{"id":6272,"date":"2026-09-27T16:29:45","date_gmt":"2026-09-27T13:29:45","guid":{"rendered":"https:\/\/aesinn.com\/uyum-denetim-due-diligence-danismanligi\/tekstilde-zorunlu-genisletilmis-uretici-sorumlulugu-epr-ab-atik-cerceve-direktifi-revizyonu-ve-eko-modulasyon\/"},"modified":"2026-09-28T14:17:51","modified_gmt":"2026-09-28T11:17:51","slug":"tekstilde-zorunlu-genisletilmis-uretici-sorumlulugu-epr-ab-atik-cerceve-direktifi-revizyonu-ve-eko-modulasyon","status":"publish","type":"page","link":"https:\/\/aesinn.com\/en\/uyum-denetim-due-diligence-danismanligi\/tekstilde-zorunlu-genisletilmis-uretici-sorumlulugu-epr-ab-atik-cerceve-direktifi-revizyonu-ve-eko-modulasyon\/","title":{"rendered":"Mandatory Extended Producer Responsibility (EPR) in Textiles: EU Waste Framework Directive Revision and Eco-Modulation"},"content":{"rendered":"<h2 class=\"wp-block-heading\">Why is this topic important?<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The European Union has implemented a significant regulatory change linking the management of textile waste to the producer&#039;s responsibility. The revision of the Waste Framework Directive (2008\/98\/EC) introduces a mandatory extended producer responsibility (EPR) regime for textiles in all member states. This means that every producer placing products on the EU market must contribute to financing the collection, sorting, and recycling of their products.<\/p>\n\n\n\n<div class=\"aes-ortak-notu\" style=\"border-left:4px solid #CE1A1A;background:#f6f6f6;padding:14px 18px;margin:18px 0 22px 0;font-size:15px;line-height:1.6;color:#222;\"><strong>Service note:<\/strong> AES Innovation carries out the EU compliance work described on this page (PPWR, digital product passport, CBAM, etc.) in collaboration with expert solution partners; it does not provide these services directly. These activities are outside the scope of our accreditation (EU-0631-M).<\/div>\n\n\n\n<p class=\"wp-block-paragraph\">This information sheet has been prepared to summarize the current status of the revision, the eco-modulation mechanism, and the potential liabilities for Turkish garment and textile exporters. The aim is to provide a general framework to help relevant parties follow the issue at an early stage.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Mandatory EPR covers manufacturers who place a textile product on the EU market for the first time.<\/li>\n\n\n<li>The obligation may include domestic producers as well as importers and online sellers.<\/li>\n\n\n<li>Prices are not uniform; they vary through eco-modulation based on the product&#039;s environmental performance.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Current Status of the Waste Framework Directive Revision<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The European Parliament adopted a targeted revision of the Waste Framework Directive on September 10, 2025. The text includes common EPR rules for textiles and food waste reduction targets. According to publicly available sources, the revised directive entered into force on October 16, 2025.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">According to publicly available sources, member states are given 20 months from the entry into force date to transpose the directive into national legislation (approximately mid-2027). A longer period is foreseen for the establishment and operationalization of national EPR schemes; sources indicate that this transition will be completed by 2028. The exact dates depend on member state implementation, so the timeline may vary from country to country.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Parliamentary approval: September 10, 2025 (confirmed).<\/li>\n\n\n<li>Effective date: October 16, 2025 (confirmed in publicly available sources).<\/li>\n\n\n<li>Transition period to national legislation: approximately 20 months, depending on member state practice.<\/li>\n\n\n<li>EPR schemes are expected to become operational by 2028; this may vary by country.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Scope: Which Products and Who?<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">According to publicly available sources, the obligation covers a wide range of products: clothing, accessories, hats, shoes, blankets, bedding and kitchen textiles, and curtains are given as examples. The exact product list and thresholds will be clarified in member state regulations.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The obligated party is defined as the producer who first places the product on the EU consumer market. Since this definition may also apply to producers outside the EU, it is considered that Turkish companies selling their products to the EU could also fall within this scope. The final scope will depend on member state transfers and relevant implementing regulations.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>A wide range of products, including clothing, footwear, and home textiles, are included within the scope.<\/li>\n\n\n<li>The liable party is the producer who first brings the product to market.<\/li>\n\n\n<li>Non-EU producers and online sellers may also be included; details depend on member state practice.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">How does eco-modulation work?<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Ecomodulation is the principle of differentiating EPR (Environmental Product Registration) fees based on a product&#039;s environmental performance. In practice, lower fees are stipulated for durable, easily recyclable products with a lower environmental impact, while higher fees may be applied to products that are difficult to recycle or contain harmful substances.