What will producer responsibility for textiles and footwear cost?
What interests you most as companies is what the extended producer responsibility (EPR) for textiles and footwear will cost you. It is also one of the most difficult questions to answer, given how much remains unknown about the specific implementation at this stage.
That said, we do have considerable knowledge of the financial framework for the forthcoming EPR.
This draws partly on the EU Waste Framework Directive and partly on our many years of experience running producer responsibility schemes across a wide range of areas in Denmark.
The Waste Framework Directive requires producers to bear certain minimum costs in connection with producer responsibility. These cover:
Tekstilretur, as your producer responsibility organisation, will handle the vast majority of these obligations, with costs covered by the environmental contribution paid to Tekstilretur.
Some tasks may be carried out by public authorities, such as waste analyses, campaigns, and research.
Our experience from other producer responsibility schemes is that collection and waste management represents the largest share of costs.
The Danish Environmental Protection Agency carried out an economic analysis in 2023 under Environmental Project 2240.
The analysis includes, among other things, an assessment of how many companies are expected to fall under producer responsibility for textiles and footwear in Denmark.
Since then, CN codes have been included in the Waste Framework Directive, and rules have been introduced bringing micro-enterprises within scope - both of which alter the assumptions underlying the 2023 analysis.
On the face of it, this suggests that more than 10.000 companies will be covered by EPR in Denmark.
The Environmental Protection Agency estimated that 116,000 tonnes of textiles were placed on the Danish market in 2021, based on expectations at the time regarding which textiles would fall under producer responsibility.
The market is currently developing in a way that sees supply growing by approximately 4% per year, so that figure will have risen since then.
The analysis concludes that the socioeconomic cost of producer responsibility will amount to DKK 158.6 million per year, but the analysis is based on prices that have changed significantly since then.
This is due to the supply of second-hand textiles having increased while demand has fallen. At the same time, quality has declined and new clothing has become cheaper and more accessible worldwide.
First and foremost, we must acknowledge that it is not yet possible to arrive at specific prices, as the basis remains too uncertain. However, Tekstilretur is aware that members need to make budget decisions for 2028.
We have therefore recently held a webinar on the financial framework and will be offering further webinars providing insight into what you can expect to pay for from April 2028.
This may be a useful starting point for briefing your management internally. We are also in a position to outline the financial principles that will govern Tekstilretur's economy, which will follow the same principles applied in the other producer responsibility organisations under Retur.
Tekstilretur will also operate on a non-profit basis with full transparency around accounts and budgets, and member democracy will be introduced for approving the financial framework and pricing. If you are interested in Tekstilretur's finances, you are welcome as a member to join the section board when it is established, no particular prior knowledge is required. We will notify members in our newsletter when sign-ups open.
Tekstilretur recently held webinars on the financial framework expected to apply to producer responsibility and to Tekstilretur from 2028. After the summer break in 2026, we plan to hold the webinar again and make it available to Tekstilretur members on MitRetur, so you can watch it at a time that suits you.