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Statement on the key points paper of the Federal Ministry for the Environment on the introduction of extended producer responsibility (EPR) for textiles
The Clean Clothes Campaign has published a recent statement on a key point paper for a draft law on extended producer responsibility, which should involve fast fashion manufacturers in the disposal and recycling costs. A textile law must stop exploitation and environmental destruction by the textile industry!
To the background
On 16 October 2025, Directive 2025/1892 amending Directive 2008/98/EC (Waste Framework Directive) entered into force. It introduces extended producer responsibility for textiles at European level. The requirements are to be implemented in Germany by a new textile law.
In preparation for the legislative process, the Federal Ministry for the Environment, Climate Protection, Nature Conservation and Nuclear Safety has published a key points paper. The key points paper presents the objectives, the central regulations and the obligations of the different actors for the collection and disposal of old textiles within the framework of the future Textile Act.
The campaign for clean clothing, of which FEMNET is a member, welcomes the key points paper of the Federal Ministry for the Environment on extended producer responsibility (EPR) for textiles As a first step, but sees a considerable need for improvement. The close focus on waste management is particularly critical, while central problems such as human rights risks in supply chains, overproduction and fast fashion business models remain largely hidden.
The Opinion on the Key Issues Paper was sent to the Ministry on 22 April 2026.
Our concrete demands on the government:
- An effective polluter-pays principle must be based on: Going beyond ecological aspects and also social costs internalize. Extended producer responsibility should take into account existing Human Rights Due Diligence be interlocked. In addition, a mechanism for human rights Impact assessment be installed.
- The intended effect on Fast fashion business models must not be squandered by subordinate qualitative criteria and insufficient financial differentiation of ecomodulation.
- The key points paper allows manufacturers to set up their own producer responsibility organisations. This entails considerable Conflicts of interest. The independent control can only be fulfilled by governmental or quasi-governmental producer responsibility organisations.
- Representatives of workers in the countries of production and actors from importing countries of used goods have so far no access to design processes, but are centrally affected by the effects of the EPR. An extension of the planned Commission to: Perspectives from the Global South is therefore absolutely necessary.
- Lack of consideration Global responsibility. A part of the obligatory producer amounts should therefore be converted into a Transformation funds It supports decent working conditions and mitigates negative effects in the producing and importing countries of old textiles.
- The introduction of mandatory transparency tools is a key prerequisite for effective monitoring e.g. by civil society organisations and for the effectiveness of extended producer responsibility.
Without these elements, the EPR threatens to miss its steering effect and perpetuate existing grievances. The Federal Government is called upon to substantially strengthen the existing key points in the further legislative process and to further develop extended producer responsibility into an effective instrument for a comprehensive socio-ecological transformation of the textile sector.
contact
Aika Fischbeck, Clean Clothes Campaign,
Dr Gisela Burckhardt, FEMNET e.V.,
Dr. Jiska Gojowczyk, SÜDWIND Institute,