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">According to publicly available sources, eco-modulation criteria include design features such as durability, recyclability, mono-material design, and the percentage of recycled content. These criteria are expected to be consistent with the design criteria to be defined under the Eco-Design for Sustainable Products Regulation (ESPR). The specific levels of fees will vary depending on member state practice and product characteristics.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Durable and recyclable design has a positive impact on driving the price down.<\/li>\n\n\n<li>Products that are difficult to recycle or contain harmful substances may incur higher costs.<\/li>\n\n\n<li>The criteria are expected to align with ESPR design criteria.<\/li>\n\n\n<li>Specific wage levels have not been confirmed; this will be clarified in member state regulations.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Manufacturer&#039;s and Importer&#039;s Responsibilities<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Under the EPR regime, producers are primarily expected to fulfill three types of obligations. First, registering with the producer register in the relevant Member State or joining an approved producer liability organization (PRO). Second, paying an eco-module fee calculated according to the quantity of product placed on the market and product characteristics. Third, reporting data on quantities placed on the market and results of collection, reuse, and recycling.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The specific form of these obligations, details such as which register to use and the frequency of reporting, will be determined in member state regulations. Therefore, companies are advised to follow the national practices of each EU member state to which they ship their products.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Registration in the national producer register or participation in an approved producer liability organization.<\/li>\n\n\n<li>Payment of an eco-module fee calculated according to product quantity and specifications.<\/li>\n\n\n<li>Reporting of data on market supply, collection, reuse, and recycling.<\/li>\n\n\n<li>Details depend on member state practice; country-specific monitoring is required.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Impact on Turkish Textile and Apparel Exporters<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">A Turkish producer or exporter placing a product on the EU market may face the obligation to register with the relevant Member State&#039;s EPR scheme and pay an eco-module fee. Since the specific scope of this obligation will be determined by the national regulations of the Member State where the product is placed, country-specific variations are expected rather than a single Europe-wide application.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">A significant commercial consequence is that design decisions can directly impact cost. Durable, recyclable, and single-material designs can, by virtue of eco-modulation, drive costs down. Therefore, early assessments of issues such as material selection, product lifespan, and recyclability can be beneficial in terms of both compliance and cost. These assessments are informative, and expert opinions and qualified engineering support for relevant technical issues may be helpful for final decisions.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Turkish manufacturers supplying products to the EU may be subject to registration under the relevant member state&#039;s EPR scheme.<\/li>\n\n\n<li>Eco-modulation fees vary depending on the product&#039;s design features.<\/li>\n\n\n<li>The durable and recyclable design can alleviate the burden of costs.<\/li>\n\n\n<li>The obligations must be followed separately in each member state to which the product is shipped.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Related Topics and Scope Distinction<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">This content addresses extended manufacturer&#039;s responsibility for textile products only. Manufacturer&#039;s responsibility on the packaging side (PPWR) is a separate topic and is covered in our related content.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The eco-design criteria on which eco-modulation measures are based, such as recyclability, are discussed in more detail in our related content within the framework of the Eco-Design for Sustainable Products Regulation (ESPR). The topic of Product Passports (DPP) is covered in a separate article.<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li>Packaging manufacturer liability (PPWR) is outside the scope of this content.<\/li>\n\n\n<li>ESPR design criteria are detailed in our related content.<\/li>\n\n\n<li>The digital product passport is discussed in a separate article.<\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Information Note<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">This content is for informational purposes only. AES is not an approved body or certification body; it does not issue EPR registrations, waste management certificates, or conformity verifications. AES&#039;s T\u00dcRKAK accreditation is only for the scope of 6.1 Electrical Installation inspection.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The information here is based on publicly available sources, and regulations may change over time and according to member state practice. It is recommended to seek support from a qualified expert for company-specific assessments.