Position paper - Response to the consultation on the Proposal for a Revision of the Waste Framework

The European Commission’s proposal to revise the Waste Framework Directive (WFD) rightly aims at reducing food waste as well as better managing textile waste in a more circular and sustainable manner.

The proposal is a welcome step towards establishing circularity for textiles by including mandatory extended producer responsibility (EPR) for textiles, incentives for the development and uptake of fibre-to-fibre recycling technologies, alignment with other EU legislation such as the Eco-design for Sustainable Products Regulation (ESPR) and emphasis for the need to develop end-of-waste criteria for textiles to support further recycling processes.

To allow for swifter implementation, avoid internal market fragmentation and ensure the scalability of sustainable innovation across the EU, the revision should carefully take into account the following recommendations:

• Including a review clause for the Commission to assess targets three-years following the creation of the EPR scheme and collection point.
• Ensuring a realistic timeline, at least 36 months, following the Member State adoption for the establishment of EPR schemes.
• Designing eco-modulation criteria that strike the right balance between encouraging environmental improvements and not overwhelming companies with administrative complexities.
• Clarifying the different kinds of collection points and sorting obligations.
• Ensuring coherence with other pieces of legislation.