In 2025, fashion brands aren’t being judged by what they make, but by what happens after it’s been worn, washed, and discarded.
Around the world, governments are putting new rules in place to make producers legally responsible for the clothing they sell, not just during production, but all the way to end-of-life. It’s called Extended Producer Responsibility (EPR), and it’s shifting the cost of textile waste away from taxpayers and municipalities and squarely onto the industry itself.
EPR laws aren’t just theoretical anymore. France already requires brands to pay for collection and recycling. The Netherlands is next. California has passed its own bill. And the EU has proposed a new directive that would make EPR mandatory across all member states, expanding its Waste Framework Directive to include producer-funded textile collection and recycling.
Add in ongoing developments in the UK, New York, and parts of Asia, and a clear picture emerges: fashion’s linear business model — take, make, dispose — is finally being priced in.
But while the pace of regulation is accelerating, readiness isn’t. Many brands are still unsure what these laws actually require, let alone how to comply across multiple markets, each with its own rules, timelines, and penalties. And for sustainability teams already stretched thin, EPR can feel like one more compliance burden in an already crowded landscape of ESG expectations.
The truth is more nuanced. Yes, EPR is a cost and for some, a wake-up call.
But it’s also a rare opportunity, because behind the legal language is a simple principle: those who design the product should take responsibility for what happens when it’s no longer wanted. And that principle, when embraced strategically, can push brands toward systems that are not only compliant but circular, traceable, and built to last.
So what does this shift actually mean in practice? What laws are already in effect? Which markets are next? How can fashion brands prepare, not just to avoid fines, but to build smarter systems and stronger business models?
Let’s break it down.
What Is Extended Producer Responsibility (EPR) and Why Fashion Can’t Ignore It
Extended Producer Responsibility (EPR) isn’t a new concept. At its core, EPR is a policy tool that makes producers legally and financially responsible for the products they put on the market, long after they’re sold.
That means when a garment is worn out, outgrown, or simply unwanted, it’s not the local council or landfill operator who foots the bill. It’s the brand that made it.
For decades, fashion’s dominant model has been linear: extract, produce, sell, dispose. Waste was someone else’s problem. But under EPR, that externality becomes a cost of doing business. The more clothing a brand sells and the harder it is to reuse, recycle, or safely dispose of, the more it pays.
Which, in theory, should drive change. It gives brands a financial reason to invest in better design, cleaner materials, and recovery systems that keep textiles in circulation.
Some countries have taken this further by introducing eco-modulated EPR fees, where products designed for durability, repairability or recyclability are charged lower fees. This turns sustainable product design into a cost-saving mechanism, not just a marketing exercise.
In France, for instance, garments made from recycled fibres or built for long use can qualify for lower tariffs under its national scheme.
EPR is forcing a rethink of what it means to take responsibility for a product’s full lifecycle. It’s more than a sustainability issue — it’s a supply chain, data, design, and commercial one.
So while EPR may sit within environmental regulation, its effects are structural. This is about shifting the default business model, from one that ends at the checkout to one that starts again at take-back.
And for fashion, that shift is already underway.
Global EPR Landscape: EU, US, UK & Beyond
Governments in major fashion markets are introducing rules that shift waste responsibility upstream — from bins and landfills, to the brands that put products on the market in the first place. But like most policy rollouts, there’s no universal template. Timelines vary. Fee structures differ. And enforcement is uneven.
For fashion brands operating internationally, that means one thing: a patchwork of obligations that are becoming harder to ignore.
Europe: Leading with Legislation
The EU is moving from policy signals to legal requirements — textile and fashion are front and centre.
- By January 2025, all EU Member States must have systems in place for separate collection of textile waste under the EU’s Waste Framework Directive. This is already the law.
- In 2023, the European Commission proposed a revision of the Waste Framework Directive that would make EPR mandatory for textiles across the bloc.
- Under the proposed rules, brands would be required to cover the full cost of post-consumer textile management, from collection to recycling.
- Crucially, fees could be eco-modulated, meaning garments that are more recyclable, durable, or made from sustainable materials would incur lower costs.
While this directive is still under negotiation, approval is expected in late 2025, with full enforcement likely by 2027.
Some countries aren’t waiting:
- France introduced textile EPR back in 2007. Brands must fund the national collection scheme managed by Refashion. It’s also one of the first to apply eco-modulation in practice.
