The planned introduction of Extended Producer Responsibility (EPR) for textiles will materially alter the commercial strategies of producers and retailers. Hence, the system's effectiveness will depend on whether it is structured for practical application or rather results in escalating expenses, greater administrative burden, and potential competitive imbalances. The VERE association is presenting concrete proposals on this matter intended to ease the burden on small and medium-sized enterprises.
Keeping costs under control: predictability instead of risk
A key problem is financial uncertainty: if companies are required to accept all collected textile volumes and meet collection quotas, additional costs can quickly arise, particularly if some market participants fail to fulfil their obligations. VERE is therefore calling for a clear system: only volumes within the specified limits should be fully counted and remunerated. Surplus quantities should be distributed via a compensation mechanism so that individual businesses are not unduly burdened. A safety net should cushion exceptional volumes. Fixed rules are also needed for remuneration; otherwise, prices could rise due to competition, and producers would have to pay. Uniform, data-based rates could create stability here and promote high-quality collection.
VERE advocates lean processes instead of duplicate structures
In addition to costs, the administrative burden is a decisive factor. VERE recommends making registration requirements as straightforward as possible and carrying them out exclusively at company level; additional requirements for individual brands create unnecessary administrative work. Digital solutions such as standardised data structures, automated verification mechanisms and clearly defined responsibilities can help make processes more efficient. Furthermore, it is advisable to incorporate existing structures to avoid duplication of effort and the creation of new authorities. For transparent tracking of material flows, precise categorisation of textiles in the register is recommended, as lifespan and recyclability vary considerably depending on the product, thereby enabling well-founded cost estimates.
Fair competition also means protection against free-riders
A system only works with consistent enforcement of the rules; unregistered suppliers, for example from non-EU countries or via online platforms, have long been causing competitive disadvantages for compliant companies. Effective enforcement and the clear principle of ‘no registration = no sale’ should therefore be indispensable here, and violations must be swiftly detected and sanctioned. Past market activities should be taken into account to close loopholes. Companies must also take responsibility for quantities already sold; otherwise, compliant suppliers will continue to suffer.
Reducing administrative burdens – without relinquishing control
Efficiency does not preclude control but simply requires clear rules. For contaminated textiles, costs should only be borne by producers if the goods are still usable. This requires transparent standards and precise documentation so that perverse incentives can be avoided and investments in better collection and sorting processes made attractive. The introduction of textile EPR is fundamentally sensible for strengthening the circular economy and securing waste management structures. Nevertheless, it's essential to make the right choices to prevent the system from turning into a costly burden:
- Costs must remain predictable and limited
- Bureaucracy must not get out of hand
- Distortions of competition must be prevented
VERE’s proposals demonstrate how these objectives can be reconciled. For producers and retailers, the priority now is to ensure these points are taken into account in the ongoing legislative process so that environmental responsibility does not become an economic burden.
VERE e.V. is in contact with all relevant stakeholders and keeps its members informed about further developments via the “VERE Insider”.
Do not miss out and become a VERE member today!
