English 
At least 4,000 Danish companies will face a new legal requirement within the next few years: they will be required to pay for the management of their textiles when they become waste. This is the consequence of the EU’s new producer responsibility for textiles, which entered into force in October 2025, and which Denmark is expected to implement by April 2028 at the latest. The rules are on their way, but many details are still missing. Here is an overview of what we know, what remains unresolved – and what it means for your business.
The idea behind producer responsibility is simple: whoever places a product or packaging on the market also bears responsibility for what happens to it when it becomes waste. This is a direct expression of the polluter pays principle, and it is not new in an EU context.
We already know it from producer responsibility for electronics (introduced in Denmark in 2005), batteries (2009), packaging (2025), and fishing equipment and single-use plastics (2024).
Every time the EU has introduced producer responsibility in a new area, the logic has been the same: those who place a product on the market have the ability to influence its design in ways that ensure better use of resources, reduced material consumption, and a shift towards more environmentally friendly materials.
The potential is enormous – and the need is real
For textiles, pressure has been building for years. The textile sector is the fourth most environmentally damaging sector in the EU, after food, construction, and transport – and consumption is growing.
A 2023 study by the Danish Environmental Protection Agency shows that Danish textile consumption increased by 36% between 2016 and 2021. In 2021, before separate collection requirements came into force, only 2,000 of the 116,000 tonnes of textiles placed on the Danish market were collected separately for recycling.
This is the context in which the EU’s decision must be understood.
The EU legal basis: from strategy to directive
The formal foundation for producer responsibility for textiles is the revised Waste Directive, adopted by the European Parliament and the Council, which entered into force on 16 October 2025 (Directive EU 2025/1892). The directive requires all EU countries to establish national producer responsibility organisations for textiles and footwear.
The directive is the endpoint of a process that began with the EU Textile Strategy in March 2022, which placed the circular economy in the textile sector on the political agenda, and which has been under negotiation since 2023 as a targeted revision of the Waste Directive.
A central element of the directive is environmental modulation. This means that the contributions producers pay for their textile waste are modulated with bonuses and penalties based on the environmental profile of their products: products designed for longevity, ease of repair, or containing recycled materials attract lower contributions than products that are difficult to recycle and have a limited lifespan. The aim is to make it financially worthwhile to design better products rather than simply financing the waste management of poor ones.
The directive also sets out a framework under which the European Commission must, by the end of 2029, evaluate the organisations and assess whether specific targets for collection, reuse, and recycling should be set. Such targets are not yet included in the directive itself, as the data basis is considered insufficient.
The Danish timeline
There is a specific process for transposing an EU directive into Danish legislation.
Denmark has 20 months to implement the directive into national law, and a further 10 months to have producer responsibility organisations operational. This gives the following timeline:
- January 2025: Requirements for separate collection of textile waste entered into force across all EU countries. (In Denmark, this requirement was brought forward to 1 January 2023.)
- October 2025: The EU’s revised Waste Directive entered into force.
- Autumn 2026: The Danish Ministry of Environment is expected to send the executive order out for consultation. Industry stakeholders will participate in a collaborative forum with the authorities.
- Spring 2027: Proposals submitted to the Danish Parliament (Folketing).
- June 2027: Deadline for Denmark to have adopted national rules.
- 2027: Possible first reporting of estimates to the authorities.
- 17 April 2028: Producer responsibility organisations must be fully operational for large, medium-sized, and small companies.
- 17 April 2029: Micro-enterprises – companies with fewer than 10 employees and a turnover below DKK 15 million – are granted one additional year.
What will producer responsibility cover?
According to the Danish Environmental Protection Agency, approximately 10,500 companies in Denmark are engaged in the manufacture and sale of textiles. At least 4,000 of these are expected to be directly covered by producer responsibility.
The directive covers clothing textiles, home textiles, curtains, bed linen, carpets, footwear, and hats. Producer responsibility for mattresses may also be introduced.
All companies making these products available on a national market are covered – including international webshops, regardless of whether they are established in Denmark or not.
The specific obligations for companies are expected to comprise four main elements: reporting of volumes by textile type to the national authorities, payment of contributions to finance collection, sorting, and recycling, internal controls for documentation during inspections, and membership of a collective organisation, which may become mandatory.
What is not yet in place?
There are many key questions that remain unanswered – both at EU level and in Danish legislation. These include:
- Which textiles are precisely covered, and how are they defined? Are commercial textiles, barbecue covers, and other textile-adjacent products included, for example?
- How should volumes be calculated and reported, and will the definition of “placed on the market” be harmonised across the EU?
- How will environmental modulation be documented, and can documentation be reused across countries?
- Which company in the value chain holds producer responsibility when multiple parties are involved?
- What will it cost? The Environmental Protection Agency’s earlier price estimates from its 2023 study are no longer reliable, as the market for textile waste management has changed significantly – and negatively – since then.
- How should fast fashion be handled under the new requirements, and how is it defined in practice?
The answers to these questions will emerge in the national executive order and in the further European regulation under the Ecodesign Regulation, where requirements for textile products are expected to be finally adopted in 2027.
The structural challenge: infrastructure is lagging
A producer responsibility organisation is only as good as the infrastructure it rests on – and here there is a real challenge: the market for household textile waste management in Europe is under severe pressure.
This is not a uniquely Danish problem. In France, where producer responsibility has existed since 2007, only 32% of textiles placed on the market were collected in 2023 – well below the target of 60% by 2028. The Netherlands, which introduced its system in 2023, has set ambitious targets, but the capacity to meet them is not yet in place.
Part of the explanation is technical: textiles are a complex and fragile fraction that is difficult to sort and recycle, and can easily be rendered unusable through improper handling. This requires investment in dedicated infrastructure – not just collection.
Our experience is that the best results come when the companies covered, the authorities, and the waste industry work together on solutions. This is precisely the model that Retur and HJHansen Recycling followed when they established ERR (Electronic Reuse & Recycling) in Nørre Aaby in 2025 – Denmark’s first reuse facility for electronics. The facility was not created in response to a legal requirement, but because the parties saw a shared responsibility to build the infrastructure needed to achieve real goals.
If the authorities choose to pursue the same approach for textiles, Tekstilretur will naturally contribute the knowledge and experience we have built through Retur in close collaboration with our members. In this way, we can develop the market for textile recycling drawing on our experience in waste management operations, investment in new technology, and support for innovation.
Read more about experiences with producer responsibility for textiles and footwear here.