- The Netherlands launched its EPR scheme in 2023, with ambitious targets: 50% of textiles collected for reuse or recycling by 2025.
- Sweden, Latvia, Hungary and others are advancing their own national schemes ahead of the EU mandate.
If you sell into these countries, you’re already expected to register, report, and contribute to compliance schemes, even if you’re not based there.
United Kingdom: Following Closely
While the UK has yet to introduce a binding textile EPR law, the direction of travel is clear.
- Government consultations on EPR for fashion have already taken place.
- Industry groups like WRAP and the British Fashion Council are actively shaping proposals.
- A voluntary textile EPR roadmap is in motion, with mounting pressure to make it mandatory.
Given its post-Brexit alignment with many EU sustainability policies, a formal EPR regulation could follow by 2026 or sooner. For brands trading in both the EU and UK, early alignment makes operational sense.
United States: State-Led Momentum
There’s no federal EPR law for textiles in the U.S. yet — but state-level regulation is starting to change that.
- In 2024, California passed the Responsible Textile Recovery Act (SB 707) — the first law of its kind in the U.S.
- The law requires fashion brands to finance and implement systems for collecting and recycling unwanted textiles, with program design set to begin in 2025.
- New York and Washington are considering similar bills.
What’s emerging is a state-by-state patchwork, echoing past U.S. EPR legislation for packaging and electronics. Without federal harmonisation, brands will need to monitor and comply with a growing list of local laws.
Rest of World: Growing Interest, Patchy Action
Other regions are in earlier stages, but attention is growing.
- Australia is exploring textile EPR through its national waste strategy. Some states have banned textile landfill disposal entirely.
- Japan operates voluntary take-back schemes led by industry; formal EPR may follow.
- Canada’s provinces, especially Quebec, have begun consultations on extending EPR into new sectors.
- In the Global South, the conversation is increasingly focused on imported textile waste. EPR may soon be tied to extended brand responsibility for post-export impacts.
The Takeaway
Fashion’s regulatory environment is fragmenting, but the direction is unified. Wherever brands sell, they’ll soon be expected to:
- Register with national authorities or PROs
- Report product volumes and materials placed on each market
- Pay fees to cover end-of-life management costs
- Design products with durability and recyclability in mind
Waiting for regulation to “settle” is no longer a viable strategy. For brands with global reach, proactive harmonisation of systems, data and design will be the only way to stay ahead — and stay compliant.
What EPR Means for Fashion Brands
EPR is redefining what it means to be a fashion producer.
Until now, most responsibility ended at the point of sale. Once the product left the warehouse or store, it became someone else’s problem — someone else’s landfill bill, recycling headache, emissions count. But under EPR, that separation no longer holds.
Brands are being asked to own the end of the story. And with that comes a new set of responsibilities, not symbolic ones, but measurable, reportable, and enforceable.
Let’s break down what this actually means in practice.
1. Financial Responsibility: Paying for End-of-Life Management
At the core of every EPR scheme is the same principle: if you put it on the market, you help pay to take it off.
That means brands must contribute financially to systems that collect, sort, and process used textiles. These contributions are typically calculated based on:
- Volume (units sold or weight placed on the market)
- Material composition
- Product category (e.g. garments vs. home textiles)
In some countries, this takes the form of a fee per garment (e.g. ~€0.01 in France). In others, it’s calculated per kilogram of textiles sold (e.g. €0.12–€0.24 in the Netherlands). And in many emerging schemes, these fees are expected to rise over time.
But the financial model doesn’t just penalise quantity. Through eco-modulation, it can also reward quality. Products designed to last longer, be repaired, or recycled more easily may qualify for reduced fees, creating a direct business case for better design decisions.
2. Operational Responsibility: Collection, Sorting, Recycling
Under EPR, brands aren’t expected to build recycling plants themselves, but they are expected to ensure systems exist.
In most cases, this means joining a Producer Responsibility Organisation (PRO) — a government-recognised body that coordinates the logistics of textile recovery on behalf of multiple brands. PROs:
- Manage collection points and partners
- Set operational targets (e.g. recovery rates, reuse vs. recycling ratios)
- Distribute funding across waste management providers
Brands must register with a PRO in each relevant market, contribute fees, and report accurate data on their product volumes. Some markets also allow brands to operate their own compliance scheme, but this comes with a heavy administrative burden and regulatory oversight.
In short, EPR doesn’t mean every brand needs its own recycling programme. But it does mean every brand must participate in one.
