After many delays, the EU Waste Framework Directive (WFD) is now close to formal adoption (expected in the autumn of 2025), and businesses in the EU food, textile and footwear sectors must prepare for a regulatory overhaul that will reshape how they think about a product’s end-of-life. The Directive brings producer accountability to the core of EU waste policy, but despite the document now being finalised, many important questions remain unanswered.
In this article, we focus on the textile and footwear aspects, taking a deeper look at what has been decided — and more importantly, what hasn’t. As usual, our team’s expert analysis also comes with practical recommendations for businesses looking to prepare, engage, and lead.
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Understanding the WFD Revision and its Context
Originally adopted in 2008, the EU Waste Framework Directive established the principles and priorities for waste management in the EU, as a way to safeguard both the environment and human health. This ground-breaking policy introduced key concepts such as the polluter-pays principle – which places financial responsibility on producers for the end-of-life management of their products – and the waste hierarchy.
As detailed in our initial analysis of the WFD Revision when it was proposed in 2023, the legislative update was designed to bring major changes to improve circularity in the food and textile sectors, which are among the bloc’s most resource-intensive industries.
Regarding textiles, the central aspect of the Directive is that it obligates Member States to establish Extended Producer Responsibility (EPR) schemes for textile and footwear products within 30 months of the Directive’s entry into force (~Q2 2028).
The final agreement outlines a broad scope for these new EPR rules, which will apply to:
- Clothing and accessories
- Home textiles (e.g. blankets, bed linen, curtains)
- Footwear
- Leather items and headwear
The Role of Producer Responsibility Organisations
Producer Responsibility Organisations (PROs) have an essential role in the implementation of the WFD’s guidelines. In a nutshell, PROs are legal entities appointed by producers to operationalise and fulfil their EPR obligations. They also manage fee collection, reporting to competent authorities, and public awareness campaigns.
Key Measures & Definitions Established by the WFD
The revised WFD introduces a new set of rules and important definitions that significantly expand the responsibilities of textile and footwear producers across the EU.
Mandatory EPR for Textiles and Footwear
Through EPR schemes and their financial contributions, producers — which include manufacturers, importers, distributors, and online retailers — must fund the several processes and initiatives related to the end of life of the products they place on the market of a Member State.
The EPR fees collected will cover the costs pertaining to:
- Collection, transport and treatment of used textile and footwear products
- Sorting, preparation for reuse, recycling and other recovery operations
- Consumer awareness and information campaigns
- Data collection, reporting and R&D for sustainable design and waste management.
Additionally, producers may have to foot the bill associated with handling textile waste that ends up in mixed municipal waste (up to the Member State to decide on that).
Refined Scope and Definitions
The Directive has been refined to determine that producers are responsible for EPR fees only in the Member State where a product is likely to become waste. Products leaving a Member State before sale or becoming waste are not subject to EPR contributions. This distinction is important to avoid double payments but will require careful tracking.
Producers are also not required to pay fees for unsold products, although they must report the quantity of such goods to PROs.
Registration and Reporting Obligations
The Directive obligates producers to register in each Member State where they sell products. While the format will be harmonised by the European Commission, for now, registration remains country-specific. The Commission has also been tasked with creating a central platform linking all national registers to facilitate the registration process.
According to the WFD, producers must report annually to PROs on:
- Products placed on the market (included in weight)
- Amounts of collected unsold goods
While the remaining reporting requirements set out in the political agreement will fall under the responsibility of the PRO (e.g. reuse and recovery rates), micro-Enterprises (businesses with fewer than 10 employees and an annual turnover of less than €2 million) will benefit from a simplified reporting scheme and a one-year delay in full obligations lasting until Q2 2029.
EPR Fees and Eco-Modulation
The WFD introduces a two-tier eco-modulation system:
- EU-level modulation aligned with the Eco-design for Sustainable Products Regulation (ESPR)
- National-level criteria based on fast fashion practices.
The Commission will harmonise the criteria that Member States may look at to define this second type of eco-modulation, but the text proposes the following criteria:
- Product variety
- Offer frequency
- Repairability
- Product longevity
- Contribution to the circular economy (e.g., via recycling or recycled content)
The Gaps Within the Revised WFD
While the revised WFD represents a major step forward, the final text still leaves several important aspects unaddressed (such as unclear definitions), some of which could create significant risks and challenges for businesses operating across the EU.
