An EPR System for Textiles in Germany: Setting the Right Course Now

The introduction of an Extended Producer Responsibility (EPR) system for textiles in Germany draws closer, bringing a valuable opportunity to shape a key lever for advancing circularity in the textile industry. At RLG, with many years of experience in return systems, we view a well-designed EPR framework as a regulatory requirement and a strategic tool to help transform the textile sector. 

This text summarises the key recommendations from our recent position paper, “Towards a Circular Economy for Textiles: Recommendations for a Robust EPR System.” In it, we outline concrete steps for designing a competitive and practical EPR system for textiles in Germany. We shared this paper with the German Ministry for the Environment and key political decision-makers. 

Return Systems as Drivers of the Circular Economy 

A future-ready textile EPR system must go beyond simply collecting, sorting, and recycling used textiles. Return systems should actively support the development of circular business models and embed circular economy principles, starting with design and extending through reuse and recycling. Only then can we meaningfully reduce the environmental impact across the entire lifecycle of textiles. 

Competition Fosters Innovation 

We strongly advocate for a competitive model with multiple return systems. Competition drives efficiency, stimulates innovation, and contributes to higher collection and recycling rates. Manufacturers and retailers also benefit from being able to choose between different systems, often finding more cost-effective solutions, unlike under a monopolistic model. 

EU Harmonisation Is Essential 

Germany’s EPR system should be aligned with European legislation, particularly the upcoming EU Waste Framework Directive revision, to avoid market distortions and unnecessary complexity. Harmonised definitions and scopes are critical to ensure effective implementation and cross-border comparability. 

Collection Must Be Efficient and Accessible 

A functioning EPR system must offer practical, consumer-friendly return options. We recommend a multi-pillar collection model: 

• In-store returns at retail locations where textiles can be collected separately 

• Recycling centres (Wertstoffhöfe) should continue to play an important role, financed by the return systems, as is the case for batteries 

• Exemptions for small retailers: Shops with limited sales areas should not be obligated to offer returns 

• Inclusion of charitable organisations such as the German Red Cross, Caritas, or Texaid, which already have infrastructure and experience, on the condition of transparent volume tracking and integration into the overall return system