Spotlight: Recycling Crisis

Policy Patchwork: How Regulatory Gaps Are Sabotaging Europe's Circular Textile Ambitions

Despite separate textile collection becoming mandatory across EU member states from January 2025, fragmented implementation and enforcement gaps undermine circular economy progress. Industry experts reveal how regulatory inconsistencies and misaligned policies are preventing meaningful recycling outcomes across European markets.

Long Story, Cut Short
  • Infrastructure limitations and regulatory fragmentation prevent effective textile waste collection despite ambitious EU targets.
  • Digital Product Passport requirements must include end-of-life data to enable sorting and recycling processes.
  • Landfilling remains cheap and accessible, undermining incentives for recycling investment across European markets.
A  diffusion of responsibility prevents coordinated action and enables continued inaction. Brands blame inadequate infrastructure, recyclers cite insufficient feedstock quality, governments point to industry resistance, and consumers expect affordable options without understanding environmental costs.
Who's responsible? A diffusion of responsibility prevents coordinated action and enables continued inaction. Brands blame inadequate infrastructure, recyclers cite insufficient feedstock quality, governments point to industry resistance, and consumers expect affordable options without understanding environmental costs. AI-Generated / Sora

This Spotlight series on textile recycling is timed with the Textiles Recycling Expo 2025 being held in Brussels, Belgium on 4–5 June 2025. texfash is a Media Partner for the event. 

The numbers, the news reports, the social media outrages—all indicate Europe's textile circularity ambitions are facing a fundamental implementation crisis. Some insist that things are not working, others believe that they are, but not to the extent desirable.

Despite generating enormous waste volumes and setting increasingly aggressive recycling targets, the gap between policy aspirations and practical outcomes continues to widen.

The European Union's commitment to separate textile collection by January 2025 represents just the latest example of ambitious regulations struggling with fragmented implementation across member states.

This disconnect reflects deeper systemic failures in how Europe approaches textile waste management. Regulatory frameworks often assume infrastructure and market conditions that don't exist, while enforcement mechanisms remain weak or inconsistent. The result is a patchwork of policies that create compliance costs without delivering meaningful environmental benefits, frustrating stakeholders across the value chain.

The stakes extend beyond sheer environmental concerns. With Europe accounting for 29.4% of the global textile recycling market, regulatory failures undermine the continent's competitive position in emerging circular economy sectors. Addressing these gaps requires honest assessment of implementation challenges and coordinated action across multiple policy domains rather than continued expansion of aspirational targets without supporting infrastructure.

The System-Level Failures

The disconnect in question—that between Europe's textile waste generation and recycling capacity—reflects multiple overlapping failures across infrastructure, regulation and market design. These systemic deficiencies are precipitating a situation where ambitious policy goals remain largely theoretical rather than practically achievable.

Tetiana Pushkarova, Development Manager at Re:inventex, identifies the fundamental challenge: "We see this disconnect as the result of multiple, overlapping shortcomings. Infrastructure for collecting and sorting post-consumer textiles remains limited and underfunded, particularly in handling blended or non-standardised materials."

The infrastructure deficit is particularly acute in Eastern European markets. Despite proximity to major Western European consumption centres, collection and processing capabilities remain much to be desired. This geographic imbalance is creating inefficient material flows and is limiting the effectiveness of EU-wide circular economy policies.

Regulatory fragmentation compounds these infrastructure challenges. "Regulatory fragmentation, such as inconsistent implementation of Extended Producer Responsibility across countries, creates uncertainty and slows progress," Pushkarova explains. Different EPR schemes, collection requirements, and enforcement approaches across member states prevent the development of coherent, continent-wide recycling systems.

However, Pushkarova acknowledges the industry's role in perpetuating these problems: "Many producers, especially in lower-cost manufacturing regions like Ukraine, Turkey, and parts of Asia, still prioritise price and speed over environmental compliance, often because buyers do not demand otherwise."

This market-driven resistance to sustainability investments reflects deeper economic incentives. Without consistent enforcement or consumer demand for circular products, manufacturers face competitive disadvantages when investing in more sustainable practices. The result is a race to the bottom that undermines policy objectives.

Consumer behaviour represents another crucial factor often overlooked in policy design. "Another factor often overlooked is consumer behaviour. Buyers expect affordability, durability, and performance - preferences that favour blended fabrics. Yet very few consumers are ready to pay more for sustainable products," Pushkarova notes.

This consumer resistance creates market conditions that work against circular economy policies. Without demand for recycled materials or willingness to pay premiums for sustainable products, brands have limited incentives to invest in circular supply chains, regardless of regulatory requirements.

