CSRD
Corporate Sustainability Reporting Directive (CSRD)
WHAT
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Standardizes ESG reporting within the EU
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Yearly disclosures on environmental and social matters
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Requires climate targets & concrete transition plan and report progress
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Sustainability report has to be audited
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WHO
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Every listed company that sells into the EU except micro-enterprises
WHEN
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Phase 1, 2025: Companies currently subject to the NFRD report on 2024 Phase 2, 2026: Large companies (both EU and non-EU) report on 2025
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Phase 3, 2027: Listed SMEs report on 2026
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Phase 4, 2028: Non-EU companies with branches in the EU report on 2027
CSDDD
Corporate Sustainability Due Diligence Directive (CSDDD)
WHAT
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Goal: Liability for human rights & environmental violations in supply chains.
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Develop due diligence policies and processes
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Identify human and environmental impacts of activities
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Prevent potential negative effects
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Ensure business models are inline w the Paris Agreement
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Include CO2e reduction objectives in their business plans.
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WHO
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Large brands w 1000+ employees and net EUR 450+m turnover worldwide
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Large non-EU w 1000+ employees w EUR 450+m turnover in the EU
WHEN
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2027 for 5000+ employees/ €1.5b+ turnover companies
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2028 for 3000+ employees/ €900m+ turnover companies
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2029 for 1000+ employees/ €450m+ turnover companies
ESPR
Ecodesign for Sustainable Products Regulation (ESPR)
WHAT
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Reduce the environmental impact of products throughout their lifecycle.
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Setting minimum requirements for physical performance (durability, reparability, recyclability, environmental footprint)
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Digital product passport
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Ban of destruction of unsold footwear and textiles
WHO
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Every brand that sells into the EU market
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SME’s will receive financial help and are initially excluded from the ban of destruction uf unsold goods
WHEN (expected)
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Q2 2025: Reporting obligations on the destruction of unsold goods
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Q2 2026: Ban of the destruction of unsold goods
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2027 (tbc): Textile companies will have to comply with the Delegated Act
Digital Product Passport
Digital Product Passport
WHAT
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Digital record of a product’s key characteristics throughout the entire lifecycle.
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Potentially 16 categories of information, including product’s origin, material composition, environmental impact, social impact etc.
WHO
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Every brand that sells in the European market
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SME’s will receive financial help
WHEN (TBD)
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Phase 1: “Minimal & simplified DPP” for Textile 2027
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Phase 2. Advanced DPP” or Textile 2030
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Phase 3: Full circular DPP” for Textile 2033
Green Claims
Directive on Green Claims
WHAT
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Complements the existing Unfair Commercial Practices Directive, and introduces more specific rules about environmental claims:
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Need to substantiate any green claims (by independent verifiers)
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Detailed guidance on how to communicate any green claims them
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Introduce new rules on environmental labeling
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Fines of at least at 4% of annual turnover.
WHO
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All companies except micro enterprises
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SMEs have an extra year and can expect financial help
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Also, non-EU companies that make voluntary environmental claims directed at EU consumers
WHEN
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2027/2028 - Proposal was adopted in March 2024, now the dialogue phase starts w the Parliament after the European elections in June 2024
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Until then the UCPD is the only European law that EU legislative act that addresses claims about the environmental impact of a product or brand.
AGEC law
France: Anti-Waste Law for a Circular Economy (AGEC law)
WHAT
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Aims to eliminate improper waste disposal and reduce waste by targeting single-use plastic packaging, extending product lifespan, implementing eco-design principles, and prohibiting the destruction of unsold goods
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Requires extension of product lifespan through measures like reparability and durability, establishing textile waste collection systems, etc.
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It will phase out all single-use plastic packaging by 2040.
WHO
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Applicable to all fashion and textile products sold in France
WHEN
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January 2023 – Companies with €50M+ in annual turnover and 25k units
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January 2024 – Companies with €20M+ in annual turnover and 10k units
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January 2025 – Companies with €10M+ annual turnover and 10k units
Climate & Resilience Law
The Climate & Resilience Law – Environmental Labeling for Products
WHAT
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Mandates environmental impact labeling on products sold by large fashion corporations in France.
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Environmental impact label to include greenhouse gas emissions, impact on biological diversity, and consumption of water and natural resources, promoting transparency and eco-consciousness.
WHO
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Requires companies with €50M+ turnover and 25,000 units to provide environmental impact labels on products.
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Eventually, this requirement will extend to all companies with €10M+ turnover and 10,000 units.
