EDANA, the voice of nonwovens, alongside fellow industry associations CIRFS (European Man-Made Fibres Association), ESF (European Safety Federation), EURATEX (The European Apparel and Textile Confederation) and EuroCommerce (Retail & Wholesale), has issued a joint statement raising critical concerns regarding the transposition of Directive (EU) 2025/1892, the targeted revision of the Waste Framework Directive.
As Member States begin implementing the Extended Producer Responsibility (EPR) for textiles, a lack of distinction within the Directive’s Annex IVc is causing confusion. Currently, the specified CN codes do not distinguish between standard apparel and essential Personal Protective Equipment (PPE) or Medical Devices (MD).
The joint statement highlights that PPE and Medical Devices are engineered to protect users from hazardous environments, including chemical, biological, and radiological risks. Consequently, these garments often become contaminated and are classified as hazardous waste, requiring incineration—often with energy recovery—rather than recycling, to ensure safety.
Including these products in standard textile EPR schemes poses significant risks:
The statement also calls for guidance on safety shoes. Like other PPE, these items face contamination issues that limit recyclability. Furthermore, manufacturers cannot guarantee product warranties or conformity for reused safety footwear, and the fee scaling for heavy items (e.g., steel-toed boots) remains unclear.
Recital 28 of the Directive already suggests that products posing safety or hygiene risks should be excluded from the EPR. However, this is being overlooked in national implementations, such as in Spain and the Netherlands.
Therefore, the signatories urge the European Commission to issue clear guidance to Member States confirming that products complying with the PPE Regulation (2016/425) and the MD Regulation (2017/745) are outside the scope of the Textiles EPR.
Read the full joint statement here.