Since July 19 of this year, under Article 25 of the EU's Ecodesign for Sustainable Products Regulation (ESPR), large enterprises operating in the EU have been prohibited from destroying unsold clothing, apparel accessories, and footwear. Medium-sized enterprises will be subject to the ban from July 19, 2030, while micro and small enterprises are exempt. The ban allows for a limited number of exceptions, such as safety risks, legal violations, irreparable damage, or unsuccessful donations.

However, this ban sidesteps a thorny question: where should all that unsold clothing, which can no longer be destroyed, go now? The regulation itself does not specify whether these products should be reused, recycled, or diverted to other waste treatment channels. It restricts destruction but does not establish the corresponding collection networks, recycling capacity, or markets to absorb these materials. This is precisely the gap the industry has avoided discussing for years.

A considerable proportion of European textile waste consists of blended fibers (such as polyester-cotton blends and polyester-viscose blends), which are difficult and costly to recycle. Mechanical recycling can shred fibers but cannot separate blended components, yielding low-value products typically only suitable for insulation materials or wiping cloths; traditional chemical recycling requires single, purified fiber feedstock to be economically viable, and blends do not fit. Newer chemical, enzymatic, and mechanical separation technologies can handle some blends, but contaminants, dyes, coatings, and elastane all add process complexity and cost.

If companies cannot destroy their inventory, the available options are all less than ideal: donation saves money in the short term but is hard to scale and may disrupt second-hand markets in other countries; export often just shifts the waste problem elsewhere; renting warehouses to stockpile; or sending items for recycling, which in practice is mostly downcycling.

The EU has a huge gap in recycling capacity. The European Commission's 2023 impact assessment estimated that EU textile recycling capacity is only about 700,000 to 850,000 tonnes per year, and is mainly open-loop. The European Environment Agency has also warned that the lack of collection and sorting capacity could lead to large amounts of textile waste being incinerated, landfilled, or exported outside the EU. Separation technologies that can truly separate blended fibers have not yet been applied at scale, and installed capacity in Europe is severely insufficient.

The financial fragility of existing infrastructure further highlights this gap: in October 2024, German textile collector Soex filed for bankruptcy; in July 2025, companies under Texaid Deutschland also entered insolvency proceedings. These are not startup recycling technology companies, but the backbone of the infrastructure responsible for collection, sorting, and finding outlets. Their difficulties show that Europe not only has a gap in future recycling plants, but the existing system is already overwhelmed.

Even if recycling capacity were in place, there is still a demand-side problem. Currently, there are no mandatory recycled content requirements for new clothing, footwear, and other products. Brands can recycle a small amount of waste and publicize sustainability achievements while still relying primarily on virgin materials. Recycled fibers often cost more than virgin materials, and without pressure on the demand side, recyclers' products struggle to find a market. The EU has already set recycled content targets for plastic packaging in its packaging waste regulation, and this approach applies equally to textiles, such as setting requirements for recycled textile content, adjusting EPR fees based on virgin material use, or giving recycled fibers a price advantage in public procurement rules. France's EPR scheme already adjusts fees based on textile recyclability, but that is only a start.

An export ban is not the end point. Without building recycling technologies that can truly process blended fibers and enacting demand-side regulations that make recycled content an economically rational choice, this ban will only keep "no burning" on paper. The EU needs a complete policy and industry loop—collection, sorting, separation, regeneration, and reliable demand—to truly move toward circular textiles.

Source: Commentary: Addressing the EU’s new textile rules · Originally published on 2026-08-19