Extended Producer Responsibility (EPR)
If you manufacture, import, or sell clothing, footwear, or textile accessories in Spain, it is highly likely that your company will soon have to begin complying with a new regulation: Extended Producer Responsibility (EPR).
This is neither a passing trend nor just another bureaucratic formality: it represents a shift in the model, placing the responsibility for what happens to a product once it becomes waste squarely on the party that brings it to market. In this guide, we explain—without unnecessary technical jargon—exactly what this entails, what the law says, and how it affects you if you work in the textile or footwear industry.
What is Extended Producer
Responsibility (EPR)?
Extended Producer Responsibility is a principle of European environmental policy under which the producer of a product—the manufacturer, importer, or brand that first places it on the market—assumes responsibility for its management once it becomes waste. Previously, this burden fell primarily on local authorities and consumers; with EPR, it is shifted, at least in part, to the entity that designs and sells the product.
In Spain, Extended Producer Responsibility (EPR) has been in place for years in sectors such as packaging, electrical and electronic equipment, batteries, and industrial oils. What is new is that it is now also being extended to the textile and footwear sector—one of the sectors that generates the most waste and has the lowest recycling rates in the entire European Union.
Objectives: prevention, reuse, and recycling
EPR (Extended Producer Responsibility) does not merely seek to better manage waste once it already exists. Its priority—in line with the European waste hierarchy—is to prevent waste from being generated in the first place by promoting products that are more durable, repairable, and easier to recycle. Only when prevention is not enough do reuse (giving a product a second life) and, ultimately, the recycling of materials come into play.
For the fashion and home textiles sector, this translates into very specific objectives: reducing the volume of clothing and footwear that ends up in landfills or being incinerated, extending the lifespan of garments, and moving toward a truly circular economy, in which materials return to the production cycle instead of becoming waste.
RAP, SIRAP, and SCRAP
It is useful to distinguish three terms that are often conflated:
- EPR: the principle or regulatory framework itself—the legal obligation that falls upon the producer.
- SIRAP (Individual Extended Producer Responsibility System): the arrangement whereby a company assumes, on its own and on an individual basis, all obligations arising from Extended Producer Responsibility (EPR) for the products it places on the market.
- SCRAP (Collective Extended Producer Responsibility System): a non-profit entity, authorized by the authorities, in which several producers join together to collectively fulfill their Extended Producer Responsibility (EPR) obligations, sharing both costs and management.
In practice, for the vast majority of textile and footwear companies, joining a collective system is far more viable than setting up an individual structure: it avoids the need to independently organize the collection, sorting, and treatment of waste across the entire country.
Producer Obligations
The law defines a “waste producer” as not only the manufacturer but also the importer and the brand that introduces a product into the Spanish market for the first time—including sales made via e-commerce platforms. Being classified as a producer entails a number of obligations that are worth understanding in advance, before the regulatory framework is finalized.
Registry of Product Producers
Every producer must register in the Register of Product Producers, specifically within the section for textiles and footwear. Without this registration, a producer cannot legally market their products in Spain. The register records the producer’s identity and the products they place on the market; generally, the registration process can be handled through the collective scheme (SCRAP) to which the company belongs, as this scheme manages the procedure on the company’s behalf.
Financing, organization, and ecodesign
Beyond registration, the producer must:
- To finance the separate collection, sorting, transport, and treatment of waste generated by the products it places on the market.
- To organize or ensure, either directly or through a collective system, the management of such waste.
- Incorporate eco-design criteria: consider the product from the manufacturing stage to ensure it is more durable, repairable, and recyclable, thereby reducing its environmental impact throughout its entire life cycle.
Legal framework for Extended Producer Responsibility (EPR) in the EU and in Spain
Extended Producer Responsibility (EPR) for textiles and footwear does not stem from a single regulation, but rather from a combination of European and Spanish legislation, which is, moreover, currently undergoing further development.
Directiva Marco de Residuos y Directiva (UE) 2025/1892
The Waste Framework Directive (Directive 2008/98/EC) is the European regulation that establishes the general principles for waste policy in the EU, including the waste hierarchy and the very concept of extended producer responsibility.
In September 2025, Directive (EU) 2025/1892 was adopted, amending the framework directive to introduce—for the first time in a harmonized manner—a mandatory Extended Producer Responsibility (EPR) scheme for textile, textile-related, and footwear products across the European Union. This regulation extends the Extended Producer Responsibility model—already established in sectors such as packaging and electrical equipment—to the textile and footwear industry. Key features include the modulation of producers’ financial contributions based on the durability and recyclability of their products (“eco-modulation”), the requirement to implement separate collection systems, and a prohibition on the destruction of unsold surplus products. Member States must have their national EPR schemes operational no later than 2028.
Law 7/2022 (arts. 37 to 54) and regulatory implementation
In Spain, the general framework for Extended Producer Responsibility (EPR) is set out in Law 7/2022, of April 8, on Waste and Contaminated Soils for a Circular Economy—specifically in Articles 37 through 54. This law establishes the general legal regime for Extended Producer Responsibility—covering definitions, financial and organizational obligations, and the authorization of collective schemes—while deferring the specific implementation details for each product category (such as textiles, furniture, or agricultural plastics) to future regulations.
