The European Union is transitioning to a circular economy model for the textile industry. It has acknowledged the significant environmental impacts of textile production and consumption. It has also stated that there is a need to move away from the linear ‘take, make, waste’ model. Recent changes to EU legislation are giving effect to the objectives identified in the EU’s 2022 Strategy for Sustainable and Circular Textiles.
At a national level, Ireland is going in the same direction. The Irish Government published the National Policy Statement and Roadmap on Circular Textiles 2026 – 2028 in April 2026. This document aims to facilitate a shift in consumer and producer behaviour.
Important changes are in force since July 2026, which operators in the textile sector will need to be aware of.
We have summarised some of the key legislation and policy changes.
Extended producer responsibility for textiles and footwear
A targeted revision of the Waste Framework Directive (WFD) came into effect on 16 October 2025.
The key changes are:
- Mandatory Extended Producer Responsibility (EPR): All EU Member States are required to establish EPR programmes for textile and footwear products. Textile and footwear producers will be required to pay a fee per product they put on the market. This fee will finance collection systems and the re-use, recycling and disposal of products. EPR fees will not be fixed. They will be “eco-modulated” according to sustainability standards including durability and recyclability.
- Uniform definition of “waste”: The WFD aims to prevent the illegal export of waste under the pretence of “reusable” goods. It therefore, requires that all separately collected textiles are considered “waste” until they undergo professional sorting operations.
Member States have been given until June 2027 to transpose these rules into national law. EPR schemes must be fully established in Member States by April 2028.
Ban on destroying unsold goods and related disclosures
The Ecodesign for Sustainable Products Regulation (EU)[1] (ESPR) was adopted in July 2024. The ESPR introduced the general principle of prevention of destruction of unsold consumer goods. Supplementary measures were adopted by the European Commission on 9 February 2026 to give further effect to this prohibition.
The destruction of unsold clothing, accessories and shoes is prohibited for:
- Companies other than medium, small and microenterprises from 19 July 2026
- Medium-sized enterprises from 19 July 2030
The ban does not apply to micro and small enterprises. There are also certain, specified exceptions where destruction is permitted. These may include, for example:
- Product safety issues
- Damage, or
- Unsuitability for resale/reuse
Companies are also required to disclose the volumes of unsold goods that are destroyed. This information must be made available on their website and included in any sustainability reporting.
The obligation to disclose this information is already in force for large companies and will apply to medium-sized enterprises from 19 July 2030.
The disclosure obligation does not apply to micro and small enterprises.
Digital Product Passport
The ESPR also introduces an obligation for textile apparel products placed on the EU market to be accompanied by a Digital Product Passport (DPP). The DPP must be accessible online at the point of sale. It also must be physically present with the product itself, for example a QR code on the packaging.
The obligation to prepare the DPP will apply to economic operators placing a product on the EU market, such as:
- Manufacturers
- Producers, or
- Importers
However, other operators in the supply chain such as distributors or suppliers may be required to ensure the DPP is made available to the consumer. They may also need to provide information necessary for the DPP.
The intention behind the DPP is to make product information more readily accessible and transparent. This includes information on sustainability and the traceability of materials.
The precise information requirements and deadlines for DPPs will be set out in further EU legislation. This legislation is expected in late 2027.
National Policy Statement and Roadmap on Circular Textiles
The National Policy Statement and Roadmap on Circular Textiles 2026 – 2028 was adopted in April 2026. It focuses on reducing excessive production and consumption while promoting the more efficient and effective management of new and used materials, and prioritising reuse and repair.
It sets out 33 actions to be taken by a range of actors and support organisations operating in the textile industry in Ireland. This includes:
- Public sector bodies
- Regulators
- Textile operators
- Civil society
- Industry, and
- Retailers
Potentially the most impactful action in the Roadmap is the commitment to establish an EPR scheme for textiles. The scheme will be in line with the new EU requirements outlined above. The proposed timeline for this is Q2 2028. We would expect the Government to consult the industry on the details of this scheme before it is further progressed.
Those operating in the textile sector need to be aware of the transition to a circular textiles economy. They also need to understand the legal measures being introduced to support that transition. It will be important to keep up to date with legislative changes and the policy developments that inform them.
For more information and expert advice on the circular economy and what this could mean for your business, contact a member of our Planning & Environment team.
Upcoming webinar
Does this topic affect your business? We will host a webinar on Recent and upcoming sustainability legal requirements for products on Thursday 22 October from 11:00am-12:00pm, via Zoom. Our expert speakers will examine the latest legal developments, including digital product passports, greenwashing enforcement, extended producer responsibility obligations for the textiles sector and the new Packaging and Packaging Waste Regulation.
The content of this article is provided for information purposes only and does not constitute legal or other advice.
[1] 2024/1781