COUNTRY COMPARISON

Which EU Countries Already Have Textile EPR? France, Netherlands and Hungary Compared

Published 01.10.2026 · Updated 21.10.2026 · Reading time ~10 min · by Lior Gabriel Graetz · LG Fashion Labs

Every EU member state will have to run a textile extended producer responsibility (EPR) scheme by 17 April 2028, under Directive (EU) 2025/1892. But that's the floor, not the full picture: some countries already run their own schemes today, years ahead of that deadline. This guide compares three of them — France, the Netherlands and Hungary — and if you sell into any of those three, you have real registration and reporting obligations right now — not in 2028.

This guide doesn't re-explain the EU-wide law — that's covered in full here. It answers a narrower, more practical question: exactly how do three of the countries that already have textile EPR running — France, the Netherlands and Hungary — actually work, and how do their reporting calendars differ? They are not the only ones: Latvia has also run a textile EPR system since 1 July 2024 (Cabinet Regulation No 359 of 11 June 2024), which this comparison does not cover.

3 countries compared, all live today

France, the Netherlands and Hungary already run textile EPR — years before the EU-wide 2028 deadline. Latvia also has a scheme, not covered here.

1, 1, and 4 filings/year

France and the Netherlands each require one annual declaration; Hungary requires quarterly reporting.

16 Oct 2025

The cut-off date in the EU directive: where a scheme already existed, Member States must ensure that producers cover the costs of used and waste textiles first made available on the market from this date (transposition by 17 June 2027).

1. Three countries, three systems, one EU floor underneath

Textile EPR did not start with the EU. France built the first scheme back in 2007, long before Brussels mandated anything. The Netherlands and Hungary both launched their own national schemes in 2023. Directive (EU) 2025/1892 — which amends the Waste Framework Directive (2008/98/EC) — only came later, in 2025, to turn this patchwork into a mandatory floor that every member state must meet by 17 April 2028.

That creates an uneven landscape brands need to navigate carefully. The three early movers compared here each built their own registration body, their own reporting calendar, and in some cases their own product scope — before the EU-wide rules existed to harmonise any of it. The directive does not retroactively rewrite how France, the Netherlands or Hungary already run their schemes; it sets a minimum everyone else must eventually reach. One EU-wide rule is already on the books for countries like these, though: where a scheme was already established under Articles 8 and 8a of the Waste Framework Directive on 16 October 2025 (the date on which Directive (EU) 2025/1892 entered into force), Article 22a(10) requires Member States to ensure that producers cover the costs referred to in Article 22a(8) for used and waste textile, textile-related and footwear products listed in Annex IVc, deposited at collection points set up under Article 22c(8) and (11), that were made available on the market for the first time from that date (the directive itself must be transposed by 17 June 2027 at the latest) — a detail easy to miss if you're only tracking the 2028 headline deadline.

2. France — Refashion

France's textile EPR sits on the "filière TLC" (Textiles d'habillement, Linge de maison, Chaussures — clothing textiles, household linen, footwear), legally grounded in Articles L541-10 and L541-10-1 (point 11°) of the Code de l'environnement, as modernised by the AGEC law of 10 February 2020 (Loi anti-gaspillage pour une économie circulaire). The scheme is overseen by the French state (via ADEME) and run day to day by Refashion, the sole eco-organisme approved to manage this sector, currently under an approval ("agrément") running through the end of 2028.

How Refashion reporting actually works

One annual declaration, with a forecast-then-true-up fee model

3. Netherlands — UPV Textiel

The Dutch scheme runs under the Besluit uitgebreide producentenverantwoordelijkheid textiel (the "Besluit UPV textiel"), a decree signed 14 April 2023 and published in the Staatsblad (Stb. 2023, 132), in force since 1 July 2023. It is administered by Rijkswaterstaat, part of the Dutch Ministry of Infrastructure and Water Management.

How UPV Textiel reporting actually works

No minimum threshold, one annual report

One point worth flagging: footwear is not covered by the Dutch scheme at present, unlike France's and Hungary's schemes. Under its Article 1 the decree applies only to clothing (CN chapters 61 and 62) and household textiles (CN heading 6302: table, bed and household linen); the decree's explanatory memorandum (nota van toelichting) lists shoes (CN chapter 64) expressly among the products that fall outside the scheme, and the Dutch government has announced that the scheme will be extended to footwear and other textile products, with the new obligations applying at the latest from spring 2028. Brands selling footwear into the Netherlands should follow that extension, since until then the national scheme and the EU-wide floor (which brings footwear into scope everywhere via Annex IVc, regardless of what any single national scheme currently covers) do not line up.