Luna Aslan, Project Manager at Noosa, emphasises the coordination challenges: "EU legislation is slow and there's no harmonised systems between countries. Many players hesitate to invest in harmonised systems due to uncertain ROI and the complexity of coordinating across diverse stakeholders and regions."

The lack of harmonisation creates particular challenges for companies operating across multiple European markets. Different regulatory requirements, collection systems, and enforcement approaches increase compliance costs while reducing economies of scale for recycling infrastructure.

Pushkarova identifies a fundamental attribution problem: "It's a system where each part passes responsibility to another. We believe change must come from all sides: regulatory action, business accountability, and cultural shifts among consumers."

This diffusion of responsibility prevents coordinated action and enables continued inaction. Brands blame inadequate infrastructure, recyclers cite insufficient feedstock quality, governments point to industry resistance, and consumers expect affordable options without understanding environmental costs.

Chloé Salmon Legagneur
Chloé Salmon Legagneur
Director
Cetia
Koen Warmerdam
Koen Warmerdam
Co-founder and Brand Director
Aware
Luna Aslan
Luna Aslan
Project Manager
Noosa
Tetiana Pushkarova
Tetiana Pushkarova
Development Manager
Re:inventex

The Digital Product Passport Solution

The European Union's Digital Product Passport (DPP) initiative represents a potentially transformative approach to addressing traceability challenges in textile recycling. However, current proposals may miss crucial opportunities to enable effective end-of-life management without proper implementation requirements.

Chloé Salmon Legagneur, Director of CETIA, believes in mandatory inclusion of recycling-relevant data: "Make it compulsory for the Digital Product Passport to include information essential to managing the end-of-life of products (the accurate composition of textile and trims, number of accessories, assembly methods, etc.)."

This information requirement addresses a fundamental challenge facing recyclers and sorters. Without accurate composition data, automated sorting systems cannot effectively route materials to appropriate processing pathways, leading to contamination and reduced efficiency.

The technical implementation of DPP systems requires careful consideration of durability requirements. Salmon Legagneur plays up the need for persistent identification: "[Authorities should] Ensure that this information is still present in garments at the end of their life (by providing financial support for the use of RFID threads for example)."

Moreover, traditional labelling approaches often fail during garment use, washing and ageing. RFID threads or other durable identification methods could maintain data accessibility throughout product lifecycles, enabling effective sorting and recycling even for aged garments.

Koen Warmerdam, Co-founder and Brand Director of Aware, supports comprehensive data infrastructure: "Verified data from fibre to finish would streamline operations, reduce loss, and unlock trust. That's the missing lever." The DPP system could provide this verification framework if properly designed and implemented.

Salmon Legagneur envisions broader applications: "Circularity requires precise traceability from raw materials to the recycled product. This could involve a unified, 'universal' database, with standardised data (common format for textile compositions). The use of QR codes or RFID could prove useful in assigning a unique identifier to each item."

The standardisation aspect is crucial for enabling interoperability across different recycling systems and supply chain actors. Without common data formats, the benefits of individual DPP implementations remain limited to specific companies or value chains.

However, DPP implementation faces significant practical challenges. Salmon Legagneur notes the complexity: "This could also help to improve logistics flows." The system must balance comprehensive data provision with practical usability for stakeholders across the value chain.

Cost considerations represent another implementation barrier. While RFID threads and comprehensive data systems offer significant benefits, the costs must be distributed appropriately across value chain actors. Government support for implementation, as Salmon Legagneur suggests, may be necessary to achieve widespread adoption.

The DPP system also requires coordination with existing regulatory frameworks. Extended Producer Responsibility schemes, waste collection systems, and recycling standards must align with DPP requirements to avoid creating additional compliance burdens without corresponding benefits.

International coordination represents a final implementation challenge. Given global textile supply chains, DPP systems must be compatible with non-EU markets and regulatory frameworks to avoid creating trade barriers or limiting effectiveness.

EPR Implementation Gaps
  • Inconsistent EPR schemes across member states create uncertainty and prevent coordinated infrastructure development.
  • Production-stage sorting requirements missing from current frameworks despite being essential for material quality.
  • Enforcement mechanisms remain weak with limited penalties for non-compliance across European markets.
  • Landfill costs remain artificially low, undermining economic incentives for recycling investment decisions.
  • Regulatory fragmentation prevents economies of scale in collection and processing infrastructure development.
DPP Implementation Musts
  • Mandatory inclusion of accurate textile composition data, trim details, and assembly method information.
  • Durable identification systems like RFID threads to maintain data accessibility throughout product lifecycles.
  • Standardised data formats enabling interoperability across different recycling systems and supply chains.
  • Government financial support for implementation costs to ensure widespread adoption across industry.
  • Coordination with existing EPR schemes and waste collection systems to avoid additional compliance burdens.

