Recycling Europe Textiles (formerly EuRIC Textiles) – the textile reuse and recycling branch of Recycling Europe – welcomes the European Commission’s forthcoming delegated act on ecodesign requirements for textile products under the Ecodesign for Sustainable Products Regulation (ESPR), as a critical opportunity to introduce forward-looking and impactful measures that can drive circularity in the European textile sector.

Mandatory ecodesign requirements for recycled content are essential to structurally shift the textile value chain towards circularity and to strengthen the recycling industry. This is particularly urgent at a time when the European textile collecting, sorting and recycling industry is under severe pressure due to an oversupply of low-quality textile waste, insufficient demand for recycled textile fibres, and funding gaps. This unprecedented textile waste challenge Europe faces is further exacerbated by the obligation to separately collect used textiles as of January 2025, and by rising clothing consumption driven by ultra-fast fashion. Without a corresponding market demand for recycled fibres, increasing volumes of these materials risk being incinerated or landfilled rather than reintegrated into new textile products.

Well-designed mandatory recycled content requirements will send strong and credible signals to the market, create predictable demand for recycled fibres, and unlock investments needed scale-up the many promising textile sorting and recycling technologies across Europe: To achieve this, Recycling Europe Textiles calls on the European Commission to:

1. Adopt a narrow and targeted definition of recycled content that prioritises European-sourced post-consumer textile waste (PCTW), excludes open-loop sources like PET bottles, and discourages the generation of post-industrial textile waste (PITW).

2. Introduce (progressive), mandatory recycled content requirements, starting with EU portfolio-level targets and transitioning to product-level targets from 2030:

• 10% by 2028 (of which 40% derived from EU-generated PCTW),
• 15% by 2030 (of which 60% derived from EU PCTW),
• 30% by 2035 (of which 85% derived from EU PCTW).

3. Ensure robust and credible verification of recycled content through a hybrid system combining mass balance accounting, chain of custody models, and strengthened traceability, especially at the PCTW collection and sorting stages.

4. Leverage the Digital Product Passport (DPP) to enhance traceability and consumer information by requiring disclosure of the quantity, type, and origin of recycled content.