puts the products on the Dutch market.
- A company based in the Netherlands that purchases clothing/textiles from a supplier based abroad and markets the products in the Netherlands. A Dutch intermediary that has clothing/textiles manufactured or purchased abroad for or on behalf of other parties (e.g. brand owners) is also considered an importer. When the brand owner himself has the products manufactured abroad, and imports them himself and markets them first in the Netherlands, the brand owner is an importer.
- An (online) retail party based in the Netherlands that imports clothing/textiles and places it on the market.
- An online party based outside the Netherlands that operates from a storage location abroad directly to the Dutch consumer (e.g. Amazon, SHEIN, Aliexpress). This e-commerce party is also obliged to appoint an authorized representative in the Netherlands for the implementation of all obligations in the context of EPR for Textiles.
For the EPR for Textiles Decree is not regarded as a producer/importer:
- A thrift shop for the sale of Dutch second-hand clothing. After all, these clothes have already been put on the market.
- A company based in the Netherlands that supplies semi-finished products/basic materials for the manufacturing of consumer clothing, work & corporate wear, bed-, table and household linen.
In a number of specific cases, the law does not yet provide sufficient information. This may require further implementation of the EPR for Textiles Decree.
The EPR for Textiles relates to consumer clothing (HS/GN 61 and 62), work & corporate wear (61 and 62), bed linen (6302), table linen (6302) and household linen, for example towels and tea towels (6302) without distinction of domestic or commercial use. Unsold stocks are not covered by the EPR for Textiles Decree if it can be shown that they have not been put on the market. On the customs papers, you will see which HS/GN code your products have. You can find an overview of the product codes covered by the EPR for Textiles Decree in the conversion tableYou don't know the code? Then you can also look it up in the customs tariff list.
Stichting UPV Textiel makes agreements about collection and processing with various stakeholders and will ensure that these are complied with. In addition, participants have the obligation to declare quantities and pay the annual fee. The foundation monitors and reports to the Ministry of of Infrastructure en Water Management and is the point of contact for compliance on behalf of the participants for the Inspectie Leefomgeving en Transport (ILT).
The EU has promised harmonization through directives. Every EU Member State must design separate textile collection by 2025 at the latest. The legal background to this is the recent update of the EU Waste Framework Directive. This is one of the reasons that the EPR for Textiles Decree was created in the Netherlands. Producers are obliged to set up an adequate collection system. It is expected that several Member States will follow the example of France (already 12 years) and the Netherlands. MODINT is a member of the European trade association Euratex. Together they lobby to ensure harmonization of the EPR for Textiles Decree within the European textiles industry.
More information on announcements around this topic can be found here.
Rules for reusing and recycling textiles: Chamber of Commerce
Rules for reusing and recycling textiles: Government of the Netherlands
Op weg naar een circulaire textielketen: Afval Circulair (in Dutch)
Uitgebreide Producenten Verantwoordelijkheid (UPV): Afval Circulair (in Dutch)
FAQ Reikwijdte UPV textiel: Afval Circulair: Afval Circulair (in Dutch)
FAQ Doel en inwerkingtreding UPV textiel: Afval Circulair (in Dutch)
Collection and processing
In 2025, the Foundation will start implementing collection and processing of textiles. For this purpose, we will develop a Textile Management Structure. This involves setting up an effective, efficient collection and processing system to achieve the EPR targets, a fee system, a recognition scheme and monitoring to measure what happens to discarded textiles. To this end, the foundation, on behalf of participating manufacturers and importers, will enter into contracts with collectors and sorters to reimburse them for the net costs associated with the separate collection and processing of textiles to achieve the EPR targets. The goal is to have the structure that is being formed align with existing textile intake and processing infrastructure. Currently, about 35% of the textiles are reused and recycled, but this needs to be increased to 50% by 2025, requiring additional measures. We are working closely with various supply chain partners including Vereniging Herwinning Textiel (VHT), Branchevereniging Kringloop Nederland (BKN), Vereniging Nederlandse Gemeenten (VNG) and NVRD (Dutch municipalities and public companies) to restablish agreements on the textile management structure and compensation that are workable and realistic for everyone.
Participation
The Textile Management Fee Agreement (TMFA) sets out the obligations between the Participants and Stichting UPV Textiel regarding the implementation of the transferred legal obligations. By signing the TMFA, you finalize your participation in Stichting UPV Textiel You also agree that the foundation will carry out the EPR obligations on your behalf and that you will honour agreements associated with them. With the receipt by Stichting UPV Textiel of your signed TMFA, you are an official and legally correct participant of Stichting UPV Textiel and the foundation takes over your individual responsibilities. The TMFA also forms the basis for applying for the General Binding Declaration (GBD) of this TMFA. This will ensure that all suppliers and importers who market products in our country will contribute and a level playing field is maintained. The TMFA therefore incorporates the legal requirements to apply for a GBD.