WHEN
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Enacted in 2021, the law initiates mandatory environmental labeling
NY Fashion Act
New York Fashion Act
WHAT
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The New York Fashion Act proposes mandatory detailed reporting on the environmental and social impact of fashion brands' products
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The act mandates enhanced due diligence procedures in fashion brands' operations to ensure compliance with environmental and social standards
WHO
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Applies to fashion businesses with annual global revenue exceeding $100M.
WHEN
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As of August 2023, the act is still under consideration and must pass both the New York State Assembly and the New York State Senate to become law.
Waste Framework
Waste Framework Directive
WHAT
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Aims to foster a circular economy and halt the EU's textile waste export
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Ensure that the EU does not ship its textile waste to developing nations
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Facilitates intra-EU waste transport and improves illegal waste tracking.
WHO
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Introduces Extended Producer Responsibility (EPR) for fashion brands, making them accountable for the entire textile lifecycle. Brands must join country-specific EPR schemes.
WHEN
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Mandates member states to establish separate textile waste collection by January 1, 2025.
Waste Shipments
Regulation on waste shipments
WHAT
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A proposed amendment to harmonize Extended Producer Responsibility (EPR) schemes in the textile industry under the Waste Framework Directive
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Aims to make textile producers accountable for textile waste management costs to incentivize waste reduction and circularity.
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Introduces eco-modulated fees based on environmental performance to cover textile waste management costs
WHO
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Applies to textile producers operating within the European Union.
WHEN
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Proposed as an amendment to the Waste Framework Directive by the European Commission in 2023
Textile Labeling Regulation
Textile Labeling Regulation
WHAT
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Revision of the Textile Labeling Regulation to address inconsistencies and inadequacies in fiber labeling, while accommodating advancements in fabric and recycling technologies
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Will introduce specifications for both physical and digital textile labeling, requiring brands to adopt standardized practices for providing accurate composition and origin information to consumers
WHO
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Fashion and textile brands operating within the EU must prepare to adapt their labeling procedures
WHEN
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The European Commission plans to revise the Textile Labeling Regulation in the fourth quarter of 2023
UCPD
Unfair Commercial Practices Directive (UCPD)
WHAT
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Established in 2005 for consumer protection, the UCPD now includes guidelines for sustainable claims, aiming to prevent greenwashing
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Complements upcoming Green Claims Directive by providing general rules for substantiating and communicating environmental claims, focusing on verification and clarity.
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Has already been enforced against major fashion retailers like H&M and Decathlon
WHO
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Applies to all commercial practices within the EU, particularly influencing companies making environmental claims and labeling
WHEN
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The UCPD has been in effect since its adoption in 2005, with the incorporation of sustainable claim guidelines in December 2021. The upcoming Green Claims Directive is proposed for March 2023
Netherlands EPR
Extended Producer Responsibility
WHAT
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Fashion and textile producers will be responsible for the collection, recycling, reuse, and waste of their products
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Brands will need to take numerous measures like providing textile collection locations, completing a one-time registration at Rijkswaterstaat, etc.
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Applies to apparel, as well as household items like bed linens and tablecloths
WHO
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Fashion and textile producers operating in the Netherlands or selling products in the Dutch market are obligated to comply with this regulation.
WHEN
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Implementation beginned on July 1, 2023. Starting from 2024, brands must submit annual reports, and from 2026, they must include objectives in their documentation.
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Textiles put on the market in 2024 will need to include at least 50% recycled materials, 20% of which are prepared for reuse.
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In 2029, all textiles will need to include 75% recycled materials with 25% prepared for reuse.
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Transparency Act
Transparency Act
WHAT
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Mandates companies to enhance transparency, uphold human rights, and promote decent working conditions throughout their value chains
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The act mandates that companies should take measures like conducting routine due diligence evaluations in line with OECD's multinational company guideline and making due diligence assessments readily accessible via the company website
WHO
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Applicable to large and mid-size companies either based in Norway or providing goods and services in the country.
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Companies meeting specific financial criteria, such as over 70 million NOK (ca EUR 6m, USD 6.5m) in sales revenue, over 35 million NOK in balance sheet total, or over 50 average employees in the financial year, fall within its purview.
WHEN
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Enacted in 2022, the act mandates companies to conduct due diligence assessments aligned with OECD's multinational company guidelines, focusing on human rights and labor conditions.
Supply Chain Act
Supply Chain Due Diligence Act
WHAT
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Fashion and textile brands will be required to implement rigorous due diligence processes throughout their supply chains, focusing on human rights and environmental standards.
