In recent years, the European Union has significantly intensified its efforts to transition to a circular economy and reduce the negative environmental impacts of production and consumption. This direction, which is one of the pillars of the European Green Deal, is reflected in a number of strategic documents and legislative initiatives aimed at reducing waste, promoting more efficient use of resources, and redirecting the European economy towards sustainability. One of the most recent and significant steps in this direction is the adoption of Directive (EU) 2025/1892 of the European Parliament and of the Council of 10 September 2025, amending Directive 2008/98/EC on waste[1] (hereinafter as the “Directive”).
This Directive is part of a broader legislative framework supporting the transition to a circular economy, as set out in the new Circular Economy Action Plan of 2020[2]. The Directive responds to the growing need to reduce waste in sectors with the highest environmental footprint, particularly the textile and food industries. These sectors have long been considered critical in Europe (or the EU): according to the European Environment Agency, textile production is one of the four largest sources of primary raw material and water consumption and is responsible for 10% of CO₂ emissions from industrial production in the EU. Food waste is a problem not only in environmental terms, but also in social terms – it is estimated that over 58 million tons of food are wasted in the EU every year, which corresponds to economic losses of EUR 132 billion[3].
Main objectives and entry into force
The Directive has two main and closely related objectives. The first is to introduce a mandatory Extended Producer Responsibility (EPR) system for textile and footwear products. This system is designed to ensure that producers are responsible not only for placing their products on the market, but also for their collection, sorting, and processing at the end of their life cycle. The second objective is to introduce legally binding targets for reducing food waste by 2030.
The Directive entered into force at the end of October 2025, and Member States now have 20 months to transpose its provisions into their national legislation, i.e. by 17 June 2027 at the latest. Within this period, they will have to create a national legal framework for the functioning of EPR, designate responsible authorities, and prepare a strategy for meeting food waste targets.
New rules for Extended Producer Responsibility in the textile sector
The introduction of an EPR system for textile and footwear products is probably the most significant change brought about by the Directive. Manufacturers, importers, and distributors who place products on the market for the first time will be required to ensure the financing and practical organization of the management of these products at the end of their life cycle. This responsibility includes not only financing, but also the establishment of or participation in systems for collection, sorting, preparation for reuse, and recycling. The Directive explicitly states that these obligations also apply to unsold products that become waste primarily due to the overproduction typical of “fast fashion”.
Self-employed tailors who make custom-made products and manufacturers who place used products intended for reuse on the market are exempt from this obligation. The aim of these exemptions is to avoid a disproportionate administrative burden on small businesses and, at the same time, to support the secondary textile market, which contributes to extending the life cycle of clothing.
Eco-modulation of fees
The new EPR system will be supplemented by the principle of eco-modulation, whereby the amount of the manufacturer’s fee will depend on the environmental characteristics of the product.
Products that are easily recyclable, contain recycled fibers, have a longer life cycle, and are repairable will be subject to a lower fee. Conversely, products with a short life cycle or made of composite materials that are difficult to recycle will be subject to a higher fee.
This mechanism is being introduced with the aim of promoting eco-design and motivating manufacturers to take into account the entire life cycle of a product – from production to end-of-use – at the design stage.
Infrastructure and separate collection
The Directive places a strong obligation on Member States to ensure that infrastructure for the collection of textile waste is available throughout their territory, including in remote and rural areas. From 2025, all Member States will be required to ensure the separate collection of textiles, which will then be used for reuse or recycling. Textile waste must be physically separated from other types of waste to prevent its degradation and preserve its quality for further use.
The Directive also encourages the involvement of non-profit and social enterprises in the collection and sorting system, as these organizations already play a key role in the chain of reuse and charitable use of clothing.
Manufacturers’ information obligation
Another element is the obligation to inform consumers about how to dispose of textile products at the end of their life cycle, including repair, recycling, and reuse options. This aspect is essential for changing consumer behavior, which is still strongly influenced by the “fast consumption” model.
Legally binding targets for reducing food waste
The second key part of the amendment is the setting of legally binding targets for reducing food waste. While the existing EU framework in this area has been based primarily on voluntary measures and political commitments, the approach now is to set clear figures and verifiable targets.
By 2030, Member States must:
- reduce food waste in the production and processing stages by at least 10%, and
- in retail, catering, distribution, and households by at least 30% per capita compared to the average for 2020-2022.
There is also an obligation to regularly monitor food waste and report to the Commission on the achievement of the targets. The European Commission will review progress in 2027 and may propose further adjustments to the targets, including tightening them for the period after 2030.
The Directive also requires Member States to integrate measures against food waste into their national waste prevention programs and to develop information and education campaigns targeting consumers. It also encourages the donation of unsold food and the creation of partnership platforms between producers, retailers and charities. The aim is to minimize situations where safe food is thrown away because it does not meet market standards or has a short shelf life.
Strengthening the principles of the circular economy and sustainable design
The Directive further consolidates the basic principles of the circular economy. Waste should be seen as a potential source of raw materials and energy, not as the end product of the production cycle. The amendment therefore introduces economic and regulatory incentives to promote the development of textiles with a lower environmental footprint and longer lifespan, while reducing pressure on primary resources.
Another significant benefit is the potential for new business models – repair shops, rental services, reuse, and recycling of textiles – which can create new “green” jobs and strengthen local economies.
The Directive also addresses social aspects: Member States are to promote the involvement of social enterprises in the collection and preparation for reuse process, thereby linking the environmental and social dimensions of the transformation.
Conclusion
The amendment to the Waste Directive represents the most comprehensive revision of European waste management legislation in the last decade. It combines binding targets for reducing food waste with the creation of a completely new system of extended producer responsibility in the textile and footwear sector. In doing so, it brings together environmental, economic, and social objectives into a single framework for the first time and puts into practice the principles of the circular economy, which the EU has been discussing for more than a decade.
However, its success and the achievement of its objectives will depend on the speed and quality of its implementation in the Member States. According to the European Environmental Bureau (EEB), there is a risk that an overly long transition period could delay assistance to municipalities and organizations that need the new rules the most. At the same time, it will be necessary to ensure sufficient infrastructure, transparency of financial flows within EPR systems, and cooperation between industry, local governments, and the non-profit sector.
We will continue to keep you informed in detail about further changes in this area. If you have any questions, we are always available – please do not hesitate to contact us.
[1] Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025L1892.
[2] Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020DC0098.
[3] More information available at: https://food.ec.europa.eu/food-safety/food-waste_en.
Mgr. Jakub Málek, managing partner – malek@plegal.cz
Mgr. Kateřina Musilová, junior lawyer – musilova@plegal.cz
Ráchel Kouklíková, legal assistant – kouklikova@plegal.cz
13. 11. 2025