The groups include German Retail Association (HDE), Textile, Shoes and Leather Goods Trade Association (BTE), and Foreign Trade Association of German Retailers (AVE). These groups represent numerous prominent enterprises with considerable stakes in private label merchandise.
The document draws from established practices in managing EPR systems for packaging as well as electrical and battery returns.
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The goal is to discern which proven procedures, actions, and strategies could be adapted for use within the textile and footwear industries. Given the intricate nature of these products, it is acknowledged that any effective EPR scheme must address their specific complexities, note the associations.
“Successful take-back systems have already been developed in recent years, for example for packaging, waste electrical equipment and batteries. This can now be built upon in the development of a system for implementing extended producer responsibility for textiles and shoes,” HDE general manager Stefan Genth stated.
Genth highlighted the necessity of leveraging insights from established systems and ensuring straightforward implementation across all business sizes within the textile and shoe industry.
“Due to the corporate structure in the textile and shoe sector, there is a need for specifications that are easy to implement for all market participants, regardless of company size,” Genth added.
Key elements of the concept paper:
Conceptual framework and goals: Establishing a framework for an effective EPR system is crucial, with goals centred on minimising fabric waste and enhancing the cycle of reuse and recycling.
Regulatory framework: The proposal calls for consistent regulatory measures across the EU, ensuring that all member states adhere to the same legal requirements without the imposition of supplementary national laws. The system should be structured as a private, competitive entity. In Germany, there is a need for clear standards and delineated duties for organisations involved in manufacturing, collection, sorting, as well as for manufacturers and their authorised representatives that are verifiable through auditing.
Centralised authorisation and oversight: To ensure uniformity, there must be a nationwide standard in Germany governing the approval of systems and their processes.
Function of intermediaries: It is essential to establish precise definitions, standards, and protocols for monitoring agents along with implementing enforceable penalties to deter malpractice.
Why the need for a EPR blueprint for Germany?
With the advent of 2025, the EU mandated a distinct collection system for worn textiles and apparel as part of its EU textile strategy. This strategy is set to introduce a standardised, obligatory EPR system across member states.
The proposed EPR initiative for textiles, clothing, and footwear is designed to hold producers, importers, or sellers accountable for their products’ entire lifecycle, including end-of-life management and recycling processes.
To facilitate this, a fee will be levied on each distributor to cover the costs associated with collection and processing.
The trade groups say that Germany must craft legislation that addresses all aspects and challenges while ensuring compliance with the European Waste Framework Directive at a national level. It is crucial that this legislation mirrors European regulations precisely within domestic law, they emphasised.