For the textile and footwear sector, this regulatory development is currently being processed through a draft Royal Decree—spearheaded by the Ministry for the Ecological Transition and the Demographic Challenge (MITECO)—which transposes the requirements of Directive (EU) 2025/1892 into our legal framework.
EPR in the textile and footwear sector: current situation
The Spanish textile and footwear sector is currently in a period of regulatory transition. The Extended Producer Responsibility (EPR) obligation is already a reality under European law, and in Spain, it is moving toward final approval.
Affected textile and footwear products
The Extended Producer Responsibility (EPR) regime covers a wide range of products: clothing and textile accessories for domestic or other uses, household linens, footwear, and other textile- or footwear-related products—including those sold remotely via online platforms. Excluded from this regime, among others, are independent tailors who create custom-made items, as well as those who sell second-hand products suitable for reuse—a measure intended specifically to avoid penalizing reuse.
Royal Decree on textile and footwear products
The draft Royal Decree regulating textile and footwear products and the management of their waste—currently undergoing a public consultation process initiated by MITECO—establishes the legal framework applicable to these products throughout their entire life cycle. Key elements include the creation of a dedicated section for textiles and footwear within the Register of Product Producers, the authorization of collective Extended Producer Responsibility (EPR) schemes, requirements regarding information and eco-design, and a penalty regime for cases of non-compliance. Final approval is expected by early 2027, making it advisable to closely monitor its development.
Impact of EPR on textile and footwear companies
Beyond the paperwork, the EPR (Extended Producer Responsibility) has direct operational and economic consequences for any company that manufactures, imports, or distributes textiles or footwear in Spain.
Costs: financial contribution and eco-modulation
Producers will be required to pay a financial contribution—either directly or, more commonly, through a collective system—to fund the collection, sorting, and recycling of textile waste. This contribution will not be fixed; “
Eco-design, durability, and fiber-to-fiber recycling
Regulations are pushing companies to rethink how they design their products: choosing more durable materials, facilitating repairs, and moving toward
Separate collection and a ban on the destruction of unsold surplus items
As of January 1, 2025, Spain is required to implement separate collection of textile waste—a mandate that, in practice, entails the introduction of dedicated collection bins and waste-stream systems distinct from those used for other types of municipal waste. Furthermore, the new European regulations include one of their most widely discussed measures: a ban on the destruction of unsold textile and footwear inventory—subject to very specific exceptions—aimed at curbing the systematic destruction of stock.
Comply with the EPR (Extended Producer Responsibility) for footwear and textiles
Although the Spanish Royal Decree is still in the processing stage, companies in the sector do not need to wait for its final publication to begin preparing.
Steps for manufacturers, importers, and brands
In general terms, any manufacturer, importer, or brand that introduces textiles or footwear into the Spanish market should:
01
Determine whether your activity makes you a “producer” for the purposes of EPR (manufacturing, importing, or selling under your own brand, including online sales).
02
Register in the Registry of Product Producers as soon as the textile and footwear section is operational.
03
Decide whether to fulfill your obligations individually (SIRAP) or by joining a collective system (SCRAP).
04
Review the design of your products incorporating ecodesign and durability criteria.
05
Adapt your supply chain to future separate collection requirements and to demands for traceability and information.
Collective systems for textiles and footwear
For most companies—especially SMEs that lack the internal infrastructure to manage waste on a national scale—the most practical approach is to join a collective extended producer responsibility (EPR) scheme. Such a scheme handles, on behalf of its members, tasks including registration, the organization of waste collection and treatment, and liaison with public authorities, while distributing costs among all members based on eco-modulation criteria.
At Gerescal, we work specifically to address this need: SCRAP Gerescal is a collective system specialized in textiles and footwear that enables manufacturers, importers, and brands to fulfill their Extended Producer Responsibility (EPR) obligations collectively, without the need to establish their own waste management infrastructure.
Frequently Asked Questions about
RAP
Yes. This obligation is already established at the European level by Directive (EU) 2025/1892 and is supported in Spain by Law 7/2022. Its specific implementation for the textile and footwear sectors is currently being finalized through a Royal Decree—which will detail the specific timelines and procedures—but the principle of extended producer responsibility for this sector is no longer up for debate: it is a legal obligation that companies must begin incorporating into their planning.
The difference lies in how the obligation is fulfilled. In an individual system (SIRAP), a company takes on the full management and financing of its own waste. In a collective system (SCRAP), several companies join together under an authorized entity that collectively manages waste collection, treatment, and administrative procedures, thereby sharing both costs and effort. For most producers—especially small and medium-sized enterprises (SMEs)—a collective system is more efficient and cost-effective.
The final timeline will depend on the approval of the Spanish Royal Decree—expected in 2026—which will establish specific deadlines for registration and participation. In any case, it is advisable not to wait until the last minute; gathering information and evaluating participation in a collective system well in advance allows for better cost planning and provides sufficient time to adapt product design.
- Directive (EU) 2025/1892 of 10 September 2025 — EUR-Lex
- Directive (EU) 2025/1892 — publication in the Official State Gazette (BOE) (DOUE-L-2025-81403) — BOE
- Law 7/2022, of 8 April, on Waste and Contaminated Soils for a Circular Economy — BOE
- Draft Royal Decree regulating textile and footwear products and the management of their waste — MITECO