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

Who must declare: every marketer — manufacturer, distributor or importer — placing clothing, footwear or household linen on the French market, including foreign companies selling into France and sales through any channel (own site, marketplace, stores, franchisees, discount outlets, rentals, donations, staff sales).
Territorial scope: metropolitan France plus the overseas departments and collectivities (Guadeloupe, Martinique, French Guiana, Réunion, Mayotte, Saint Pierre and Miquelon, Saint Martin).
The declaration window: 14 January to 28 February in the 2026 schedule (15 January to 28 February in 2025), filed online through Refashion's member extranet (adherent.refashion.fr), covering the actual volumes placed on the market the previous year.
Invoicing and payment: 14 January to 31 March in the 2026 schedule (15 January to 31 March in 2025) — this covers both the balance owed on the prior year's actual eco-fee and a new eco-fee call for the current year, which Refashion estimates from the prior year's declared volumes and then adjusts the following year once real figures are in.
New producers: declare "0" automatically in their first partial year, then true up with real volumes at the beginning of the following year.
Simplified declaration (optional): marketers placing fewer than 5,000 items a year on the market and declaring no products eligible for eco-modulation may use Refashion's simplified declaration instead of the detailed one, charged at an increased per-piece rate by product family (2026 scale: clothing €0.5799, household linen €0.6525, footwear €0.6414) — registration and declaration are still required.
Non-France-established producers: Article L541-10-9-1 of the Code de l'environnement — created by Loi n° 2026-602 of 8 July 2026 to reduce the environmental impact of the textile industry, in force since 10 July 2026 — requires any person not established in France and subject to a French EPR scheme to appoint a France-established representative by written mandate. It's framed as a general, cross-sector rule rather than one written only for textiles, but it binds TLC producers the same as every other French EPR filière.

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

Who it covers: producers, importers and foreign suppliers placing clothing (including work and industrial clothing), bed and table linen, or household linen (towels, tea towels) on the Dutch market for the first time. Resellers of second-hand textile products are explicitly excluded.
No volume threshold: unlike France's simplified declaration for low volumes (which still requires registration and declaration), the Dutch scheme has no minimum-quantity exemption at all — a single commercial item placed on the market triggers registration.
Registration: required with Rijkswaterstaat within six weeks of the obligation first applying to you. Producers not established in the Netherlands must appoint a Netherlands-based authorised representative.
Annual reporting: due before 1 August each year, stating the weight (in kg, per product category) of the textile products placed on the market the previous year, together with data on compliance with the obligations and targets, on the collection system and on informing waste holders.
Compliance route: individually, or by joining a producer organisation that takes on the obligation collectively.
Rising targets through 2030: in 2025, 50% of the weight of the textile products placed on the market the previous year must be prepared for re-use or recycled (rising 5 points a year to 75% by 2030); 20% must be prepared for re-use (rising to 25%); 10% must be prepared for re-use in the Netherlands, which the ministerial reporting rules read as textile actually re-used there (rising to 15%); and, of the prior year's textile products that are recycled, at least 25% by weight must be recycled fibre-to-fibre (rising to 33% by 2030).

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

Scope: the decree's own textile-product annex lists, by customs (CN) code: leather apparel and accessories (CN 4203), other leather articles (CN 4205), artificial fur articles (CN 4304), carpets and other textile floor coverings (Chapter 57), knitted or crocheted apparel (Chapter 61), and further chapters covering woven apparel, linens and footwear — a broader explicit list than the Netherlands', and notably the only one of the three that explicitly includes carpets, which aren't in the EU-wide floor's own product list.
No minimum threshold: as with the Netherlands, there is no de-minimis exemption — a single garment or pair of shoes placed on the Hungarian market triggers the obligation.
Reporting frequency: quarterly, not annual. The decree's own text requires data on the quarter's volumes to be reported to the national waste management authority by the 20th day of the month following the end of that quarter — four filings a year rather than one.
Payment: the concessionaire invoices the fee based on that quarterly data, and the producer pays within 15 days of receiving the invoice — so the payment deadline itself floats with invoicing, even though the underlying reporting cadence is fixed. Where a quarter's fee, excluding VAT, would come to less than HUF 1,000, it is not invoiced for that quarter but accumulated until the amounts not yet invoiced reach HUF 1,000 (after the fourth quarter of the year an invoice is issued in any case); this concerns invoicing only, not the quarterly reporting duty.
Fees: charged by weight; publicly reported rates moved from 145 HUF/kg to 164 HUF/kg effective 1 October 2025.
Enforcement: reported to have tightened since April 2025, with administrative fines for producers that miss a quarterly filing or payment, on top of the outstanding fee itself.

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.

