Extended Producer Responsibility: What’s Missing?

By Zöe Rucker

Understanding what EPR achieved for packaging helps explain why textiles lag and what is structurally missing.

Extended Producer Responsibility (EPR) shifts the cost of managing waste from local authorities to the producers who place products on the market. This makes producers financially responsible for managing products at end of life, particularly once they become waste¹.

In the UK, EPR has been most developed in packaging. Textiles sit outside that level of development.

How EPR Works in Packaging

Packaging EPR in the UK has been built through regulatory frameworks that require producers to contribute to the cost of managing packaging waste².

Recent reforms extend this further. Under the reformed UK packaging EPR system, producers are required to cover the full net cost of managing household packaging waste, including collection, sorting, treatment and disposal³.

Instead of local authorities carrying these costs through public funding, they are transferred to producers based on the volume and type of packaging they place on the market.

This has three effects:

1. It creates a direct cost signal Materials that are harder to recycle or manage are expected to incur higher fees under modulated charging structures³. This links design decisions to waste outcomes.

2. It generates consistent data flows Producers are required to report the quantity and type of packaging they place on the UK market⁴. This produces a national dataset on packaging material flows.

3. It funds waste infrastructure Local authorities are funded for the efficient management of household packaging waste³. Packaging becomes a defined waste stream with clear accountability and cost allocation. This is what functioning EPR looks like in practice.

What This Means in Policy Terms

Packaging EPR aligns with the waste and resource strand of UK sustainability policy, where materials are tracked, measured and managed once they enter the waste stream. Because packaging is treated as a defined material category, it can be measured. That allows it to be governed.

EPR works where three conditions are met: 

• the material is clearly defined 

• it is consistently collected 

• it is measurable at scale

Packaging meets these conditions.

Where Textiles Sit

Textiles are internationally complex, environmentally intensive systems before they reach the UK waste policy⁵. Textile production takes place across global supply chains, from fibre production through spinning, dyeing, manufacturing and distribution, with environmental impacts occurring at each stage⁵.

In UK policy, textiles are addressed within waste and resource frameworks once discarded, rather than through a fully operational producer responsibility system⁶.

There is no comprehensive, mandatory EPR scheme for textiles in the UK equivalent to packaging. They do not function as a consistently defined or measured waste stream in the same way.

Conclusion

The UK has signalled progress toward textile EPR through broader circular economy and waste-reduction policy⁶. 

Industry-led initiatives aim to reduce environmental impact and improve resource efficiency⁷. These are voluntary agreements and do not require producers to fund end-of-life management or generate a single national dataset.

Packaging EPR shows what happens when a material is fully integrated into the waste system. It becomes measurable, fundable and governed. Textiles remain partially outside that system. They are environmentally significant but structurally under-defined, affecting how they are measured, how costs are allocated and what interventions are prioritised.

Packaging waste is counted and costed, while clothing need is measured separately through income and deprivation data.

Extended Producer Responsibility is not only a funding mechanism. It is a way of defining a material within policy. Packaging has that definition. Textiles do not yet have it at the same level.

Until textiles are consistently measured, collected and costed as a system, a full EPR model cannot operate effectively. The gap reflects how clothing is positioned as waste when discarded but not fully accounted for as a material flow across its lifecycle.

References:

1. OECD, Extended Producer Responsibility: Updated Guidance for Efficient Waste Management, defines EPR as producer responsibility for end-of-life management, OECD Publishing, 2016. 

2. UK Legislation, Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended), establishes legal obligations for producers to recover and recycle packaging waste, UK Government, 2007.

3. Department for Environment, Food & Rural Affairs (Defra), Extended Producer Responsibility for Packaging: Policy Statement, confirms full net cost recovery, modulated fees and local authority funding, Defra, 2022.

4. Environment Agency, Packaging Data Reporting Requirements, sets out mandatory reporting of packaging placed on the UK market by obligated producers, Environment Agency, ongoing guidance

5. United Nations Environment Programme (UNEP), Sustainability and Circularity in the Textile Value Chain, details environmental impacts of textiles including emissions and resource use, UNEP, 2020.

6. Department for Environment, Food & Rural Affairs (Defra), Resources and Waste Strategy for England, identifies textiles within waste streams and highlights challenges in collection and recycling systems, Defra, 2018.

7. WRAP, Textiles 2030, voluntary industry agreement to reduce lifecycle environmental impact of textiles, WRAP, 2021.