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Sorting For Circularity Europe: An Evaluation And Commercial Assessment Of Textile Waste Across Europe

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Key European Policy Levers To Sort For Circularity

The policy landscape for the end-of-use of textiles across Europe has been progressively changing over the past decade. In 2007, France introduced the first mandatory Extended Producer Responsibility (EPR) scheme for clothing, linen and footwear in a European country, obliging producers to provide for or contribute towards the end-of-use management of items placed on the market,79 and has banned the destruction of unsold goods from 2022 onwards.80 Further, the 2018 revision of the EU Waste Framework Directive (2008/98/EC) has established that all EU Member States need to ensure that systems are in place for the separate collection of discarded textiles by the beginning of 2025.81 Whilst some of the countries in focus for this report already have separate collection systems in place, like the Netherlands, others such as Spain have committed to fully establishing separate collection of textile waste from 2024 onwards.82 Several institutions have also published guidance documents on this matter at national or regional level for the UK,83 Germany (Länder Baden-Württemberg, North Rhine-Westphalia and Saxony),84 and the EU.85

 

Following these developments, other countries in Europe are establishing their EPR systems, including the Netherlands by 2023. The UK is currently working on draft legislation for EPR which, regrettably, has been postponed for the time being.86 Nonetheless, the issue is gaining traction in the country, with the Prime Minister recently pledging £80 million in support of the Fashion Industry Sustainable Change Programme, a long-term initiative that aims to promote and improve textile sorting and recycling infrastructure amongst other areas.87 In Belgium, as of 2022, there is a private voluntary EPR platform, Circletex, which is tasked with the collection and recycling of pre and post consumer textiles.88

 

The EU Strategy for Sustainable and Circular Textiles, launched in March 2022, builds on the 2020 EU Circular Economy Action Plan, and formulates a vision to ‘create a coherent framework for the transition of the textiles sector’ to improve durability, recyclability, repairability, as well as commit to promoting respect for social rights and health and safety.89 Initiatives under the communication include, amongst others, the introduction of mandatory Ecodesign requirements; developing transparency reporting obligations for corporations to help stop the destruction of unsold or returned textiles; the introduction of a Digital Product Passport as well as harmonised Extended Producer Responsibility rules for all Member States. Additionally, the European Commission has proposed a revision to the EU Waste Shipment Regulations, taking into account textile waste as one of the key streams where the ability and willingness to reuse and recycle this waste has to be proven by recipient countries.

 

Based on the policy landscape introduced above, we have identified the following as some of the key policy levers to foster sorting to enable circularity across Europe:

  • Ensuring local or regional sorting capacity for the increasing quantities available of PCT after 2025 in the EU. The proposition of harmonised EU EPR rules for textiles with eco-modulation of fees (under the 2023 revision of the Waste Framework Directive) becomes key to secure investment not only in collection systems but also in sorting infrastructure that allows for enough capacity for sorting used textiles in the countries or regions where they are discarded. The fee propositions may need to be revised at national levels to be in accordance with the development and implementation needs of the sectors involved.
  • The introduction of legislation at different stages of clothing and textiles life cycles to influence the potential for recycling of the non-rewearable fraction of PCT. This should encompass stages beyond the collection, sorting and recycling. For example, the introduction of mandatory ecodesign requirements (under the Ecodesign for Sustainable Products Regulation) that include a perspective on fibre-to-fibre recyclability of products may have a large impact on the use of certain types of material blends put on the European market. Minimum recycled content targets that take into account adequate product applications and functionality may serve to trigger investments in the scaling of fibre-to-fibre recycling technologies, which may lead to an increased demand for sorted textiles of certain material compositions. A green premium subsidy introduction may help reduce the price of recycled fibres as the industry scales up. This subsidy may alleviate cost pressure on recyclers and thus potentially facilitate the purchase of non renewable feedstock at prices that compete with the other commercial destinations e.g. wipers.
  • Assessing any unintended counter incentives for European textile sorting that may emerge from the establishment of mandatory targets for preparation for reuse and recycling (under evaluation by 2024 by the European Commission). The proposal of target setting for reuse and recycling activities across Europe should take into account the impact that these may have on sorting operations. The proposal must ensure that proper incentives are in place to minimise negative impacts to the business case of textile sorting, whilst stimulating sorting operations to remain in place as close as possible to the place of disposal and collection. This will be especially relevant in the light of the international used textiles trade landscape, maintaining a thriving global second-hand market where items shipped worldwide are those matching the market demand for specific trends, product types and material compositions.
  • Aligning rules for sorting criteria for reuse and recycling across the EU could help harmonise the sorting industry’s standards and requirements to prepare textiles for reuse and recycling. The European Recycling Industries’ Confederation (EuRIC) has put together a guidance document on “Textiles Handling and Sorting Specifications for re-use and recycling of used textiles90 which could serve as a basis for identifying the key process requirements to ensure adequate sorting operations. However, certain criteria are more easily aligned on than others, as the sorting industry also serves dynamic and changing market demands. For the non-rewearable fraction, introducing end-of-waste criteria to include sorted used textiles by material composition as feedstock for recycling processes would further support the global development of fibre-to-fibre recycling of post-consumer textiles.
  • Considering how digital labelling and product passports will enhance material traceability efforts in the long term for the end-of-use textiles value chain given that today’s textiles will, on average, only reach a sorting facility in 4 years time. Structured and accessible data on material composition and substances of concern are essential pieces of information for non-rewearable sorted textiles that will become input for recyclers. Nonetheless, until these tracking and tracing technologies and practices reach scale at the end-of-use, the practical application of them for sorters and recyclers will be minimal. However, with a clear outlook of what the future legislation may require, upskilling and technological investments can be planned in due time at EU and national level, making sure the sorting industry can adapt to changing traceability standards.