4. Hungary — the MOHU system

Hungary's scheme runs under Government Decree No. 80/2023. (III. 14.) on the detailed rules of the extended producer responsibility system — a general EPR framework decree covering eleven product streams (packaging, single-use plastic products, electrical and electronic equipment, batteries, vehicles, tyres, office paper, advertising paper, cooking oil and fat, textile products and wooden furniture), with textile products as their own numbered stream (code 20). It entered into force in three stages: the decree as a whole on 1 April 2023, the registration provisions (§23) on 1 May 2023, and a further set of substantive provisions — including the individual-compliance contracting framework — on 1 July 2023. Day-to-day administration runs through the state-designated national waste management concessionaire (publicly reported as MOHU), alongside data reporting to the national waste management authority.

How Hungary's reporting actually works

Quarterly, not annual — the only one of the three schemes compared that doesn't follow the calendar-year model

The decree number, entry-into-force dates, textile product scope and the quarterly 20th-of-the-month reporting deadline above were verified directly against the consolidated Hungarian legal text on net.jogtar.hu. The concessionaire's identity (publicly reported as MOHU) and the specific fee-rate and enforcement figures are drawn from converging professional-compliance sources rather than this decree's own text, since fee rates and the concession appointment are set in separate instruments.

DPP AUDIT

EPR and the DPP are two different compliance tracks.

Textile EPR is about who pays for waste; the Digital Product Passport is about what data travels with the product. We help you build the data infrastructure correctly once, regardless of which EU country's EPR scheme you're registering with. Under NDA.

Start Your DPP Audit

5. Side by side

CountryRunning sinceRegistration bodyReporting frequencyMinimum thresholdSmall-producer accommodation
France2007 (current legal basis: AGEC law, 2020)RefashionAnnual (Jan–Feb declaration)NoneOptional simplified declaration under 5,000 items/year
Netherlands1 July 2023RijkswaterstaatAnnual (before 1 Aug)NoneNone identified
Hungary2023 (phased: Apr–Jul)National waste management authority / MOHUQuarterlyNoneNone identified

The pattern that matters most for a brand selling across all three: France and the Netherlands both ask for one well-defined annual filing, but on different dates and through entirely different portals — there's no shared calendar to rely on. Hungary breaks that pattern entirely with quarterly filings, meaning a brand active in all three countries is never more than a few months away from a reporting deadline somewhere.

6. Who's coming next

Every other EU member state is working toward the same 17 April 2028 deadline, but most are still at the drafting stage. Sweden's government tasked its environmental agency (Naturvårdsverket) on 4 December 2025 with designing a national textile EPR system; the agency delivered its proposal for legal amendments in an interim report dated 27 August 2026 (ahead of the 1 September 2026 deadline), which the government sent out for consultation on 25 September 2026 (responses due by 30 December 2026), and its final report is due by 13 November 2026 — all ahead of the general 17 June 2027 transposition deadline. Germany's environment ministry (BMUKN) published a key-points paper on 27 March 2026 (the "Eckpunktepapier zur Einführung einer erweiterten Herstellerverantwortung für Textilien") for a planned national "Textilgesetz"; the deadline for comments was 24 April 2026 — no final German law has been published yet. The EU-wide floor guide covers this transposition timeline and the harmonised minimum requirements in full detail.

What that means practically: in a country where no national textile EPR scheme is running, you don't yet have a national EPR filing to make — but that window is closing country by country between now and April 2028, not all at once on a single date. France, the Netherlands and Hungary are not the only countries with a scheme already in place (Latvia has one too), so check each market you sell into.

Status update, 21 October 2026

EU proposal on authorised representatives: not adopted

The Commission proposal COM(2025) 983 (procedure 2025/0396(COD)) would suspend, until 1 January 2035, the rule in Article 22a(3) of the Waste Framework Directive (Directive 2008/98/EC) under which a producer selling by distance contract from another Member State must appoint an authorised representative for extended producer responsibility in the Member State where it sells. The proposal concerns this appointment duty only (its title also names the corresponding rules for electrical and electronic equipment and single-use plastics). It would not change the EU-wide dates in this guide (transposition by 17 June 2027; schemes established by 17 April 2028), and it does not suspend registration, fee or reporting obligations.