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Monitoring and reporting on potential risks and adverse impacts in their global operations
WHO
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Affects large businesses operating in Germany, initially those with more than 3,000 employees, expanding to those with 1,000 or more in 2024.
WHEN
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Effective since January 2023, this law imposes fines of up to 2% of global turnover and potential bans from public contracts for non-compliance.
The FABRIC Act
The FABRIC Act
WHAT
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The Fashion Accountability and Building Real Institutional Change (FABRIC) Act, introduced in the US Senate in May 2022, aims to address the environmental and social impact of outsourcing garment production.
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Proposes a 30% tax credit for clothing producers willing to relocate their manufacturing to the US.
WHO
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The FABRIC Act targets clothing producers and fashion brands operating within the United States.
WHEN
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Introduced in May 2022, the FABRIC Act is currently pending passage in the US Senate, after which it will proceed to the House of Representatives for consideration
SB 253
California’s Climate Corporate Data Accountability Act (SB 253)
WHAT
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The act mandates large fashion companies operating in the state to annually report their greenhouse gas (GHG) emissions, including Scope 1, 2, and notably, Scope 3 emissions.
WHO
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The law applies specifically to large fashion companies in California, targeting those with annual revenues exceeding $1 billion
WHEN
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Effective January 1, 2026, the Climate Corporate Data Accountability Act necessitates the first emissions reports by 2027
SB 261
California’s Greenhouse Gases: Climate-Related Financial Risk Bill (SB 261)
WHAT
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Goes beyond emissions reporting to assess corporations' financial risks stemming from climate change
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The bill mandates compliance for brands, requiring them to assess and disclose climate-related financial risks, both physical and transitional.
WHO
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The legislation applies to corporations in California with revenues over $500M, encompassing a broad range of industries.
WHEN
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In October 2023, the California Governor signed SB 261 into law.
Labor Prevention Act
Uyghur Forced Labor Prevention Act
WHAT
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The Act aims to combat forced labor practices targeting ethnic minorities in China's Xinjiang Uyghur Autonomous Region
WHO
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American fashion companies importing products from the Xinjiang region are required to ensure no forced labor was used in the manufacturing process.
WHEN
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Effective as of June 2022, the act mandates companies to provide evidence of labor practices compliance when importing products from Xinjiang.
Mandatory Climate Reporting
Singapore's Mandatory Climate Reporting
WHAT
- Singapore will implement mandatory climate-related reporting to strengthen companies’ sustainability capabilities.
- Singapore will provide funding support of up to 30% for large companies starting mandatory climate-related disclosures from 2027.
WHO
- Applicability: Listed companies and large non-listed companies in Singapore.
- Exemptions: A large non-listed company may be exempt if its parent company reports climate disclosures using ISSB-aligned local standards, equivalent standards, or other international standards from FY2027 to FY2029.
WHEN
- Listed companies must report Scope 1 and 2 emissions in 2025, Scope 3 emissions in 2026, and obtain external limited assurance on Scope 1 and 2 GHG emissions by 2027 (two years after initial reporting).
- Large non-listed companies (those with at least $1 billion in revenue and $500 million in assets) must report Scope 1 and 2 emissions in 2027, begin Scope 3 reporting in 2029 or later, and obtain external limited assurance on Scope 1 and 2 GHG emissions two years after their initial reporting.
Greenwashing Bill C-59
Greenwashing Bill C-59
WHAT
- Bill C-59 introduces explicit prohibitions against deceptive environmental claims. These claims must be backed by scientific evidence and concrete data. All claims must be substantiated according to globally accepted standards (e.g. ISO) to prevent inconsistent and unverified methods.
- Significant penalties for deceptive marketing, with fines up to $10 million, $15 million for subsequent offenses, or three times the benefit derived from the conduct, or 3% of annual revenues.
- Reporting: Maintaining thorough documentation is crucial. Companies must keep detailed records of their tests, including methodologies, collected data, performed analyses, and drawn conclusions. This documentation must be readily accessible for regulatory authorities to verify.
WHO
- Any business making environmental benefit claims in Canada, whether a small startup or a multinational corporation, must comply with Bill C-59.
WHEN
- Bill C-59 became mandatory on June 20, 2024. From that date onward, all businesses operating in Canada must adhere to its stringent provisions to avoid penalties and ensure their environmental claims are credible and legally compliant
CRFD
Climate-Related Financial Disclosure (CRFD) Regime
WHAT
- The CRFD regime will mandate that certain organizations include a “sustainability report” in their annual financial statements.
- Reporting:
- Entities must submit a sustainability report covering climate-related risks, opportunities, and Scope 1, 2, and 3 emissions.