3. Reporting Responsibility: Traceability is Now a Compliance Issue
One of the less visible — but most disruptive — parts of EPR is what it demands behind the scenes: data clarity.
Brands will be expected to report on:
- The quantity and type of textiles placed on each national market
- Material breakdowns (e.g. % cotton, % recycled fibre)
- Design attributes relevant to recyclability or durability
- Proof of compliance with eco-modulation criteria (where applicable)
In some regions, this also includes consumer labelling (e.g. France’s Triman logo), public disclosure of recovery rates, and digital product tracking for future traceability requirements.
For many brands, especially those with complex or decentralised operations, this will mean significant upgrades to data systems — and closer integration between design, sourcing, logistics, and sustainability teams.
4. Market Responsibility: Registration and Representation
Selling into a country with an active EPR law? You can’t remain invisible.
Most regulations require that brands — regardless of where they’re based — must register locally. This often includes:
- Appointing an authorised representative if you don’t have a local legal entity
- Maintaining a unique producer ID for regulatory audits
- Demonstrating that you’ve joined an approved PRO or compliance scheme
Failure to comply can lead to:
- Fines or enforcement actions
- Product delisting or blocked imports
- Loss of reputation with retailers, regulators, and consumers
For global brands, EPR compliance is now a go-to-market issue. The shape of these responsibilities may vary by market. But the message is consistent:
What you sell. How you design. What data you track. Where you sell. How you plan for end-of-life. It’s all becoming part of your brand’s regulatory footprint.
And the longer a brand waits to adapt, the more costly that footprint could become.
ERP Playbook for Fashion Brands: How To Prepare in 2025
EPR is coming or, in many cases, already here. But compliance isn’t just about avoiding penalties. It’s about getting your systems, teams, and products aligned with a world where circularity is no longer optional.
For brands still playing catch-up, here’s what readiness looks like.
1. Start With Your Data and Don’t Wait for Perfection
The most common blocker isn’t policy; it’s data. Many brands still don’t have accurate visibility on:
- How much product do they place on each market
- The weight of each SKU or style
- Material composition at the fibre level
- Whether their designs meet “eco-modulation” thresholds
That’s a problem because every EPR scheme starts with a measurement. Without that baseline, you can’t register, report, or pay the right fees. And you can’t prove circular design if you can’t describe your product.
The fix? Start with what you have. Conduct a material and product audit across your most important markets. Identify gaps. Set a standardised product data protocol going forward. Then build towards traceability from there.
You don’t need perfect data. But you need real data and a system for improving it.
2. Engage With the Right PROs, in the Right Markets
You’re unlikely to fulfil EPR obligations on your own. In most cases, you’ll need to join a Producer Responsibility Organisation (PRO), the entity that handles collection, sorting, and reporting on behalf of its members.
Each country has different systems. A few to know:
- France: Refashion
- Netherlands: Stichting UPV Textiel
- Hungary: MOHU
- California (forthcoming): Program being designed under SB 707
Joining a PRO means contributing fees, yes. But it also provides structure, support, and often pre-approved pathways to compliance.
For global brands, the key is local representation, ensuring you have a compliance partner (internal or external) who can manage registrations and ongoing reporting market by market.
3. Budget for Fees, But Don’t Stop at Cost Control
Yes, EPR comes with a price tag. But smart brands aren’t just treating it as a cost line; they’re looking at it as a pricing, margin, and product strategy issue.
Here’s what that looks like in practice:
- Finance teams model EPR fees per unit or per kilo to assess market exposure.
- Design and R&D explore how material and construction choices impact cost under eco-modulation.
- Merchandising teams understand which products will carry heavier regulatory weight.
Brands that take a passive, reactive approach risk death by a thousand cuts. Those who plan early can integrate circularity into product development and save money by design.
4. Align Product Design With Circular Requirements
EPR doesn’t prescribe what your products should look like. But it rewards the ones that play well with end-of-life systems.
That means:
- Avoiding hard-to-recycle blended materials
- Designing for disassembly and repair
- Using mono-material constructions where possible
- Integrating recycled or bio-based content
- Labelling clearly for sorting and reuse
These decisions, once siloed under “sustainability”, are now compliance-relevant. The sooner design teams are looped into EPR implications, the better.
This is where eco-modulation becomes a real lever: designing smarter means paying less.
