Footwear & EU Regulation: From Rule-Taker to Agenda Setter
Many EU laws apply to footwear, but very few were written with shoes in mind. EU sustainability rules for textiles and fashion tend to take a catch-all approach that sweeps footwear in with garments, which can leave significant gaps. With national EPR schemes taking shape and ecodesign rules being drawn up for textiles, there’s a lot to keep track of.
Why does this matter? Around 24 billion pairs of shoes are made every year. According to consultancy circular.fashion, roughly 90% of those discarded end up in landfill or incineration, and global recycling rates for textiles and footwear remain below 1%. As the organisations puts it: “footwear recycling is where apparel recycling was a decade ago”. As this blog will show, this isn’t down to a lack of ambition from industry. It’s partly because collection and recycling systems for footwear don’t exist yet, and partly because footwear has so little EU policy of its own.
Footwear is often an afterthought. It falls under a long list of cross-cutting laws yet only a handful of rules are designed for the product itself. The question for the sector is whether it will go beyond compliance and help shape the rules?
What EU rules apply to footwear today?
Among the many EU rules that apply to footwear are: the EU Deforestation Regulation (EUDR), the Forced Labour Regulation, because of the widespread use of rubber in footwear; and chemicals legislation such as REACH and the Biocidal Product Regulation also applies, as many shoes are treated to be water-repellent or antimicrobial. Footwear companies may also be subject to the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD), where they meet the applicable scope and reporting thresholds.
Unlike textiles, plastics, electronics or packaging, however, footwear has very little product-specific regulation. In practice, only three EU frameworks can truly be considered footwear-specific:
- The Footwear Labelling Directive sets out consumer information requirements on the material composition of footwear.
- The recently revised Waste Framework Directive introduces Extended Producer Responsibility (EPR) obligations for footwear.
- The Ecodesign for Sustainable Products Regulation (ESPR) covers footwear in its reporting obligations on unsold goods and the ban on the destruction of unsold apparel, clothing accessories and footwear (although it does not establish dedicated ecodesign requirements for footwear yet)
Why Footwear Is Unique
Shoes are complicated products. A single running shoe can contain up to 65 different materials and require more than 360 production steps throughout the manufacturing process. Foams, rubbers, textiles, adhesives, metals and synthetics are bonded together, which makes disassembly very difficult. As Claudia Szerakowski, Circular Strategy Consultant, circular.fashion explains: “This complexity defeats most sorting and recycling processes designed for simpler material streams.”
The features that make a shoe hard to recycle are often the same ones that help it perform. Jerome Pero, Secretary General of FESI (The Federation of Sporting Goods Industry), says that in sport and performance shoes: “Materials and components work together to deliver durability, comfort, safety and performance, and changing one element can affect the whole product. FESI wants to ensure that future requirements recognise these interdependencies and support circular innovation without compromising the functions people rely on.” Circularity rules that ignore performance and durability, risk backfiring, which is why industry is calling for rules designed specifically with footwear’s characteristics in mind
Gaps in EU legislation for footwear
The only one of these laws written solely for footwear, the Footwear Labelling Directive, dates from 1994.
The Directive sets out information requirements for footwear sold to European consumers. Footwear must display information on the composition of three components:
- the upper,
- the lining and sock, and
- the outer sole.
The label indicates the material composition through standardised pictograms. Material information must be provided for materials representing at least 80% of the surface area of the upper and lining/sock, and at least 80% of the volume of the outer sole. Where no single material exceeds this threshold, the two main materials must be disclosed. The Directive distinguishes only four material categories: leather, coated leather, textiles, and other materials.
With so many materials in a single shoe, four categories say very little about what it’s made of. Claudia Szerakowski, Circular Strategy Consultant at circular.fashion elaborates:
“Limited material transparency at the component level, making sorting and recycling guesswork; no established repair, reuse or take-back infrastructure at industry scale; and a regulatory framework such as ESPR, that is primarily being shaped around apparel, with footwear-specific considerations at risk of being overlooked or added as an afterthought.”
Waste Framework Directive: lacks bite
As part of the 2022 EU Sustainable and Circular Textiles Strategy, the revised Waste Framework Directive introduces mandatory Extended Producer Responsibility (EPR) schemes for textiles
and footwear. By April 2028, all Member States must establish collection and management systems for used textile and footwear products.
But the Directive sets no reuse or recycling targets, and it doesn’t require EPR fees to be directed towards recycling innovation. It’s therefore unclear how far producer responsibility organisations will invest in footwear-specific end-of-life solutions.