From Landfill to Leadership

Current waste management economics across Europe continue to favour disposal over recycling, undermining circular economy policies and creating perverse incentives that work against sustainability goals. Addressing this fundamental market failure requires coordinated policy intervention across multiple domains.

Pushkarova identifies the core economic problem: "One of the root issues is that landfilling is still a cheap and accessible option in many countries. Unless disposal becomes less convenient or more costly, there is little pressure to prioritise recycling."

This economic reality creates systematic bias against recycling investment. Companies naturally choose the lowest-cost disposal options, and without regulatory intervention, these choices aggregate into outcomes that contradict stated policy objectives.

The implementation challenges extend to production facilities. "One of the challenges we've encountered in practice is the difficulty of integrating textile waste sorting into the daily operations of sewing facilities. For many manufacturers, waste has traditionally been disposed of without any separation, as this didn't affect disposal costs or logistics," Pushkarova explains.

This operational reality highlights the gap between policy assumptions and workplace practices. Effective recycling requires behaviour changes throughout production processes, but these changes require training, time, and internal motivation that current economic incentives don't support.

Pushkarova turns her attention to production-stage requirements: "That's why we believe that Extended Producer Responsibility schemes should include clear requirements at the production stage. It would not only simplify the handover for recycling but also empower production teams to make a tangible contribution to reducing the environmental footprint of their operations."

This approach is in tune with the argument that that recycling begins during production rather than after consumption. By integrating sorting requirements into manufacturing processes, EPR schemes could improve material quality and reduce processing costs for recyclers.

The motivational aspects of proper implementation are significant. "With proper support and awareness, we've seen how this process can become a source of progress and even pride for responsible manufacturers," Pushkarova notes. Creating positive associations with sustainable practices can accelerate adoption beyond minimum compliance requirements.

Market instruments offer additional policy levers. "We believe stronger outcomes will depend on clearer prioritisation of recycling over landfilling in national waste policies, combined with market instruments that reward recyclability and material recovery," Pushkarova argues.

These instruments could include landfill taxes, recycling subsidies, or procurement requirements that create market demand for recycled materials. However, effectiveness requires coordination across member states to prevent regulatory arbitrage and ensure consistent incentives.

Ukraine's position as an EU candidate country offers unique opportunities. "From our position in Ukraine, we see this as an opportunity: as a candidate country to the EU, Ukraine is actively harmonising its waste and environmental legislation. Introducing landfill restrictions and setting recycling as a legal priority would help create long-term demand for circular solutions," Pushkarova explains.

This regulatory alignment process could enable more aggressive recycling policies than those politically feasible in established member states. "Ukraine offers unique strengths: a simpler regulatory environment compared to many EU countries, lower labour and operational costs, and logistical proximity to key European markets," she adds.

The potential for regulatory leadership from candidate countries challenges assumptions about policy development direction. Rather than simply adopting existing EU standards, new member states could pioneer more effective approaches that established markets could subsequently adopt.

Tailender

Europe's circular textile ambitions require fundamental alignment between regulatory frameworks and economic incentives rather than continued expansion of aspirational targets. The gap between policy goals and practical outcomes reflects systemic failures in implementation design, enforcement mechanisms, and market conditions that favour disposal over recycling. Success depends on making recycling economically advantageous while ensuring landfilling becomes more expensive and less convenient. This requires coordinated action across infrastructure development, regulatory harmonisation, and market instrument deployment. The Digital Product Passport initiative offers a pathway to address traceability challenges, but only if implementation requirements include end-of-life data and durable identification systems. Ultimately, Europe's circular economy leadership depends on closing the implementation gap rather than setting more ambitious targets.

Despite generating enormous waste volumes and setting increasingly aggressive recycling targets, the gap between policy aspirations and practical outcomes continues to widen. The EU's commitment to separate textile collection by January 2025 represents just the latest example of ambitious regulations struggling with fragmented implementation across member states.
Despite generating enormous waste volumes and setting increasingly aggressive recycling targets, the gap between policy aspirations and practical outcomes continues to widen. The EU's commitment to separate textile collection by January 2025 represents just the latest example of ambitious regulations struggling with fragmented implementation across member states. AI Generated / Gemini
 
 
 
  • Dated posted 4 June 2025
  • Last modified 4 June 2025