Common Approach to EPR Policy Design a Must to Solve Global Waste Crisis, Asserts New Study

A report by Ellen MacArthur Foundation outlines a shared direction of travel and the opportunity for Extended Producer Responsibility (EPR) to create ambitious outcomes that accelerate the circular economy transition.

Long Story, Cut Short
  • EPR is a crucial policy tool to ensure discarded textiles are collected and put back in circulation at scale.
  • EPR systems need to align around the same key objectives while setting targets that reflect a specific understanding of the national and local context, stakeholder landscape, and infrastructure availability.
  • To date, four countries have adopted EPR policy covering textiles — France, Hungary, Latvia and the Netherlands.
EPR is a performance-based regulation in which specific outcomes and objectives are set and defined by law, and so are the roles and responsibilities of stakeholders involved in delivering on these (such as obligated producers, local governments, charities, and non-profit operators).
The Right Regulation EPR is a performance-based regulation in which specific outcomes and objectives are set and defined by law, and so are the roles and responsibilities of stakeholders involved in delivering on these (such as obligated producers, local governments, charities, and non-profit operators). Cottonbro Studio / Pexels

A comprehensive circular economy approach is the only solution that can match the scale of the global textile waste problem. And today, the economics for separate collection and recirculation do not stack up—this is a key barrier to achieving a circular economy for textiles, says a report by the Ellen MacArthur Foundation.

  • The report—Pushing the boundaries of EPR policy for textiles—written for policymakers, aims to contribute to this emerging policy conversation, outlining a shared direction of travel and the opportunity for Extended Producer Responsibility (EPR) to create ambitious outcomes that accelerate the circular economy transition.
  • Proposing a common approach to EPR policy design, the report says that to achieve a global circular economy national EPR systems need to align around the same key objectives, while setting targets that reflect a specific understanding of the national and local context, stakeholder landscape, and infrastructure availability. In addition, alignment around common definitions and stakeholder involvement is crucial to the effectiveness of EPR policy.
  • As the regulatory process for EPR development takes years to come to fruition, businesses should not wait to accelerate progress and turn circular economy ambitions into demonstrable action.
  • Coordinated and compounding industry action is needed to challenge the linear economic model at its core, and to capture the full value opportunity by keeping products and materials in use for as long as possible.

SUGGESTIONS TO FIX A LEAKY SYSTEM: Establishing and expanding separate collection infrastructure for textiles is a necessary part of the solution.

  • To divert textiles from landfill, incineration, or leakage into the environment, it is crucial to build collection infrastructure at scale.
  • Collection infrastructure for discarded textiles is underdeveloped and does not capture all textiles in the system. Separate collection is the only way to keep textiles out of municipal solid waste streams.
  • To establish separate collection systems at scale, structural funding is needed to cover the net cost associated with managing all discarded textiles, not just the fraction with high market value. Where separate collection systems are in place, they are largely funded through the reusable clothing fraction, which is traded all around the world. This market-driven system faces significant pressure, and will not achieve further expansion nor material capture unless dedicated funding is put in place to cover the cost.
  • Spending on infrastructure should be a balancing act, examining short-term needs and longer-term considerations.
  • Sorting facilities need to expand their operations and need further investment in machinery and equipment.
  • A combination of demand and supply-side measures is needed to deliver textile-to-textile recycling at scale, and drive down the industry’s demand for virgin resources.

THE CONTEXT: The global debate on textile waste and pollution by focusing on EPR policies is a necessary part of the solution to achieve a circular economy for textiles.

  • EPR is a crucial policy tool to ensure discarded textiles are collected and put back in circulation at scale.
  • To date, four countries have adopted EPR policy covering textiles (France, Hungary, Latvia and the Netherlands).
  • EPR policy for textiles is currently debated and/or proposed in a range of other countries and regions (including Australia, Ghana, Kenya, Colombia, California, New York, and all EU Member-States).
  • The data modelling and analytics included in this report focus on selected countries (including Chile, European Union Member States, Ghana, India, Kenya, Tunisia, and the USA), chosen due to the significant role they play in the trade of used textiles, as well as the existence or ongoing development of EPR policy for textiles in these countries
  • The focus of this report is on discarded textiles, i.e. textiles that are discarded by citizens and enter a form of waste management (waste collection or uncontrolled disposal). These textiles may or may not have reached the end of their useful life at the point of disposal.

UNDERSTANDING EPR: In this report, EPR refers to mandatory, fee-based EPR schemes. The OECD defines EPR as an environmental policy approach in which a producer’s responsibility for a product is extended to the post-consumer stage of the product’s lifecycle.