- For the first three years, companies have some legal protection for certain statements in their sustainability reports, meaning they won’t face penalties for those specific disclosures during this period.
WHO
- Large entities, phased in based on size:
- Group 1 (from 1 January 2025): $500M+ revenue, $1B+ assets, or 500+ employees.
- Group 2 (from 1 July 2026): $200M+ revenue, $500M+ assets, or 250+ employees.
- Group 3 (from 1 July 2027): $50M+ revenue, $25M+ assets, or 100+ employees.
WHEN
- 22 August 2024: Bill passed by the Senate.
- 1 January 2025: CRFD regime begins for Group 1 entities.
- 1 July 2026: Group 2 entities start reporting.
- 1 July 2027: Group 3 entities start reporting.
France EPR
France Extended Producer Responsibility
WHAT
- Manufacturers, online retailers, and distributors are legally required to compensate for the impact of their products, from packaging design to waste disposal.
- Producers must display the Triman Logo and Sorting Instructions on textiles for recycling.
- Eco-modulated EPR fees to encourage environmentally friendly product designs (Average: €0.01 per unit, Maximum: €0.06 per unit)
- Reporting: Producers must report placed on the market data on an annual basis by March of the succeeding year.
WHO
- The Textiles EPR system in France covers clothing, footwear, and household linens.
- Companies can choose to comply individually or collectively.
- Although some large companies like H&M have their own take-back systems, 95% of the market participates in the Refashion collective compliance scheme.
WHEN
- France was the first country in the world to adopt EPR for textiles in 2008
Sweden EPR
Sweden Extended Producer Responsibility
WHAT
- Sweden’s Textiles EPR system is targeting a 70% reduction of textiles disposed of by 2028, an 80% reduction by 2032, and a 90% reduction by 203624. Furthermore, from 2028, at least 90% of textile waste collected must be prepared for reuse or sent for recycling.
- Producers must join a Producer Responsibility Organization (PRO) to comply with fees, such as SEK 0.23 (~$0.02) per t-shirt.
- Reporting: Companies must report the amount of packaging they have imported, manufactured, or used in the Swedish market during the previous calendar year.
WHO
- Applies to producers of clothes, household & interior textiles, bags, and accessories.
- Includes both local and foreign companies selling textiles in Sweden, with foreign companies needing an 'Authorised Representative'.
- Obligations are placed on Sweden-based online marketplaces for products sold through their online marketplace to customers in Sweden.
- Producers that produce textile products from >80% textile waste (fibre-to-fibre) are exempt from obligations.
WHEN
- Since January 1, 2023, Sweden has implemented strict new regulations for packaging manufacturers and distributors to enhance recycling and reduce waste.
- Depending on the quantity and price per package, the deadlines are divided into three periods: monthly, quarterly, and yearly. Reports must be submitted by the 25th day of the month following the reporting period
- By January 1, 2027, at the latest, all municipalities must implement a door-to-door collection system for packaging waste.
Hungary EPR
Hungary Extended Producer Responsibility
WHAT
- Will make producers and manufacturers responsible for the waste management costs of specific products
- Producers must register with the National Waste Management Authority and make EPR contributions quarterly. EPR fee: HUF 145 ($0.42) per kg of textiles.
- Reporting: The EPR system requires companies to submit quarterly sales volume reports to the National Waste Management Authority. The data is sent to MOHU MOL, which invoices companies for recycling fees used for waste collection and treatment in Hungary.
WHO
- Scope: Apparel, clothing accessories, household linens, curtains, blankets/rugs, footwear, and carpets. Applies to companies at the first domestic sale of the product.
- Includes foreign companies selling directly to customers in Hungary, who can appoint a national 'Authorised Representative'.
WHEN
- Obligated companies were required to register with the National Waste Management Authority by 31 May 2023.
Spain EPR
Spain Extended Producer Responsibility
WHAT
- Law 7/2022 on Waste & Contaminated Soil for the Circular Economy entered into force in April 2022. The Law expanded the application of the EPR concept to cover the textiles waste stream.
- Online platforms must ensure partners selling in Spain have appointed an authorized representative and obtained an EPR ID.
- Reporting: Reports on the amount of packaging introduced to the market for each production year.
WHO
- Applies to national producers and online marketplaces.
- National online marketplaces (e.g., Zalando) must ensure foreign partners appoint an authorized representative and obtain an EPR ID ("numero de registro").
WHEN
- The deadline for implementation is not until April 2025. Thus, whilst Textiles EPR is present in the law, it is not active in Spain, and implementation is pending.
