Everything the footwear industry should know about new European textile waste regulations

This past Sunday, July 19, the European ban on destroying unsold clothing, accessories and footwear came into force. This is the first visible measure of the Ecodesign for Sustainable Products Regulation (ESPR), which directly affects the fashion industry.

This ban is just the tip of a broader regulatory change that will, sooner or later, affect any company operating in the European market. The measures initially apply to large companies, defined as those with 250 or more employees and a turnover of 50 million euros, according to the most widespread interpretation. The regulation will be extended to medium-sized companies in July 2030. Micro and small businesses are currently exempt. From the weekend, surplus stock that was previously destroyed must be channelled into donation; resale; reuse; or recycling as part of the ESPR. This is officially known as Regulation (EU) 2024/1781, which has been in force since July 2024 and is gradually taking its final form.

The next major development is the introduction of extended producer responsibility (EPR) for textile and footwear products across the European Union. While the framework is European, its implementation will take place through national systems, creating a regulatory landscape that companies operating across multiple markets will need to navigate.

To clarify this regulatory landscape and delve into the implications of the future application of EPR to textile and footwear products, the Federation of Spanish Footwear Industries (FICE) has organised a webinar for companies in the sector. The event was held in collaboration with Gerescal, the collective extended producer responsibility scheme (SCRAP) for footwear and textiles based in Elche. What follows is a practical guide based on their explanations, with a particular focus on how the European framework is being translated into national systems.

What is EPR and why is it happening now

The core of the new framework is extended producer responsibility (EPR). This principle shifts the cost of managing the waste generated by products at the end of their life to companies. Until now, this management was the responsibility of public administrations and, therefore, the citizen. EPR returns it to the entity that places the product on the market, under the “polluter pays” principle.

The trigger is a reform of the European Waste Framework Directive, Directive (EU) 2025/1992, which has been in force since October 16, 2025. This reform made EPR for textiles and footwear mandatory in all member states and started the countdown for its national implementation. The ultimate goal is to reduce the volume of fashion waste ending up in landfill and to push the sector towards a circular economy and ecodesign.

Julia Villaplana, head of projects and European regulations at FICE, stressed that the challenge is greater in footwear than in textiles due to the technical complexity of recycling a shoe, which is composed of multiple bonded materials.

"It's not the same to recycle a shoe as it is to recycle a T-shirt,"

The European framework must be translated into national legislation through individual implementation processes. In Spain, this will be done through a specific royal decree that is not yet in force. It is currently in the TRIS procedure, the European system that checks whether a national regulation creates unjustified barriers in the single market. Villaplana expects the Commission to give its approval in September, barring any objections, and for the law to come into full force in Spain in 2027.

The first declaration must be submitted before February 2027. In it, liable companies will have to provide a detailed account of what they commercialised the previous year, which will be the basis for calculating the eco-tax and eco-modulation.

Smaller companies have an additional grace period. Those with fewer than ten employees or a turnover of less than two million euros will have 12 months to prepare and register once the regulation comes into force. It is important not to confuse this threshold with that of the ESPR's destruction ban, which is governed by different limits.

Who is affected

The obligation applies to producers and marketers of footwear and textiles in the markets where national EPR systems are implemented. The specific scope and obligations can vary according to national legislation. Francisco Javier Rico, head of business development at Gerescal, detailed several relevant clarifications for SMEs in the sector based on the Spanish system.

Bespoke footwear and very specific professional or sports uses, such as skiing, are excluded. Leather goods are also not currently included in this royal decree. The ancillary industry—manufacturers of components such as insoles or soles—has its own industrial waste management and is not required to join, as it does not place a finished shoe on the market.

Large corporations exceeding 2.5 percent of the quotas will assume additional obligations, with specific ecodesign programmes to meet legal targets. Most SMEs in the sector do not fall into this bracket.

What companies will have to do

For companies bound by EPR regulations for textiles and footwear, there are four fundamental steps.

• Register with the relevant national producer registry, following the existing model for packaging.
• Join a SCRAP (Collective Extended Producer Responsibility Scheme).
• Periodically submit the corresponding declarations.
• Contribute financially through an eco-modulation system, the amount of which will depend on the product's weight, its durability, the ecodesign criteria applied and the volume the company places on the market.

The system aims for specific targets for separate collection, in public containers or in the stores themselves. Rico stated the target is 30 percent by 2030, compared to the 12 percent that is currently collected separately in Spain. In practice, this would mean almost tripling the current collection rate, as well as increasing reuse with stricter criteria and activating post-consumer waste recycling.

Control will be supported by municipalities and their recycling centres; retailers; social economy operators, who are key to collection and sorting in Spain; and online platforms, which will have to verify producer registration. Rico anticipated customs filters similar to those already applied to electrical appliances.

Eco-tax

During the webinar, they explained that the contribution will function as a ring-fenced fee set by the SCRAP. National systems are developing at different speeds, with France cited as an example and benchmark in this area due to its more mature market. There, the cost currently ranges between 8 and just over 20 cents per pair depending on the product's weight and type, with more developed eco-modulation criteria. Spain has a progressive margin until 2030 and is estimated to start with slightly lower amounts.

Rico recommends that manufacturers start incorporating this cost into the pricing of their spring/summer 2027 collections. In the future, the fee must be reflected on the invoice, as is already the case with packaging, which could create commercial friction if it is passed on to the customer after the price has been agreed.

What if I export to multiple markets?

This is the biggest headache for what is an essentially international sector. Each country has its own SCRAP, its own deadlines and its own declaration format, and there is not yet a single European registry.

“France is a decade ahead with Refashion, its benchmark SCRAP,” the experts explained during the session. “The Netherlands has EPR for textiles and Lithuania has also made progress. Spain and Norway are among the most advanced, with implementation expected next year, while Germany is still working on its draft and would follow about a year later.” The deadline is the same for everyone, however. By April 2028, all member states must have their SCRAPs operational.

Gerescal, along with other European schemes, is pushing through Euratex for a coordination office in Brussels to harmonise declarations and eco-modulation criteria and to move towards a “one-stop shop” that would allow a single registration to be valid throughout the Union. As long as this model does not exist, some consultancies are already managing registration in the various national SCRAPs for an additional fee.

The rule for brands is to declare in the countries to which they send the product directly to the end consumer, for example, through their own store or online sales. When the sale is channelled through a marketplace that acts as an importer—Rico used the example of Zalando invoicing from Germany—the responsibility for joining and declaring falls on the platform, not the brand.

Beyond the nuances, the general criterion is clear. The brand owner who places the product on the market must assume compliance and payment of the eco-tax. This includes multi-brand chains that import foreign products or manufacture private labels, as they act as importers or producers and are equally obligated.