The German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety(BMUKN) plans to present a draft bill for a new Textiles Act this summer. The legislation is intended to introduce Extended Producer Responsibility (EPR) for textiles. Around 90 responses to the Ministry’s key issues paper are currently being evaluated, and, according to the Ministry, a number of crucial decisions are still pending. At the heart of the proposal lies a fundamental restructuring of the collection of used textiles. In future, distributors placing textiles on the market for the first time would assume responsibility for collection. Commercial collectors would be required to hand over all collected textiles to these producer responsibility systems and would receive remuneration for doing so, but would no longer have the right to market the collected materials themselves. The proposal is justified by reference to European requirements and the target of achieving a collection rate of around 70 per cent of the quantity placed on the market in the previous year. According to the Ministry, this target can only be achieved through clearly defined producer responsibility.
Industry meets draft bill with criticism
The recycling sector has warned of significant structural consequences. Commercial collectors and sorting companies argue that the collection system they have developed independently and financed privately is now under threat. In particular, they criticise the proposal that would reduce them to service providers with no influence over the recovery of collected materials. A central point of criticism is that removing marketing rights would weaken economic incentives to maintain high standards of sorting and quality. This, they argue, could ultimately undermine both reuse and high-quality recycling. From a legal perspective, critics point out that while EU legislation requires producer responsibility, it does not require the complete replacement of existing market structures. Instead, they argue, it envisages cooperation between producers and the waste management sector. Another concern is the proposed dual role of producer organisations as both funders and controllers of material flows. Critics believe this could create conflicts of interest that may negatively affect recycling quality and competition. The different treatment of commercial collectors compared with municipal and non-profit collectors is also viewed as problematic. The industry is therefore calling for a system in which producers assume financial responsibility while collection, sorting, and recovery remain open to competition. In addition, it proposes the establishment of an independent body for registration and enforcement, comparable to the existing registration structures in the electronics sector.
Key practical issues remain unresolved
Several important practical questions remain unanswered. These include how the 70 per cent collection target will be calculated and monitored, how non-recyclable textiles will be financed, and how collection volumes will be allocated among producer organisations. The protection of investments made by existing market participants also remains unresolved. The forthcoming draft bill is expected to provide the first detailed legislative proposal. However, the overall direction remains highly controversial. While the BMUKN supports a more centrally managed system of producer responsibility, the industry advocates maintaining a competitive system that builds on existing structures.
Will the change in paradigm in the textile retail sector succeed – from a throwaway society to a circular economy?
Olaf Dechow from the OTTO Group will speak on 9 September 2026 at the 9th VERE Panel Event at the Mövenpick Hotel in Hamburg on the topic “Will the change in paradigm in the textile retail sector succeed – from a throwaway society to a circular economy?”
VERE members can attend free of charge.
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