FEAD position: prioritising post-consumer waste in textile eco-design targets

FEAD, the European Waste Management Association representing the private waste and resource management industry across Europe, warmly welcomes the JRC Preparatory Study on eco-design for textiles. FEAD recognises this initiative as a crucial milestone in properly defining the importance of eco-design and addressing what is currently not working in the textiles sector, thereby strengthening circularity and sustainability.

Recycled content must be limited to post-consumer textiles

The eco-design criteria for textile products will be the first in a long series of requirements to be developed and proposed in the coming years and may therefore set an important precedent for subsequent product groups. For this reason, we believe it is essential that the criteria, especially those relating to recycled content, comply with European legislation and, above all, address the main problem of textile circularity, namely management of post-consumer waste.

In particular, alignment with the Waste Framework Directive (WFD) is crucial. According to Article 3 of the WFD, ‘waste’ means any substance or object which the holder discards or intends or is required to discard. This definition – including the distinctions between post-industrial, pre-consumer, and post-consumer textile waste – should be consistently reflected in the JRC Preparatory Study on eco-design for textiles to ensure legal clarity and regulatory coherence.

Post-industrial textile waste is generated during the manufacturing of fibres, yarns, fabrics, and confectioning, including off-cuts, roll ends, defective materials, and unsold products that never reach the market. Pre-consumer textile waste arises primarily at the retail stage, including unsold, obsolete, damaged, or returned products that have not been used by consumers. However, both post-industrial and pre-consumer streams are often intended for reincorporation in  production processes or  redistribution and are often classified as by-products, not fully meeting the WFD criteria for waste.

By contrast, post-consumer textile waste consists of textile products discarded after use by households or commercial and industrial end-users. This stream is highly heterogeneous and represents the fraction most in need of proper end-of-life management and stronger market demand for recycled output.

Therefore, FEAD strongly supports limiting recycled content definitions and targets to post-consumer textile waste only. Extending recycled content to post-industrial or pre-consumer streams would dilute the effectiveness of circularity, merely encouraging process optimisation that in many cases is already taking place and would weaken incentives to invest in genuine recycling solutions. Restricting recycled content to post-consumer textiles ensures that eco-design requirements address real waste management challenges, avoid distorted incentives to generate avoidable waste upstream, and effectively promote circularity at the end-of-life stage of textile products.

Likewise, FEAD does not identify significant market barriers for recycled PET used in the production of new textile products and fibres. Demand for recycled PET remains strong due to established recycling technologies and economic viability.

Once again, for recycled content targets, the focus should be placed only on post-consumer textile waste, as this addresses one of the key weaknesses in textile circularity. Recycled content requirements are a targeted policy tool designed to correct market failures, and post-consumer textiles, due to their higher treatment costs and lower market uptake, are precisely the segment that most requires such support.

Recycled content must be supported by market-stabilising measures

Although covering a fundamental role, recycled content targets alone cannot succeed in the current market context. Europe’s post-consumer textile collection, sorting, preparing for reuse, and recycling operators are facing severe economic pressure due to low demand for second-hand textiles and recycled fibres, competition from low-cost imports, and rising management costs.

While EU-wide Extended Producer Responsibility schemes for textiles are the right long-term solution, their implementation will take time. Interim support measures are therefore essential to preserve existing collection and sorting capacity and ensure that post-consumer feedstock remains available for future recycled content obligations. Among these:

• Temporary financial support to sustain collection, sorting, and recycling operations until Extended Producer Responsibility (EPR) schemes are fully operational.
• Tax incentives and VAT reductions for reuse, repair, and recycling activities to stimulate demand for recycled textiles.
• Investment in sorting and recycling infrastructure to expand processing capacity within the EU and ensure quality and traceability of post-consumer feedstocks.
• Support for research and innovation in textile sorting and recycling technologies, including exemptions to permit restrictions for small-scale R&D.

FEAD remains committed to supporting the development of effective eco-design requirements for textiles and stands ready to engage further with the European Commission, the JRC and other stakeholders. Ensuring that recycled content definitions drive the recycling of post-consumer textile waste will be key to building a truly circular textile value chain in Europe.

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be