The T2T Alliance, an initiative dedicated to driving the global scaling of innovative textile-to-textile recycling technologies, has come up with recommendations on how to structure recycled content requirements and verification in the ESPR Delegated Act for textiles to accelerate circularity, prevent unintended bottlenecks, and ensure closed-loop recycling technologies can scale.
- In its first Position Paper on recycled content ecodesign requirements in the ESPR Delegated Act on textiles, the T2T Alliance has shared its perspective on mandatory product-level recycled content thresholds, a powerful policy lever to accelerate circularity across the EU textile sector.
Outlining why ambitious but realistic thresholds, aligned with current and scaling industry capacity, are essential to unlock demand for recycled materials and enable textile-to-textile recycling to scale, it suggests:
- Include post-industrial waste alongside ESPR-compliant pre-consumer- and postconsumer waste in the definition of recycled content: While the EU Commission’s approach to defining recycled content as closed-loop recycled material recognises the need to tackle post-consumer waste in the EU and globally, the current definition of ‘recycled content’ including only post-consumer waste overlooks critical realities of the textile recycling industry: sourcing exclusively from post-consumer textiles waste as of 2028 is not feasible. Without a recycled content requirement that allows sourcing from all possible textile waste streams globally, the necessary capacity of recycled material cannot be secured and the T2T industry will not be able to scale efficiently.
- The position paper suggests including post-industrial waste alongside ESPR compliant pre-consumer waste and post-consumer waste in the definition of recycled content. In addition, it asks for all types of textile waste, including but not limited to, carpets, airbags, tire chords, industrial material etc to be included in the definition of ‘textile waste’ to encourage application of innovative technology.
- This could provide the direly needed time for post-consumer waste management infrastructure to scale.
- Set ambitious but realistic, gradually increasing performance requirements for recycled content at the product level, namely 10% by 2028, 15% by 2030 and 30% by 2035: Brands must be given the flexibility to creatively design their products, but product-level recycled content thresholds are critical to ensuring sufficient capacity to drive the transition to a circular economy. This transition can only succeed if robust thresholds are introduced and progressively increased over time. To make sustainable products the norm, recycled content performance requirements must be both ambitious and realistic. It recommends setting the following minimum thresholds for recycled content at the product level:
- 10% by 2028
- 15% by 2030
- 30% by 2035
The 2028 recycled content requirement should be limited to commercially scaled fibres, with application to other fibres, including nylon 6 and 6,6 from 2030.
- Implement a flexible but robust verification system that leverages Chain of Custody (CoC) combined with mass balance approaches and traceability tools: To effectively enforce recycled content requirements, it is essential to implement a robust yet flexible verification system that accommodates different operational realities across the value chain. A combination of Chain of Custody (CoC) and mass balance accounting approaches (as defined by ISEAL5) offers a practical and scalable solution. Without the integration of mass balance, the textile sector risks fragmented regulations, competitive disadvantages, and barriers to achieving circularity. In addition, emerging digital technologies are enhancing the traceability and authentication of recycled content. As industries increasingly adopt advanced digital tracking systems, these tools will play a key role in providing additional layers of credibility and assurance.
- It urged the European Commission to adopt a clear, flexible and robust verification framework that integrates mass balance accounting as a core component, supported by Chain of Custody models and traceability tools.
- Introduce an information requirement for recycled content that supports enforcement and ensures traceability, including the origin country of recycled content, waste type and quantity Information requirements and performance requirements must go hand in hand: Without clear, traceable data on the recycled content within products, verifying compliance becomes difficult and trust among stakeholders weakens. While performance requirements create the necessary market demand for recycled materials, information requirements provide the critical data needed to monitor progress, verify compliance, and validate claims to build trust among stakeholders.
- It urged for the inclusion of an information requirement that accompanies the performance requirement, to ensure full transparency on the type, origin and quantity of recycled material in each product.
- Moving forward, it also encouraged the EU authorities to continue and deepen collaboration with key industry stakeholders like the T2T Alliance that play an integral part in supporting companies to comply with the ESPR Delegated Act on textiles and in meeting the EU’s circularity ambitions.
ABOUT: The T2T Alliance - Powering Policy for a Textile-to-Textile Future brings together leading textile-to-textile recyclers such as Circ, Circulose, RE&UP, Syre and Samsara Eco, to advocate for policies that enable a truly circular textile industry. By actively engaging with EU policy making, the Alliance strives to be the go-to organisation for policy recommendation affecting T2T recycling, driving the global scaling of innovative
