EU textile rules move forward as Recycling Europe calls for mandatory recycled content
Recycling Europe Textiles (formerly EuRIC Textiles) has presented a detailed position on the European Commission’s upcoming ecodesign delegated act for textile products. The organisation views the delegated act, developed under the Ecodesign for Sustainable Products Regulation (ESPR), as a key tool to drive circular practices in the textile sector.
The group argues that the European textile system faces significant pressure, shaped by a growing volume of low-quality textile waste, limited demand for recycled fibres, and financing gaps in the sector. The obligation for all EU Member States to separately collect used textiles from January 2025 adds to the strain, as does the rapid rise in ultra-fast-fashion consumption. Without measurable demand for recycled textile fibres, large volumes risk being landfilled or incinerated instead of returned to production cycles
Recycling Europe Textiles sets out several actions it believes the EU should adopt: a focused definition of recycled content, mandatory and staged recycled-content targets, strong verification and traceability rules, and use of the Digital Product Passport (DPP) to share reliable information with authorities and consumers.
Prioritising post-consumer textile waste generated in Europe
The organisation urges the Commission to adopt a narrow definition of recycled content. In particular, it argues that materials from open-loop sources such as PET bottles often imported should not count, as this does not support fibre-to-fibre recycling. The position paper cites the European Commission’s existing statement that the use of PET bottles for apparel is not aligned with the dedicated closed-loop system designed for food-grade plastics
Post-consumer textile waste (PCTW) generated in Europe is presented as the priority. It makes up around 85% of all textile waste in the region, which means focusing on this stream is central to improving end-of-life management. Mandatory separate collection rules starting in 2025 are expected to increase both collected volumes and the amount of non-reusable clothing available as feedstock for recycling.
The paper also examines the role of post-industrial textile waste (PITW). Recycling Europe acknowledges that PITW remains important for recyclers today because of its consistency and lower contamination levels. It supports the use of PITW as a transitional supply source but stresses that long-term policy should avoid measures that increase PITW generation. Pre-consumer textile waste, including unsold goods, can be included within the definition, though the group emphasises that these items must follow the waste hierarchy and be reused whenever possible before entering recycling streams
Mandatory recycled-content requirements
Recycling Europe supports binding requirements for recycled content in textile products and suggests using a “portfolio approach” during the early years. Under this model, companies measure recycled content across all their textile products placed on the EU market, based on the previous financial year. The organisation notes that this offers flexibility while aligning with Corporate Sustainability Reporting Directive (CSRD) obligations.
After 2030, Recycling Europe recommends shifting fully to product-level requirements, making sure each single textile item placed on the EU market includes a minimum share of recycled fibres.
The paper proposes the following timeline for mandatory targets:
• By 2028 – 10% recycled content, with 40% of that amount sourced from European PCTW.
• By 2030 – 15% recycled content, with 60% sourced from European PCTW.
• By 2035 – 30% recycled content, with 85% sourced from European PCTW.
The organisation proposes revising these targets every two years and adjusting them by fibre type when needed. It also stresses that recycled fibres originating outside the EU should meet conditions equivalent to those applied within the EU, in line with the revised Waste Shipment Regulation
Strengthening traceability and verification through the DPP
The paper highlights the need for a verification system that is credible and workable for industry. It supports a hybrid model combining chain-of-custody systems and mass-balance accounting. Chain-of-custody tools, already used in several textile certification schemes, track material flows but currently lack visibility at early stages such as collection and sorting of PCTW. Recycling Europe therefore calls for investment and harmonised standards to reinforce upstream traceability.
Mass-balance accounting can be used where physical segregation of recycled and virgin materials is not technically possible. The organisation argues that combining these approaches will reduce the risk of misleading claims and provide clarity for regulators.
Recycling Europe also proposes that the Digital Product Passport should include:
• The quantity of recycled content in each product
• The specific waste category used (PCTW, PITW, or pre-consumer waste)
• The country where the recycled material reached end-of-waste status
These measures aim to support enforcement and offer users transparent information on material origins
Recycling Europe Textiles concludes that mandatory recycled-content targets are one of the most effective policy measures available for shifting Europe’s textile supply chain toward circular fibre use. The group sees an opportunity for the EU to reduce raw-material dependence, expand textile-recycling capacity, and support a stable recycling industry. It commits to working with the European Commission as the delegated act is finalised and encourages policymakers and industry stakeholders to back a strong and coordinated approach to ecodesign requirements across the textile sector