Member States are taking different approaches to footwear EPR, with varying levels of ambition. France, for example, is proposing that 45% of recycled textile and footwear waste be recycled in a closed loop by 2031 and recognises footwear as a particular challenge, while The Netherlands plans to start with dedicated footwear collection targets before moving to reuse and recycling.
Fee design matters too. Jerome Pero warns that
“EPR fees based on weight alone could penalise a durable, repairable boot simply because it is heavier than a shorter-lived fashion shoe”. FESI also wants EPR funds to help build footwear-specific collection, sorting and recycling infrastructure.”
Ecodesign: the missing piece
The revision of the Waste Framework Directive was developed alongside the implementation of the Ecodesign for Sustainable Products Regulation (ESPR), particularly for apparel. One objective is to incentivise better product design through the modulation of EPR fees based on sustainability criteria. For apparel, Member States will eventually be able to rely on harmonised ESPR ecodesign requirements to reward products that perform better. But, footwear is notably absent from the first ESPR Working Plan 2025-2030, so footwear-specific ecodesign requirements are not currently being developed at EU level, and there is no harmonised framework Member States can use to reward more sustainable footwear design. The European Commission is expected to conduct a dedicated footwear study in 2027 to determine whether footwear should be included in the 2030-2035 Working Plan. This could pave the way for footwear-specific ecodesign requirements and a Digital Product Passport (DPP).
In the meantime, any attempts to incentivise better footwear design through EPR fee modulation remain voluntary and are being driven at the national level. For instance, under Refashion’s current eco-modulation framework, footwear can benefit from bonuses when it complies with recognised environmental certification schemes, such as the EU Ecolabel, while products with features that hinder recycling may be penalised. Under the proposed reform published in July 2026, footwear containing qualifying recycled content from local recycling streams could also benefit from a bonus of €500 per tonne placed on the market.
Claudia Szerakowski, Circular Strategy Consultant, at circular.fashion, argues that:
“Footwear is not a simplified version of apparel, it is a fundamentally different product category that requires its own regulatory treatment. Policymakers risk setting targets that are technically unachievable for footwear in the near term, or inadvertently incentivising design choices that look circular on paper but create new problems in practice. The industry needs time, design standards and guidance, as well as financial incentives such as the upcoming EPR eco-modulation schemes that can provide a cushioning for the increase in quality & durability tests and certifications.”
From rule-taker to agenda-setter
Until now, footwear companies have largely focused on understanding and complying with requirements developed elsewhere. The sector is now starting to take a more proactive role and there are signs of it aiming to set the agenda through industry initiatives, research projects and stakeholder collaborations.
Examples include:
- ECOSTEP, a Horizon Europe project developing footwear-specific ecodesign methodologies, sustainability assessment tools and Digital Product Passport functionalities;
- Closing the Footwear Loop, an initiative co-led by circular.fashion and Fashion for Good, which aims to accelerate the transition towards circular footwear by developing design guidance, testing circular business models and identifying solutions to improve product circularity across the footwear value chain.
- The dedicated footwear sub-taskforce within FESI, which brings together industry stakeholders to identify common policy positions.
With national EPR schemes developing and footwear ecodesign discussions taking shape, FESI decided to bring its members’ expertise together early. Jerome says:
“The specific challenges of shoes, particularly sport and performance footwear, risk not being reflected in current textile policy discussions. We want to ensure that policies are informed by how footwear is designed, used and treated at end of life, and support realistic progress towards greater circularity.”
EU regulation for footwear: what to watch
Several decisions over the next few years will show whether footwear will get rules that fit its products. National EPR schemes must be in place by April 2028, but without EU-level targets, national choices on how fees are spent will matter a great deal. At EU level, the Commission’s 2027 study will help decide whether footwear is included in the 2030 to 2035 ESPR Working Plan, and with it the chance of footwear-specific ecodesign requirements and a Digital Product Passport. Behind all of this sits a simple question: will footwear be at the table when these rules are written, or fitted in afterwards? As FESI’s Jerome Pero puts it,
“Footwear deserves its own place in circular economy policy.”
Further reading
About circular.fashion
circular.fashion is collaborating with Fashion for Good through the Closing the Footwear Loop initiative to develop industry recommendations on footwear design. The initiative recently released a Circularity Quick Sheet outlining practical guidance and key design principles to support the transition towards more circular footwear.
About FESI
FESI is the Federation of the European Sporting Goods Industry. Its footwear sub-taskforce brings together industry stakeholders to identify common policy positions.
Resources: