Fabric of change
UK textiles industry group publishes 10-point blueprint for mandatory EPR scheme

Cross-industry coalition warns UK used textiles sector faces collapse without mandatory scheme, publishing detailed recommendations ahead of government's Circular Economy Growth Plan.

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A coalition of UK textiles industry stakeholders has published a blueprint setting out how an Extended Producer Responsibility scheme should be designed, warning that without government action the used textiles sector faces collapse.

The Blueprint for a UK Textiles EPR Scheme, published by WRAP on behalf of the UK Textiles Pact, contains 10 recommendations developed through consultation with brands, retailers, trade associations, charities and waste companies.

It highlights that without action local authority costs for dealing with textile waste could rise from £73 million to £137 million per year, increasing to £200 million by 2035. This would result in an estimated 2.5 million additional tonnes of CO2 equivalent per year from increased disposal.

The blueprint was developed through working groups and workshops hosted by the UK Textiles Pact during 2025, building on a cross-industry position statement released in summer 2025 by WRAP, the British Retail Consortium, British Fashion Council, UK Fashion and Textiles Association and WEFT.

Single PRO and eco-modulated fees

Among the key recommendations, the blueprint advocates for an industry-led scheme operated by a single non-profit Producer Responsibility Organisation with a steering committee representing the whole value chain. The document argues that a single PRO would simplify producer registration and data reporting, centralise compliance metrics, and make the scheme easier to regulate than a multi-PRO model.

On fee structure, the blueprint proposes that EPR fees should be charged per item rather than by weight. This differs from the EU approach under the revised Waste Framework Directive, which requires fees to be charged per kilogram. However, UK stakeholders expressed concern that weight-based charging could inadvertently incentivise lightweighting and reduced product durability. The recycling sector also reported that the real costs of processing are typically linked to the number of units handled rather than total weight.

While a fee-per-item approach is recommended, the blueprint says that there might need to be different fees according to product category to reflect varying processing complexity, with a pair of socks requiring less handling than a more complex item such as a jacket.

The document states that fees should be eco-modulated to reward sustainable design. During consultations, stakeholders ranked durability, recyclability and recycled content as the top three priorities for eco-modulation, followed by preferred fibres and repairability. Wider supply chain considerations such as circular business models, carbon impact and social impact were ranked as medium-term priorities for later phases of the scheme.

The blueprint also notes the importance of at least partial alignment with EU eco-modulation criteria, since many brands produce for regional markets rather than individual countries. If UK criteria diverged significantly from the harmonised EU approach, brands would likely adapt products to satisfy EU requirements across 27 member states, possibly making the UK approach redundant as it would be the smaller market, with garment manufacturers accepting the additional costs.

A UK EPR fee of 10p per garment would generate over £300 million per year, more than covering predicted waste management costs. This funding would be ringfenced for reinvestment into the scheme, with short-term priorities including domestic collection, sorting, grading and reuse infrastructure. Medium-term investment would focus on repair facilities, awareness campaigns and support for circular business models, while longer-term funding would target closed-loop fibre-to-fibre recycling and developing end-markets for recycled content.

"Urgent action is the only way to prevent charities, local authorities and consumers bearing the cost of dealing with the nation's unwanted textiles," said Jordan Girling, Head of EPR at WRAP. "The cost of inaction is greater than the cost of establishing a UK EPR scheme."

Phased product scope

The blueprint recommends a phased approach to product scope, with clothing, accessories, hats, footwear and two-dimensional household textiles such as bed sheets included from the outset. These categories already have established collection infrastructure through charity shops, textile banks and kerbside collections.

Industrial textiles and hospitality sector textiles would be brought into the scheme in a second phase. The blueprint notes that these product categories currently have minimal or no collection systems in place, and bringing them into scope immediately would generate fees without adequate infrastructure to handle the materials. The phased approach would allow collection and sorting systems to be established first, with the additional fees from scope expansion then funding that infrastructure. However, the document recommends that phase two products and their timelines should be predefined in the initial legislation to provide certainty.

Carpets and upholstered furniture should be excluded entirely, as a 2024 Defra-commissioned report indicated these products could be captured under a separate furniture EPR scheme.

Waste hierarchy and reuse prioritisation

A central theme of the blueprint is the prioritisation of reuse over recycling. The document notes that existing textile reuse channels through charity shops and platforms such as Vinted and eBay are well-established and should be preserved. It recommends that any scheme should promote increased domestic reuse rates, partly by applying financial incentives to reuse operators and supporting consumer behaviour change.

This approach would also address concerns about EPR fees inadvertently increasing product prices during the cost-of-living period, the blueprint states, as second-hand items would not be subject to EPR charges.

The UK currently sends large quantities of used textiles to countries in the Global South, which the blueprint suggests could be ‘plugged in’ via a voluntary mechanism that brands could engage with to support sustainable waste management in receiving countries. However, it notes this would require further exploratory work and should not delay implementation of the core domestic scheme.

"Implementing a textiles Extended Producer Responsibility scheme is a critical step in delivering a more circular UK fashion and textile industry," said Adam Mansell, Chief Executive of UKFT. "The Blueprint demonstrates the importance of a mandatory scheme that is co-designed with industry, balancing environmental ambition with the economic and operational realities faced by businesses."

The blueprint follows earlier industry work on variable EPR fee structures, including the EPR Sandbox Project which tested how fees could be tailored to specific product attributes. That project has since expanded to examine the impact on SMEs, which represent a significant proportion of the textiles sector.

Sophie De Salis, Sustainability Policy Advisor at the BRC, said the industry is prepared to work with government on implementation. "A well-designed, well-sequenced and industry-led scheme has the power to revitalise our textiles waste management system, create more jobs in the circular economy and ultimately lead to better designed textiles in the market."

The publication comes ahead of the government's Circular Economy Growth Plan, expected in early 2026. Nearly half of all used textiles in the UK are currently disposed of in household bins rather than through collection schemes, equivalent to 35 items per person per year.

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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?

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There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.