German Trade Bodies Propose EPR for Textiles, Footwear

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Three major German retail trade associations have unveiled a concept paper proposing a ‘practical and experience-based’ approach for implementing an extended producer responsibility (EPR) framework targeted at the textiles and footwear industries.

The associations involved include the German Retail Association (HDE), the Textile, Shoes and Leather Goods Trade Association (BTE), and the Foreign Trade Association of German Retailers (AVE). Together, these organisations represent a wide range of key businesses with significant interests in private label goods.

The proposal is inspired by existing EPR systems for managing packaging waste, as well as for the collection and recycling of electrical equipment and batteries.

The central aim of the initiative is to identify established and effective strategies from these systems that can be adapted to the textile and footwear sectors. The associations acknowledge that any successful EPR initiative for these industries must account for the unique and complex nature of their products.

“Successful take-back systems have already been developed in recent years, for example for packaging, waste electrical equipment and batteries. This can now be built upon in the development of a system for implementing extended producer responsibility for textiles and shoes,” said Stefan Genth, general manager of HDE.

Genth also underscored the importance of drawing from the lessons learned in existing systems, with a focus on creating processes that can be easily implemented by businesses of all sizes within the textile and footwear sector.

“Due to the corporate structure in the textile and shoe sector, there is a need for specifications that are easy to implement for all market participants, regardless of company size,” Genth added.

Key aspects of the concept paper:

  • Framework and Objectives: The proposal outlines the establishment of an effective EPR system aimed at reducing fabric waste while promoting reuse and recycling.
  • Regulatory Guidelines: It stresses the necessity of consistent EU-wide regulations, ensuring member states follow the same requirements without introducing additional national laws. In Germany, this includes clear standards and responsibilities for stakeholders involved in production, collection, and sorting, verified through audits.
  • Centralised Oversight: The associations propose a unified national standard in Germany for the approval and regulation of EPR systems, ensuring consistency in operations.
  • Role of Intermediaries: The document emphasizes the need for well-defined roles, standards, and monitoring mechanisms for agents, as well as enforceable penalties to prevent misuse.

Why an EPR framework is crucial for Germany:

The EU’s textile strategy mandates the establishment of separate collection systems for used textiles and clothing by 2025. This initiative is part of a broader effort to create a standardised EPR framework across all EU member states.

The proposed EPR system for textiles and footwear aims to hold producers, importers, and retailers accountable for the entire lifecycle of their products, including end-of-life management and recycling. To fund this initiative, a fee will be levied on distributors to cover the costs of collection and recycling.

Germany’s trade associations stress the importance of crafting legislation that addresses the complexities of the textile sector while complying with the European Waste Framework Directive. They emphasize the need for German laws to align seamlessly with EU regulations, ensuring a cohesive and efficient system at both the national and European levels.

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