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Related Services and Content<\/h2>\n\n\n\n<ul class=\"wp-block-list\">\n\n<li><a href=\"https:\/\/aesinn.com\/en\/uyum-denetim-due-diligence-danismanligi\/urun-ambalaj-etiketleme-uyum-analizi\/ppwr-geri-donusturulebilirlik-tasarimi-a-b-c-performans-siniflari-geri-donusturulmus-icerik-ve-2026-2038-takvimi\/\">PPWR Recyclability Design (A\/B\/C)<\/a><\/li>\n\n\n<li><a href=\"https:\/\/aesinn.com\/en\/uyum-denetim-due-diligence-danismanligi\/dijital-urun-pasaportu-dpp\/tekstil-sektorunde-dijital-urun-pasaportu-dpp-espr-veri-gereklilikleri-ve-hazirlik\/\">Digital Product Passport (DPP) in the Textile Industry<\/a><\/li>\n\n\n<li><a href=\"https:\/\/aesinn.com\/en\/uyum-denetim-due-diligence-danismanligi\/\">Compliance, Audit and Due Diligence Consulting<\/a><\/li>\n\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Frequently Asked Questions<\/h2>\n\n\n\n<h3 class=\"wp-block-heading\">Is the mandatory EPR for textiles actually in effect?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">According to publicly available sources, the revision of the Waste Framework Directive introducing mandatory EPR for textiles was adopted by the European Parliament on 10 September 2025 and entered into force on 16 October 2025. The implementation of national schemes is expected in the following years, depending on member state transfers.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Would a Turkish textile exporter be affected by this obligation?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">A manufacturer placing a product on the EU market may, depending on the source, face the obligation to register under the relevant Member State&#039;s EPR scheme and pay eco-module fees. This may also apply to non-EU manufacturers. The specific scope depends on the practice of the Member State where the product is placed.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">What does echomodulation mean?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Eco-modulation is the differentiation of the EPR fee based on the environmental performance of the product. Lower fees may apply to durable, recyclable, and single-material products, while higher fees may apply to products that are difficult to recycle. The criteria are expected to align with ESPR design criteria.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">What is the actual amount of the fee?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">Specific fee levels have not been confirmed and will vary according to member state regulations and product characteristics. Publicly available sources indicate that fees will start at low amounts per product and vary according to eco-modulation criteria.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">When do I need to register?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">The exact registration timeline depends on the member state&#039;s practice. Sources indicate that the transposition period into national legislation is approximately 20 months, and the schemes are expected to become operational by 2028. It is recommended that you follow the national timeline of each member state to which you are sending your products.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Does AES issue documents or EPR records regarding this?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">No. AES is not an approved body or certification body; it does not issue EPR registrations, waste management certificates, or conformity verifications. AES&#039;s T\u00dcRKAK accreditation is only for section 6.1 Electrical Installation inspection. This content is for informational purposes only.<\/p>","protected":false},"excerpt":{"rendered":"<p>Revize AB At\u0131k \u00c7er\u00e7eve Direktifi tekstil \u00fcr\u00fcnleri i\u00e7in zorunlu geni\u015fletilmi\u015f \u00fcretici sorumlulu\u011fu (EPR) getiriyor; \u00fccretler eko-mod\u00fclasyonla \u00fcr\u00fcn\u00fcn dayan\u0131kl\u0131l\u0131\u011f\u0131na ve geri d\u00f6n\u00fc\u015ft\u00fcr\u00fclebilirli\u011fine g\u00f6re farkl\u0131la\u015f\u0131yor.<\/p>","protected":false},"author":1,"featured_media":6275,"parent":4954,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"_kad_blocks_custom_css":"","_kad_blocks_head_custom_js":"","_kad_blocks_body_custom_js":"","_kad_blocks_footer_custom_js":"","_kadence_starter_templates_imported_post":false,"_kad_post_transparent":"","_kad_post_title":"","_kad_post_layout":"","_kad_post_sidebar_id":"","_kad_post_content_style":"","_kad_post_vertical_padding":"","_kad_post_feature":"","_kad_post_feature_position":"","_kad_post_header":false,"_kad_post_footer":false,"_kad_post_classname":"","slim_seo":{"title":"Mandatory EPR and Ecomodulation in Textiles (EU WFD)","description":"The revision of the EU Waste Framework Directive introduces mandatory EPR (Environmental Protection Regulation) for textiles. Information on eco-modulation, the member state timetable, and its impact on Turkish exporters."},"_pplb_hide_from_list":false,"footnotes":""},"class_list":["post-6272","page","type-page","status-publish","has-post-thumbnail","hentry"],"acf":[],"taxonomy_info":[],"featured_image_src_large":["https:\/\/aesinn.com\/wp-content\/uploads\/wfd-tekstil-epr-aes-kart-1024x1024.png",1024,1024,true],"author_info":{"display_name":"Emre Metin","author_link":"https:\/\/aesinn.com\/en\/author\/yonetim\/"},"comment_info":"","_hostinger_reach_plugin_has_subscription_block":false,"_hostinger_reach_plugin_is_elementor":false,"_links":{"self":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/6272","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/comments?post=6272"}],"version-history":[{"count":3,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/6272\/revisions"}],"predecessor-version":[{"id":6296,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/6272\/revisions\/6296"}],"up":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/pages\/4954"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/media\/6275"}],"wp:attachment":[{"href":"https:\/\/aesinn.com\/en\/wp-json\/wp\/v2\/media?parent=6272"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}