Australia EPR
Australia Extended Producer Responsibility
WHAT
- The Australian Government has added clothing textiles to the Federal Minister’s priority list for product stewardship, requiring industry action to reduce landfill waste.
- WRAP collaborated with the Australian Fashion Council, Charitable Recycling Australia, Queensland University of Technology, and Sustainable Resource Use to create a National Stewardship Scheme for clothing in Australia.
- The National Stewardship Scheme mandates a four-cent charge per garment to encourage durable, recyclable clothing design and fund the expansion of textile collection, sorting, and recycling infrastructure.
WHO
- Scope: Clothing manufacturers and importers in Australia.
- The Seamless Stewardship scheme is a voluntary initiative that was co-created by WRAP
WHEN
- The EU directives regarding extended producer responsibility (EPR) are mandatory for all European countries. The translation into national laws in the countries must be completed by 2025 at the latest.
Bulgaria EPR
Bulgaria Extended Producer Responsibility
WHAT
- Producers will be responsible for coordinating and financing the collection, recycling, and preparation for reuse of footwear and textile waste.
- Packaging Requirements: Under EPR, companies must label packaging with material codes to enable proper sorting and recycling. The previous obligation to label with the "Möbius Loop" and "Tidy Man" is now voluntary, but packaging materials must still be identified with material codes.
- New Obligation: Producers must register with the Bulgarian environmental authority and submit regular reports on their waste management efforts.
WHO
- Scope: Applies to producers, importers, and distributors of new textile products and footwear in Bulgaria. This includes both local and foreign companies distributing products.
WHEN
- By 2025: The EU directives on EPR must be transposed into national laws, requiring compliance by 2025.
- January 2022: The packaging labeling obligations came into effect, requiring clear material identification for all packaging placed on the Bulgarian market.
USA EPR
U.S. California Extended Producer Responsibility
WHAT
- Objective: Manage textile waste effectively and promote recycling, reuse, and durability.
- Responsible Textile Recovery Act SB 707 will adopt Textiles EPR in California.
- Producers must implement and fund a Textiles EPR system, making products more durable and easier to repair, reuse, and recycle.
- Reporting: Producers must provide CalRecycle (California’s Department of Resources Recycling and Recovery (CalRecycle) with a list of covered products and update it annually.
WHO
- Scope: Apparel, accessories, handbags/backpacks, drapes/curtains, furnishings, upholstery, bedding, towels, and napkins/tablecloths.
- Fines for non-compliance range from $10,000 to $50,000 per day.
WHEN
- Following some postponements to conduct wording negotiations during 2023, Act SB 707 is expected to be actioned during 2024.
- 31 December 2025: Effective date for regulations implemented by CalRecycle.
Italy EPR
Italy Extended Producer Responsibility
WHAT
- Objective: Manage textile waste, promote sustainability, and reduce environmental impacts in design, production, disposal, and recycling of textiles.
- Producers are responsible for financing and organizing the collection, preparation for reuse, recycling, and recovery of textile waste.
- Eco-design measures must be incorporated to ensure products are suitable for reuse, repair, and contain recycled materials, while also being durable and easily repairable.
- Digital Labeling System: Producers must describe the textile’s characteristics and composition, including the presence of non-textile parts.
- Environmental Fee: Introduced to cover waste management costs and encourage circular economy innovations.
WHO
- Applies to clothing, footwear, leather apparel, home textiles, and accessories.
- Local and foreign companies must comply.
- Collective compliance or individual compliance will be permitted
WHEN
- February 2023: The Ministry of Environment and Energy Security (MASE) and the Ministry of Enterprise and "Made in Italy" (MIMIT) announced the draft EPR Decree.
- Consultation Phase: Feedback due by 3 March 2023.
- By 2025: Italy is expected to establish separate textile waste collection in line with the EU Waste Framework Directive.
UK EPR
United Kingdom Extended Producer Responsibility
WHAT
- Objective: Manage textile waste effectively and reduce landfill/incineration of old clothing.
- The 2018 Waste/Resources Strategy (updated in 2023) includes plans for the UK government to review and consult on EPR measures for textiles by the end of 2025.
- The UK Fashion & Textile Association (UKFT) is leading the creation of a £4 million automated sorting and pre-processing plant for non-renewable textiles
WHO
- Scope: All companies placing garments on the UK market.
WHEN
- 2018: Waste/Resources Strategy initially published.
- 2023: Strategy updated; announcement of delay in EPR measures for textiles.
- End of 2025: Deadline for reviewing and consulting on EPR measures for textiles.
