Transitioning to a circular textile economy requires a balanced approach that aligns regulatory mandates with industry realities. The T-REX (Textile Recycling Excellence) project, a consortium of 13 industry leaders, committed to developing a blueprint for a harmonised EU framework for textile-to-textile recycling, has highlighted critical challenges and opportunities, advocating for policies that promote innovation while ensuring compliance.
- A white paper brought out thereafter, Advancing Textile Circularity: Policy Recommendations for Implementing ESPR in the EU, outlines the core insights from the T-REX Project policy roundtable and provides strategic recommendations for policymakers to facilitate a robust and sustainable textile recycling ecosystem in the EU.
- Funded by the EU’s Horizon Europe programme, the project demonstrates textile-to-textile recycling for polyester, polyamide 6, and cellulosic materials while exploring systemic solutions to scale recycling and engage citizens in circularity efforts.
KEY RECOMMENDATIONS: T-REX Project’s Recommendation for the Future of ESPR has revealed fundamental challenges in the EU’s textile circularity infrastructure that regulation must help bridge.
- Without investment in advanced sorting technologies, recycling technologies, and the missing pre-processing stage, circularity at scale remains out of reach.
- Pre-processing of textile waste feedstock is essential for chemical recycling, yet no players in the value chain are fully addressing this need. Existing infrastructure is insufficient to handle the complexities of textile waste, making it challenging to meet future recyclability and recycled content targets.
- EU regulations, particularly ESPR or Ecodesign for Sustainable Product Regulation and Waste Framework Directive, must take a strategic approach to support the entire value chain—from design, collection, and sorting to pre-processing and recycling—so that commercial infrastructure can scale effectively. Without this, the industry will struggle to integrate recycled materials into new textile products at the necessary volume.
- Mandatory recycled content quotas, clear eco-design guidelines, and investment in sorting and preprocessing infrastructure are critical to ensuring textile circularity's technical and commercial feasibility.
- Additionally, ESPR must provide a regulatory framework that fosters innovation rather than imposing premature restrictions that may hinder progress.
- As EU policies are shaped, eco-design requirements must acknowledge technological and infrastructural constraints. Regulations must balance recyclability criteria and broader industry needs, ensuring that requirements do not unintentionally create trade-offs that hinder progress.
- ESPR’s role in reducing textile waste must align with the circular economy hierarchy, establishing a clear and consistent framework for defining recyclability, supporting all recycling technologies, and mandating the inclusion of recycled content in textiles.
- Against this background, the feedstock for recycled content should not be artificially restricted. It should come from different types of textile waste (including post-consumer, post-industrial, and pre-consumer waste). The feedstock origin needs to be cleared, traced and included in data shared for transparency. This framework must be backed by comprehensive research and industry collaboration to avoid regulatory measures that stifle innovation.
- Standardised definitions of recyclability, mandatory product-level performance criteria, and transparent information requirements are necessary to ensure regulations drive real impact rather than adding complexity without practical outcomes.
- Policymaking must also account for the global nature of textile waste flows.
- The EU should mandate minimum recycled content in clothing regardless of waste origin, as the industry depends on international trade in unsorted textile waste.
- Additionally, regulations should not impose unnecessary restrictions on recycling technologies or chain-of-custody models beyond existing certification standards, such as Textile Exchange’s RCS/GRS. Credibility in circularity policies requires a focus on recycling with verifiable recycled content and feedstock origin.
- EU regulations must actively engage innovators and industry stakeholders to drive meaningful change, ensuring policies reflect real-world capabilities and constraints.
- Regulatory frameworks should remain flexible to accommodate advancements in recycling and material innovation rather than locking the industry into rigid standards that could become obsolete.
- Suppose trade barriers or taxes are introduced for textiles from non-EU regions. In that case, they must specifically target products that fail to meet EU environmental and social responsibility standards rather than creating blanket restrictions that could disrupt supply chains. By addressing these gaps, policymakers can ensure that regulation acts as an enabler—rather than a bottleneck—for textile circularity, allowing innovation, investment, and sustainable practices to scale effectively across the industry.
THE BACKGROUND: In November 2024, the T-REX Project policy roundtable convened key stakeholders from across the entire value chain, along with EU policymakers and research institutes, to address the challenges and opportunities within ESPR, a key pillar of EU textile legislation, focusing on recyclability, recycled content targets, sorting mechanisms, and infrastructure development.
- ESPR aims to set sustainability performance and information requirements, including recyclability, recycled content, durability, and repairability.
- However, clear, practical provisions and reliable verification methods are needed to ensure compliance without stifling innovation. ESPR’s recyclability requirements will mandate that textiles are designed for easier recycling, discouraging complex material blends that hinder sorting and processing.
- Additionally, recycled content targets will drive the use of secondary raw materials, reducing reliance on virgin resources and fostering a circular economy.
- For the apparel sector, these requirements present both an opportunity and a challenge, as the industry must integrate recycled content while addressing supply chain constraints, limited availability of recycled fibres, and the need for scalable recycling technologies.
- By acting early, the EU textile industry can gain a competitive advantage in sustainable practices, setting a global precedent.
- By adopting these recommendations, the EU can establish a globally leading textile recycling ecosystem, supporting the principles of circularity and long-term sustainability.