Stichting UPV Textiel is a formally recognized producer organization. Meanwhile, more than 850 producers and importers have joined Stichting UPV Textiel. The list of participants shows an overview of our participants. Participants in this list can also represent sub-participants.
Textile Management Fee
The board of Stichting UPV Textiel annually sets the budget and the provisional and final rate of the textile management fee. The foundation board consists of executives from. Angro, Beddinghouse, Company Fits, HEMA, Fabienne Chapot, Livera, WE fashion, Wibra, Zeeman and INretail/Modint. The textile management fee is largely determined by costs required for implementation of collection and processing and market coverage of the producer organization.
Producer/importer pays a fee to the producer organization allowing a separate collection, reuse and recycling, support to innovation/transition circular, cooperation in a sustainable supply chain & waste handling/processing. You can read more about the textile management contribution and budget distribution in this infographic.
You pay an annual provisional fee on the weight of textiles you expect to market first in the Netherlands. In the following year, you provide the realised sales of the previous calendar year before April 1st. The difference in fee will then be settled. You only pay for textiles actually placed on the market in the Netherlands. Large companies receive a quarterly invoice for a quarter of the provisional textile fee, smaller companies receive the invoice once a year, in September. The final invoice follows after you have submitted the final statement.
The participants will pay a fee in 2024 to cover the start-up costs required to make the systems operational. These start-up costs are distributed among all participants, including those who will join in the coming years. Participants who contributed in 2024 to the development of the system (pre-financing the start-up costs) will receive this contribution back from 2026 onwards, in four annual instalments. In 2025, the Foundation will require all available funds to finance operational costs and meet legal obligations.
According to the EPR for Textiles Decree, each producer/importer is responsible for the weight put on the market. A small proportion of these companies will market most of the weight. To keep the administrative burden low, Stichting UPV Textiel is investigating the possibility of using a threshold for companies that do not put a lot of weight on the market.
On the basis of the EPR for Textiles Decree, Stichting UPV Textiel must assess whether rate differentiation on the basis of sustainability indicators is feasible and useful. The foundation will conduct further research into this in the near future, for example to stimulate the application of recycled content in clothing/textiles. The foundation will work closely with the sector to develop a fair and applicable form of rate differentiation.
The EPR obligation applies to products marketed in the Netherlands. The producer/importer declares all these products, also when is not clear where the products go to later in the chain. The starting point is that the fee is paid only once. Within the collective we are working on a settlement and export refund is possible for textiles on which a fee has been paid, as with other EPR systems. This needs to be elaborated in consultation with the sector to decide what is a practical manageable system. With individual participation (not through a collective), such a settlement is not easy to achieve.
Yes. The Foundation will not issue invoices in the first and second quarters of 2025. In the third and fourth quarters of 2025, you will receive an invoice of €0.12 per kilogram based on the total weight for 2025. This means that half of your 2025 textile management contribution will be invoiced in the third quarter and the other half in the fourth quarter. This amounts to an average contribution of €0.12 per kilogram on an annual basis for the entire 2025 calendar year.
Statement
Before April 1 you must declare the total weight of textiles that you will put on the market in the Netherlands in the coming year. Based on this statement, you will pay a provisional fee. In the following year, you submit the realised sales for the previous calendar year before April 1. The difference in fee is then settled. In Textool you will find the Textile Administration Manual, in which you can read exactly what the statement looks like and how to keep your records.
Trade often works with pieces. The collection and processing work on the basis of kilograms.
The blueprint working group examined which administration is simplest and fairest. In the statement 2023 you gave input on this. The working group's advice was adopted by the board and it was decided to do the statement in kilograms. This has also been included in the Textile Management Fee Agreement (TMFA).
The foundation is working with participants on a supplementary manual for your EPR for Textiles administration, which will be published in early December. The manual will include a practical roadmap with tools on how your company can set up textile administration to declare and pay the fee.
Stichting UPV Textiel
Complying with the legislation on EPR for Textiles is an individual legal obligation, but the EPR states that this may be carried out collectively by means of a producer organization. MODINT and INretail have taken the initiative for a collective implementation by establishing Stichting UPV Textiel (EPR Foundation for Textiles). This foundation will act as a producer organization and works for the entire sector, both members and non-members. In other sectors that preceded (packaging, tyres, cars, electronic devices, …), this appears to be the best way to keep the EPR efficiently, effectively and affordable. The foundation wants to cooperate with systems in other EU countries. Companies who are active on the international market have an interest in this.
The board of Stichting UPV Textiel includes executives from Angro, Beddinghouse, Company Fits, HEMA, Fabienne Chapot, Livera, WE fashion, Wibra, Zeeman and INretail/Modint.
There is great enthusiasm: many companies are substantively interested, take the subject seriously and indicate they would like to join the collective. As with other UPV systems, the collective needs volume to set up an efficient, effective and affordable collection and processing system in the Netherlands for textiles. We count on a majority of the total weight put into the market and of the total number of companies. This majority is needed for a General Binding Declaration, by which all producers/importers that put textiles in the Netherlands on the market must pay a textile contribution.
