The ongoing work by the European Commission on the final version of the revision of Directive 2008/98/EC on waste is raising serious concerns among Polish businesses in the textile, clothing, and footwear sectors. The draft introduces a wide array of new obligations that EU member states — including Poland — will have to implement in the coming months. While the proposed changes are grounded in environmental goals, industry leaders warn that they could significantly increase operating costs and harm the competitiveness of Polish companies.
Extended Producer Responsibility: A Game-Changer
One of the most significant changes is the introduction of Extended Producer Responsibility (EPR). Under this principle, any entity placing textile, clothing, or footwear products on the market — whether a manufacturer or importer — will be required to finance the entire waste management process.
In practical terms, this means companies will pay a modulation fee for each product introduced to the market. These fees will fund:
- Collection
- Sorting
- Recycling
- Consumer education regarding the proper disposal and reuse of textiles and clothing.
Mandatory Registration and Participation in PROs
Each EU country will need to establish a Producer Responsibility Organization (PRO) and maintain a national registry of producers and importers. Registration will be mandatory; failure to comply will result in a ban on product sales in Poland.
PROs will be responsible for organizing collection systems, managing waste processing, and fulfilling legal obligations. To operate, they must obtain state authorization and meet strict financial and organizational criteria.
Eco-Modulation and Reporting Requirements
The fees companies pay into PROs will follow eco-modulation principles, meaning the cost will vary based on:
- Product durability
- Repairability
- Use of recycled materials
- Production volume
This aims to encourage sustainable design, but could dramatically raise costs — especially for producers of low-margin, high-volume apparel.
Additionally, both producers and PROs will need to submit detailed reports on product quantities, collection system performance, and environmental outcomes. These administrative obligations are expected to be time-consuming and expensive, with many businesses saying they’ll struggle to comply without additional support.
Used Clothing: No Longer Waste, But Still Regulated
Another proposed change redefines reusable used clothing as non-waste. While seemingly positive, this change requires revisions to transport, storage, and trading regulations. It will particularly affect second-hand retailers and non-profits involved in textile reuse.
E-commerce Platforms Under Scrutiny
The directive also targets online sales. E-commerce platforms, both domestic and international, will be required to verify whether sellers are registered in the national registry. This aims to curb illegal and unfair competition but adds a new layer of administrative responsibility for marketplaces.
Industry Appeals for Dialogue and Support
Polish textile and fashion industry representatives are urging the government to engage in meaningful dialogue and include businesses in shaping the national implementation of the directive.
“We do not question the need for change, but we call for reason and dialogue,” said Tadeusz Wawrzyniak, President of the Polish Clothing and Textile Industry Employers’ Association (PIOT).
“The EPR system for textiles is too significant a reform to be introduced without involving the companies that will finance and operate it. We fear that the full burden will fall on legally operating companies, especially SMEs, while the grey and black markets and illegal imports will escape regulation.”
Wawrzyniak also proposed practical steps to improve transparency and control:
- Require CN codes on all domestic and international invoices to track product movement and volume.
- Establish clear regulations, realistic timelines, and transitional periods.
- Provide consulting and financial support, particularly for small and medium-sized businesses.
“Poland’s textile and clothing sector — which employs tens of thousands of people and is a key pillar of our economy — is ready for ecological transformation,” Wawrzyniak concluded.
“But it expects the changes to be designed wisely and implemented in close cooperation with the business community.”
Key industry demands include:
- Meaningful public consultations in drafting national implementation laws
- Realistic deadlines and transitional periods for adaptation
- Technical and financial support, especially for SMEs
Source: ceo.com.pl – New EU Regulations Raise Alarm in Fashion Industry
PIOT – Polish Employers’ Association of the Clothing and Textile Industry
