Textile EPR in Europe faces safety challenges over PPE and medical waste
As European countries begin enforcing extended producer responsibility (EPR) for textiles under Directive (EU) 2025/1892, a growing concern is emerging from across the value chain. Several major industry bodies say the current approach risks creating confusion and, in some cases, serious safety issues.
EDANA, representing the nonwovens sector, has joined forces with CIRFS, ESF, EURATEX, and EuroCommerce to issue a joint statement calling for urgent clarification from the European Commission. Their message is clear: not all textiles should be treated the same under EPR rules.
The problem with one-size-fits-all classification
At the core of the issue is how textiles are defined and classified. The combined nomenclature (CN) codes referenced in the directive do not distinguish between everyday clothing and specialized products such as personal protective equipment (PPE) or medical devices.
This matters because PPE and medical textiles are designed for high-risk environments. Hospital gowns, protective coveralls, masks, and safety footwear often come into contact with chemicals, pathogens, or other hazardous substances. Once used, many of these items are legally classified as hazardous waste.
For safety reasons, such products are typically incinerated, often with energy recovery, rather than recycled. Treating them like ordinary post-consumer textiles ignores both their purpose and their risk profile.
Health and environmental risks
The joint statement warns that mixing contaminated PPE with regular textile waste could lead to cross-contamination during collection, sorting, and processing. This puts workers, recyclers, and the environment at risk.
Existing EU waste law already addresses this issue. Articles 13, 17, 18, and 19 of the Waste Framework Directive set clear rules for handling hazardous waste. Folding PPE and medical devices into standard textile EPR systems creates overlap and potential conflict with these established safeguards.
Limited environmental benefit
Data shared by the signatories also challenges the environmental logic of including PPE in textile EPR schemes. PPE accounts for less than 1 percent of total textile waste, and around 80 to 90 percent of it is considered hazardous.
Even the remaining non-hazardous portion offers limited recycling value. Large-scale transport would be required to collect enough material, reducing any environmental gains from recycling.
Safety footwear adds another layer of complexity
Safety footwear presents its own challenges. Like other PPE, these products are exposed to contamination. Reuse raises questions about hygiene, liability, and compliance with safety standards. Manufacturers also point out practical issues with EPR fee structures, especially for heavy items such as steel-toed boots, where costs remain unclear.
Gaps in national implementation
While the directive itself states that products posing safety or hygiene risks should be excluded, this principle is not being consistently applied at national level. The statement highlights Spain and the Netherlands as examples where PPE and medical textiles are still being drawn into textile EPR schemes.
A call for clear guidance
The industry groups are asking the European Commission to step in with clear, practical guidance for member states. Their request is straightforward: confirm that products covered by the PPE Regulation (2016/425) and the Medical Devices Regulation (2017/745) fall outside the scope of textile EPR.
Without this clarification, well-intended sustainability policies risk undermining safety, increasing regulatory confusion, and placing unnecessary burdens on sectors that already operate under strict waste and safety rules.
For textile sustainability to work, the rules must reflect how different products are actually used, handled, and disposed of. Treating protective equipment like everyday clothing is not only impractical, it may also be unsafe.