Nevertheless, many of these gaps can also be seen as opportunities for advocacy by the industry, allowing stakeholders to further influence and shape the legislation.
Reporting Harmonisation
Producers must submit detailed data to PROs annually, yet no EU-wide template or reporting frequency has been agreed. This could lead to a patchwork of national systems and increase compliance burdens for producers.
However, secondary legislation like the Implementing Act sets the reporting schedules from PROs to competent authorities. The structure and format of these reports could offer an advocacy opportunity to push for harmonised reporting requirements from producers to PROs.
Eco-Modulation Criteria
The WFD introduces a two-part eco-modulation system: one based on harmonised EU-level criteria under the ESPR, and another based on fast fashion practices defined by each Member State. While the ambition to reward more sustainable business models is welcome, the Directive does not specify how these two layers will be defined, and lacks clarity on how criteria will be measured, verified, or enforced across Member States.
Until the Commission adopts an implementing act, fragmentation is likely. Some Member States may act early, while others delay or take no action. Without a harmonised system in place, the incentive for sustainable performance is weakened, potentially undermining efforts to promote more circular and environmentally responsible business practices.
Governance of PROs
The WFD allows Member States to choose between single, multiple, or state-run PROs. Although private competition is encouraged, Member States can decide to establish state-run PROs and future guidelines are expected regarding the criteria and competences of such PROS.
What’s Next for the EU Waste Framework Directive?
Although the revised WFD has reached its final form, much of its practical impact will depend on how it is implemented over the next few years. Several important legislative steps remain, including the adoption of secondary legislation as well as national-level rollout of EPR schemes.
Below is a timeline of what comes next and when businesses should be ready to act.
Q4 2025
- Final WFD text to be adopted by the European Parliament in plenary and by the Council of the EU. The Directive enters into force 20 days after its publication in the Official Journal.
Q2 2027 (18 months after entry into force)
- Commission to adopt a harmonised format for producer registration across Member States.
- A central EU website will link to all national producer registers.
Q2 2028 (30 months after entry into force)
- All Member States must have operational EPR schemes in place for textiles and footwear.
3 Strategic Next Steps For EU Brands
As always, our best advice is for businesses to engage in the policymaking process and get involved in shaping what happens in Brussels. However, our experts have also prepared three key recommendations tailored specifically to the WFD:
1. Define Your Position on Eco-Modulation Before It’s Set for You
With eco-modulation rules still in development, now is the time to define where your brand stands. Clarify your position on both ESPR-based criteria and fast fashion indicators, such as product variety, release frequency, and repairability. Assess what you can currently measure and where key gaps lie. This internal clarity will strengthen your ability to engage with the European Commission as it prepares implementing acts, and to advocate for fair, harmonised, and workable fee structures alongside industry peers.
2. Influence National Decisions During the Transition Phase
Until EU-level harmonisation is in place, Member States can define eco-modulation criteria and other EPR obligations independently. This means you should coordinate with PROs, industry associations, and policymakers in the countries where you operate to help define how fees, reporting obligations, and collection systems are applied. Use insights from existing schemes to push for clear, consistent, and efficient systems. Early engagement will help avoid fragmented approaches that could increase costs and complexity later on.
3. Push for Clarity on Reporting and PRO Governance
Despite imposing extensive obligations, the WFD does not provide clear EU-wide rules on how producers must report data or how PROs should be governed. For that reason, businesses should look to advocate for harmonised reporting templates and schedules through upcoming implementing acts, and support the establishment of minimum standards for PRO transparency and performance. Without clear rules, businesses may face inconsistent demands and limited insight into how their fees are used.
Key Takeaways
The revised Waste Framework Directive marks a major policy shift for textiles and footwear in the EU, and with implementation details still evolving, now is the time for brands to take action and position themselves strategically. Companies that engage early will not only be better prepared but also help shape the systems under which they will be operating for years to come.
If you need expert guidance navigating the WFD, defining your advocacy priorities, or preparing for other upcoming legislation, simply get in touch. Our team of specialised consultants will help you develop and implement a strategy tailored to your goals, while also protecting your business from costly missteps.