Explore how the EU’s Ecodesign for Sustainable Products Regulation is reshaping fashion for a circular future →
5. Pilot Collection, Repair or Resale Schemes
Even if you’re relying on a PRO, it’s worth building internal experience with product return systems.
That could mean:
- Take-back pilots in key markets
- Repair or refurbishment services
- In-house resale or partnerships with recommerce platforms
Customers are increasingly looking for ways to dispose of garments responsibly. And brands that offer circular services build trust while gathering valuable reverse logistics data.
Plus, in a few years, these initiatives may no longer be optional.
6. Set Up an Internal EPR Taskforce
EPR cuts across departments. No single team can manage it alone. That’s why leading brands are establishing cross-functional working groups to coordinate readiness.
Your task force might include:
- Sustainability/CSR – policy tracking, strategy
- Legal/Compliance – registration, reporting, risk
- Product/Design – circular material guidance
- Supply Chain/Logistics – market allocation, traceability
- Finance – cost modelling and fee planning
The job of this group is to manage compliance, yes, but it’s also to identify opportunities, prevent duplication, and build systems that are fit for the future.
7. Monitor the Landscape and Stay Ahead of It
Laws are being passed, revised, and challenged in real time. New markets are entering the conversation. Targets are tightening. Fee models are evolving.
For brands, staying passive isn’t a neutral position — it’s a liability.
Build the habit of horizon-scanning. Subscribe to legislative trackers. Join working groups. Share learnings across your supply chain. And above all, recognise that policy is moving faster than many brand systems are built to handle.
How to Turn EPR Into Opportunity
It’s easy to see EPR as another regulatory burden. Another set of forms to file. Another fee to pay.
But if you zoom out, the opportunity becomes clearer.
Build Traceability That Does More Than Tick Boxes
EPR demands data. But that same data—weight, material composition, market volumes — also fuels:
- More accurate impact assessments
- Smarter production planning
- Stronger supplier accountability
- Clearer sustainability reporting
Brands that build traceability systems for EPR will be better positioned to handle what’s coming next: digital product passports, carbon disclosures, SBTi FLAG Targets, deforestation-free sourcing regulations. Compliance becomes the foundation for competitiveness.
Strengthen Supply Chain Resilience
As brands shift towards traceable, circular inputs, they begin working more closely with suppliers, forging longer-term relationships based on shared standards, not just lowest cost.
That stability matters, especially in a world of climate shocks, shipping volatility, and rising material scarcity. A supply chain built for circularity is often a supply chain built for resilience.
Click here to learn more about how to decarbonise fashion supply chains →
Win Consumer Trust, With Proof, Not Promises
Today’s consumer has heard it all. Sustainable. Conscious. Carbon-neutral. But they’re increasingly sceptical, and more interested in actions than adjectives.
EPR gives brands a way to show, not tell:
- Clear product take-back systems
- Real-world end-of-life solutions
- Transparent disclosures on material flows and recovery rates
It’s not about the language on the swing tag. It’s about closing the loop in public view and letting the system do the talking.
Click here to learn how you can use Green Claims Directive for sustainability marketing →
Shape the Standards While They’re Still Being Written
Brands that move early don’t just comply — they help define what good looks like.
Whether through industry coalitions, feedback to regulators, or pilot schemes that prove new models, early adopters have leverage. They can push for harmonised reporting formats, fairer fee structures, or recognition of high-performing design.
Waiting means following. Acting now means leading.
What comes next is up to the industry. Build systems that only do the bare minimum, and this will feel like just another compliance cost. Build systems that work for business, for design teams, for customers, and for the planet, and the return goes far beyond regulation.
Conclusion
Extended Producer Responsibility isn’t a future scenario. It’s unfolding now — in legislation, in supply chains, and in the shifting expectations of customers, regulators, and partners alike.
What started as an environmental policy has become something more: a structural signal that fashion’s business model must evolve. Not gradually. Not voluntarily. But through measurable, enforceable systems that hold brands accountable for the full lifecycle of what they produce.
Yes, EPR brings new pressures — financial, operational, strategic. But it also creates rare clarity in a sustainability landscape that’s often clouded by vague goals and inconsistent standards.
For brands ready to engage, this is a moment to move:
- From fragmented reporting to integrated traceability
- From surface-level sustainability claims to systemic action
- From short-term compliance to long-term advantage
Because EPR is not just about regulation — it’s about rebalancing fashion’s responsibilities. And those who respond with purpose, rigour, and readiness won’t just keep pace. They’ll set it.
