What exactly has been decided?
On 9 September 2025, the European Parliament adopted new rules to reduce textile waste. The core of the legislation: textile producers (including clothing and footwear) must, through national EPR schemes, contribute financially to the costs of collecting, sorting and recycling their products. The rules also apply to e-commerce sellers, regardless of whether they are based inside or outside the EU.
Timeline and scope
Member states must set up EPR schemes for textiles within 30 months after the directive enters into force. Micro-enterprises will get an additional year to comply. The product scope includes clothing and accessories, hats, footwear, blankets, bed and kitchen linen and curtains; member states may also decide to apply EPR to mattresses. After signing, the directive will be published in the Official Journal of the EU. From then, countries have 20 months to transpose the rules into national law.
What does this mean for Dutch online sellers?
If you sell textiles (such as clothing) to EU consumers, you will likely face obligations such as:
Registration with one or more national EPR schemes (Producer Responsibility Organisations, PROs)
Periodic reporting of quantities placed on the market per product category
EPR contributions (eco-modulated fees) that vary by material/sustainability and by country
Administrative checks on imports and cross-border fulfilment (e.g. when selling via marketplaces)
Note: the EU sets the framework, but the practical implementation (registration processes, reporting formats, fee structures) is arranged per member state. Expect differences between countries in procedures, deadlines and fee levels.
Are there thresholds or exemptions?
The adopted text explicitly mentions an additional year for micro-enterprises. A uniform EU-wide “de minimis” threshold for quantities has not been defined in the official communication. Whether national thresholds, simplified regimes or temporary exemptions will exist will be up to the member states. In practice: some countries may introduce a volume threshold or simplified reporting, others may not. Businesses must monitor national implementation closely once transposition begins.
Selling via Bol, Amazon or your own webshop?
For many Dutch sellers, revenue flows through both marketplaces and direct-to-consumer shops. In practice, the pattern is:
Marketplaces may provide EPR-related information, but the legal responsibility lies with the “producer” placing the product on the market in a member state.
Using cross-border fulfilment (e.g. Pan-EU-like models) may mean “placing on the market” in several countries, creating EPR obligations in each.
For D2C shops (Shopify/WooCommerce), the seller remains responsible for registration and reporting, unless an authorised representative is appointed — details of which will depend on each national scheme.
In short: map out where your stock is located, in which countries you first offer goods, and link that to EPR obligations per country.
How does this work operationally?
Three concrete steps Dutch e-commerce businesses can prepare:
Map your assortment into EPR categories
Classify products (clothing, footwear, household textiles) and record material, weight and quantity per country.
Set up data flows and documentation
Ensure you can export reports (monthly/quarterly) with volumes and weights per country. Link PIM/ERP/marketplace data to EPR reporting and store proof (invoices, ASN, fulfilment reports).
Budget for EPR costs and impact on pricing
Expect eco-modulated fees that vary per material and country. Factor in an “EPR surcharge” at SKU level in your margin analysis.
Are there differences per EU country?
Yes, expect differences in:
Which PROs operate in each market
Fee tables by material/weight
Reporting cycles and formats
Possible thresholds or simplified regimes for small volumes
Because member states set up their own systems within EU guidelines, harmonisation will be limited. For sellers active in multiple countries, it pays to standardise on one internal data model and then map to local schemes.
What do we know for sure, and what not yet?
We know for sure: the Parliament has adopted the law; EPR for textiles will apply across the EU; e-commerce is explicitly included; member states have 30 months to set up schemes, and micro-enterprises get an extra year; countries then have 20 months to transpose the directive into national law. The exact national rules, thresholds and fee tables will only become clear during and after implementation by each member state.
