Producer obligations under textile EPR/RAP
Extended Producer Responsibility (EPR/RAP) for textiles and footwear requires those who place products on the market to take an active — and financial — role in managing them at end of life. On this page, we explain whether it applies to you, what you will need to do, and what information you should start preparing now.
Prepare for the future of textiles: comply seamlessly and with business vision.
The European strategy for more sustainable textiles is changing the rules of the game: greater traceability, stricter circularity requirements, and new end-of-life obligations. EPR/RAP is one of the key pieces because it connects what you sell with the real cost of managing the waste it generates.
Proper compliance is not just about “paying a fee”: it involves organisation, data and reporting, as well as a way of working that allows you to scale compliance across different markets and channels, including retail, online and marketplaces.
European Union facts and figures
What textile EPR/RAP is and what is changing at EU and Spanish level
EPR/RAP (Extended Producer Responsibility) requires companies that place textiles and footwear on the market to finance and organise — usually through a PRO/SCRAP — the management of those products when they become waste.
At EU level, the revision of the Waste Framework Directive strengthens this approach and pushes all Member States to have EPR schemes for textiles. In Spain, transposition is being implemented through national legislation — currently in progress — that will define categories, operational obligations and reporting requirements, as well as how the system will operate.
What this means for you: if you sell in Spain and/or other EU countries, you need an approach that enables you to comply by country and by channel, with consistent and traceable data.
Who does it apply to?
How to know whether you are a “producer” for EPR purposes
In practice, a producer is anyone who “places the product on the market” in a given country. It applies to you if you fall into any of these cases:
Manufacturers / Brands
You manufacture in Spain/the EU or market products under your own brand — even if produced by a third party — and sell on the Spanish/EU market.
Importers
You introduce products from outside the country — or from another country — to sell them in Spain/the EU, whether B2B or B2C.
Retailers and eCommerce
You buy from external suppliers and sell in Spain/the EU, including direct online sales.
If you sell from outside the EU to end consumers within the EU, you will normally also fall within scope as distance selling.
Financing waste management
You must cover the costs associated with separate collection, sorting, preparation for reuse, and recycling/recovery of textile waste, in proportion to the products you place on the market.
Registration and membership with a PRO/SCRAP
In most scenarios, compliance is handled through an authorised PRO/SCRAP that manages operations and centralises reporting.
Data reporting and traceability
You will need to declare — depending on the country and scheme — information such as quantities placed on the market, categories, weights/units, channel, and periods, with auditability.
Consumer information and communication
You will need to provide clear information on how to manage end of life, including return, collection, authorised drop-off points, etc., and in some cases comply with labelling/symbol requirements or campaign obligations.
What data you should prepare
This is the part that most often holds companies back when it comes time to register or report. Practical recommendation:
- Product catalogue and categories, including clothing, household textiles, footwear, etc.
- Weight per item — or reliable conversion rules — and/or compositions where applicable.
- Units and kilograms sold by country, channel (B2B/B2C, online, marketplace), and period.
- Brands and legal entity that “places the product on the market” — very important for groups and subsidiaries.
- Evidence: invoices/shipments, ERP listings, and basic accounting reconciliation.
Even if you currently sell only in Spain, prepare your data model as if you were going to sell in two or three EU countries. It will save you from having to rebuild processes later.
How compliance works in practice
Most producers comply through:
- Joining a PRO/SCRAP, which is the most common and efficient route.
- Individual system, which is less common and usually requires more structure and justification.
Timeline and upcoming milestones
EU: the legislation already sets the direction and the timelines for transposition and implementation by country.
Spain: national legislation will define the operational details, including categories, reporting, system operation, and specific obligations.