  • Under EPR legislation, businesses that place products on the market (“obligated producers”) become responsible for managing their products when these are discarded by consumers. In the context of textiles, obligated producers are typically brands, retailers, and online marketplaces that place clothing, footwear, and household textiles on the market.
  • The responsibility imposed on these producers may be financial, organisational, or both.
  • EPR is a performance-based regulation in which specific outcomes and objectives are set and defined by law, and so are the roles and responsibilities of stakeholders involved in delivering on these (such as obligated producers, local governments, charities, and non-profit operators).
  • Generally, companies can fulfil their responsibility individually, by putting in place their own collection, sorting, reuse, and recycling systems, or collectively, by joining efforts to establish a shared system.

PRODUCER RESPONSIBILITY ORGANISATIONS (PROS): In a collective EPR scheme, obligated businesses delegate their responsibility (fully or partially) to a third party.

  • Typically — but not exclusively — the third party is a joint PRO, which fulfils obligations for the in-scope products on the businesses’ behalf, and coordinates the activities identified as within the scope of such a body.
  • The legally obligated businesses pay the PRO, in order to cover the necessary expenses for achieving the legally required outcomes and objectives.
  • The PRO is normally funded through fees that each obligated producer pays to the PRO. Such an EPR scheme can be referred to as a fee-based EPR scheme.
  • The scope, design, and operating methods can vary across countries.
  • In fee-based EPR schemes, the funding remains ring-fenced and dedicated to the after-use management of the product and related activities (such as data-gathering and support to R&D).

WHAT THEY SAID:

We are developing an EPR policy for plastics, which will be expanded to textiles and other material streams over time. The common approach proposed in this report is certainly in the right direction, and I expect that all countries will pursue a minimum level of alignment with the approach. To eliminate textile waste, countries at both the import and export ends of the used textiles trade must collaborate more closely.

— Oliver Boachie
Special Advisor, Minister of Environment, Science, Technology, and Innovation
Ghana

Textile waste is a significant contributor to the climate crisis. But right now, we don’t have sufficient infrastructure to responsibly manage discarded clothing and increasing amounts of textile waste, and our existing systems do not support consistent, convenient, or widespread collection needed to incentivise the reuse and recycling of textiles. That’s why we need comprehensive policy to make the economics work for textile reuse, repair, and recycling. Particularly, EPR offers an opportunity to do just that while holding the textile industry responsible for its role in the system.

—  Chellie Pingree
Congresswoman
US Congress 

France has an important legacy of EPR policy for textiles, as our textiles EPR scheme has been in place since 2008. In recent years, we have been working to evolve our EPR system beyond collection and sorting operations, towards stimulating circular business models with a particular focus on repair and recycling. This way, EPR helps ensure products are used longer before being discarded. Moving forward, EPR should continue to evolve and should address the fate of used textiles after exportation. For example, EPR presents a significant opportunity to enhance transparency and traceability on the used textiles trade. By doing so, it can help ensure that in the future, we only export products to markets where demand and capacity exists to reuse textiles and manage them after use. 

Léonard Brudieu 
Deputy Head for Circular Economy, Ministry for Ecological Transition
France

In Chile, our ambition is to expand our EPR legislation to include textiles — a process we’d like to kickstart in 2025. The minimum objectives set out in this report are a relevant starting point. In Chile, EPR for textiles will not only improve separate collection and sorting but will also support increased local reuse, by including tailors and small upcycling businesses as EPR fund recipients. Additionally, EPR can deliver positive social impacts by training, involving, and integrating informal workers, building on our experience with the packaging EPR system. But we cannot recycle our way out of Chile’s high per-capita textile consumption. While EPR may not be the only solution, it is an important part of the broader effort to shift towards a circular economy.

— Tomás Saieg
Chief, Circular Economy Office, Ministry of Environment
Chile

In 2023, EPR policy for textiles entered into force in The Netherlands. Throughout the development of this policy, and from the many stakeholders we consulted, we learnt that while EPR is essential, EPR alone is not sufficient to achieve a circular economy. Other policy measures such as ecodesign are needed. Still, EPR is an important part of the toolbox of policies that can help reduce the volumes of textile waste generated. There is room to further develop EPR policy in line with principles of the circular economy, by giving more attention to circular design, reuse, and repair.

Marije Slump
Senior Policy Advisor (Circular and Sustainable textiles), Ministry of Infrastructure and Water Management
Netherlands

Textile and plastic waste and fragments represent one of the biggest environmental problems related to pollution and biodiversity loss in the world. A large volume of plastics is hidden in other products, such as textiles and packaging. That is why it is important to expand debates on these products and their appropriate disposal to reduce pollution.

Adalberto Maluf
National Secretary (Urban Environment and Environmental Quality), Ministry of Environment and Climate Change
Brazil

 
 
  • Dated posted: 27 September 2024
  • Last modified: 27 September 2024