As of 21 October 2026 the proposal has not been adopted. On 20 October 2026 the European Parliament adopted its amendments to the proposal (text adopted P10_TA(2026)0344, based on report A10-0267/2026 of its Environment Committee) and referred the file back to the committee for interinstitutional negotiations (Rule 60(4) of its Rules of Procedure). The amendments would limit the suspension to micro and small enterprises established in the Union and end it on the earlier of 1 January 2035 and the date of application of a Union legal act establishing a horizontal framework for extended producer responsibility. On 24 June 2026 the Council announced that its negotiations on the proposal were discontinued. The French and Dutch authorised-representative requirements described in this guide are national law.

Frequently asked questions

Which EU countries already have a textile EPR scheme running? +
As of this writing, at least four. Three of them are compared in this guide: France (since 2007, now run by Refashion), the Netherlands (since 1 July 2023, under the Besluit uitgebreide producentenverantwoordelijkheid textiel), and Hungary (since 2023, under Government Decree 80/2023, run through the MOHU system). A fourth, which this comparison does not cover, is Latvia (a textile EPR system since 1 July 2024 under Cabinet Regulation No 359 of 11 June 2024). Every other EU member state must have a scheme operating by 17 April 2028 at the latest under Directive (EU) 2025/1892, and most are still drafting their national rules.
Do France, the Netherlands and Hungary report on the same schedule? +
No, and the difference matters operationally. France requires one annual declaration (volumes for the prior year reported between 14 January and 28 February in the 2026 schedule, with fees invoiced by 31 March). The Netherlands also reports annually, but on a different date — before 1 August each year. Hungary reports quarterly, with each report due by the 20th day of the month after the quarter ends — four filings a year instead of one.
Is there a minimum sales volume before textile EPR applies? +
In the Netherlands and Hungary, no — a single garment (in Hungary, also a single pair of shoes) placed on the market triggers registration and reporting obligations. France does not have a volume threshold for the underlying obligation either, but it offers an optional simplified declaration for marketers placing fewer than 5,000 items a year on the market (provided they declare no products eligible for eco-modulation), charged at an increased per-piece rate by product family — registration and declaration are still required.
Does the Netherlands' textile EPR scheme cover footwear? +
No, not at present. The Dutch scheme covers only clothing (including work and industrial clothing), bed and table linen, and household linen; the decree's explanatory memorandum lists shoes expressly among the products that are not covered. This is narrower than France's scheme, which explicitly covers footwear, and Hungary's, which also explicitly lists footwear. The Dutch government has announced that the scheme will be extended to footwear, with the new obligations applying at the latest from spring 2028; brands selling footwear into the Netherlands should follow that extension, since until then the national scheme's scope and the incoming EU-wide floor (which covers footwear everywhere via Annex IVc) do not line up.
If my country doesn't have textile EPR yet, do I have any obligations now? +
Not under your own country's law until its scheme launches, but you already have obligations if you sell into France, the Netherlands or Hungary, regardless of where your brand is based (Latvia also has its own scheme, in force since 1 July 2024, which this guide does not cover). Directive (EU) 2025/1892 also contains a narrower EU-wide rule: in any Member State that already had a scheme established under Articles 8 and 8a of the Waste Framework Directive on 16 October 2025, Article 22a(10) requires Member States to ensure that producers cover the costs referred to in Article 22a(8) for used and waste textile, textile-related and footwear products listed in Annex IVc, deposited at collection points set up under Article 22c(8) and (11), that were made available on the market for the first time from that date (the directive itself must be transposed by 17 June 2027 at the latest) — one more reason why brands already selling into these three countries should not wait for their own home country's scheme to catch up.

Sources

The legal and official sources were accessed and verified directly against primary legal text or official government guidance on 01.10.2026, including Hungary's own consolidated decree text; Refashion's reporting mechanics come from its own guides and FAQ, and the identity of the Hungarian concessionaire and the fee rates from converging professional sources (see above). Sources added after that date (Latvia, Germany, the Dutch explanatory memorandum, general EPR decree, implementing regulation and government page, and Refashion's 2025 and 2026 guides) were checked on 13.10.2026, except the Swedish interim report and government consultation (Regeringen.se, Naturvårdsverket), which were checked on 20.10.2026. The status of the Commission proposal COM(2025) 983 was checked on 21.10.2026. National EPR schemes change frequently — verify current requirements with the relevant national authority before acting. This is general information, not legal, financial or investment advice.