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5. Side by side

Country	Running since	Registration body	Reporting frequency	Minimum threshold	Small-producer accommodation
France	2007 (current legal basis: AGEC law, 2020)	Refashion	Annual (Jan–Feb declaration)	None	Optional simplified declaration under 5,000 items/year
Netherlands	1 July 2023	Rijkswaterstaat	Annual (before 1 Aug)	None	None identified
Hungary	2023 (phased: Apr–Jul)	National waste management authority / MOHU	Quarterly	None	None 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

EU-wide legal floorDirective (EU) 2025/1892 of 10 September 2025, amending Directive 2008/98/EC — entered into force 16 October 2025; Article 22a(10)–(11) (paragraph 10: cost coverage for products first made available from 16 October 2025 where a scheme already existed). See our full EU-wide textile EPR guide for the complete legal mechanism. CELEX 32025L1892 ↗
Commission proposal — authorised representativesProposal for a Directive of the European Parliament and of the Council suspending the application of the rules on the appointment of authorised representatives for extended producer responsibility for waste, waste electrical and electronical equipment and single use plastic waste, COM(2025) 983 final, 10 December 2025, procedure 2025/0396(COD): Article 1, point (a) (suspension of Article 22a(3) of Directive 2008/98/EC until 1 January 2035). Status checked on 21.10.2026 on the EUR-Lex procedure page (ongoing), the Legislative Observatory (which, next to a vote entry of 20.10.2026, still listed the status as awaiting Parliament's position in first reading), Parliament report A10-0267/2026 of 9 October 2026, the minutes and the text adopted of 20 October 2026 (P10_TA(2026)0344) and the Council press release of 24 June 2026. CELEX 52025PC0983 ↗ Legislative Observatory ↗ Minutes of 20 October 2026, item 6.3 ↗ Text adopted P10_TA(2026)0344 ↗
FranceCode de l'environnement, Articles L541-10 and L541-10-1 (point 11°: textile, footwear and household-linen EPR category), as modernised by Loi n° 2020-105 of 10 February 2020 (AGEC); Article L541-10-9-1, created by Loi n° 2026-602 of 8 July 2026, in force since 10 July 2026 (authorised-representative requirement). Reporting mechanics per Refashion's own member guidance; simplified-declaration criteria and the 2026 per-piece scale per Refashion's Eco-fee guide 2026 (Appendix II) and its FAQ on the differences between simplified and detailed declarations; declaration and payment windows per Refashion's Eco-fee guides 2026 and 2025. Refashion — declaration obligations ↗
NetherlandsBesluit uitgebreide producentenverantwoordelijkheid textiel, Stb. 2023, 132 (BWBR0048093) — Article 1 (scope: clothing and household textiles only, no footwear; section 9.1.2 of the explanatory memorandum in the same Staatsblad also lists shoes (chapter 64) expressly among the products not covered), Article 2 (authorised representative of producers not established in the Netherlands), Articles 3–5 (year-by-year targets through 2030), Article 7 (annual reporting before 1 August), Article 8 (in force 1 July 2023). Registration mechanics (Rijkswaterstaat, six-week window) and the content of the annual report (Article 5(1)) sit in the general Besluit regeling voor uitgebreide producentenverantwoordelijkheid (BWBR0044197), not this textile-specific decree; the report form, whose Part B(2) asks for the total weight in kg per product category, is Annex II to the Regeling uitgebreide producentenverantwoordelijkheid textiel (BWBR0048299). The announced extension to footwear and other textile products, with the new obligations applying at the latest from spring 2028, is described by Rijkswaterstaat on the Afval Circulair site (page on the new rules for the collection, re-use and recycling of textiles and footwear ↗). wetten.overheid.nl — consolidated text ↗
Sweden — what's coming nextRegeringen.se, government assignment to Naturvårdsverket of 4 December 2025 to design a national textile EPR system under the EU waste directive; final report due 13 November 2026; proposals for any legal amendments due 1 September 2026 (interim report of 27 August 2026, ref. NV-25-057557; government consultation of 25 September 2026, case KN2026/01849, responses due 30 December 2026, Regeringen.se — consultation ↗). Regeringen.se — government assignment ↗
Germany — what's coming nextBundesumweltministerium (BMUKN), Eckpunktepapier zur Einführung einer erweiterten Herstellerverantwortung für Textilien (key-points paper on a planned national textile law), as of 27 March 2026; comments invited until 24 April 2026. BMUKN — Eckpunktepapier ↗
HungaryGovernment Decree No. 80/2023. (III. 14.) a kiterjesztett gyártói felelősségi rendszer működésének részletes szabályairól (consolidated text), Annex 1 (1. melléklet), point 1.10 (textile product CN codes), §21(1)–(1d) (fee payable within 15 days of the invoice; small amounts accumulated before invoicing), §27(1) (quarterly data reporting, by the 20th of the month following the quarter), §36 (phased entry into force: 1 April / 1 May / 1 July 2023). Concessionaire identity (MOHU MOL Hulladékgazdálkodási Zrt., under a 35-year concession from 1 July 2023) and the 1 October 2025 fee-rate change (145→164 HUF/kg) are set in separate instruments from this decree and are sourced from converging Hungarian business press and professional-compliance reporting (KPMG, EY, PwC, Accace and others independently cite the same figures and date). net.jogtar.hu — consolidated text ↗
Latvia — not covered hereCabinet Regulation No 359 of 11 June 2024, Noteikumi par ražotāja paplašinātās atbildības sistēmas izveidi un piemērošanu tekstilizstrādājumiem (regulations on the establishment and application of an extended producer responsibility system for textile products; English wording ours, there is no official translation), published in Latvijas Vēstnesis No 115 of 14 June 2024, in force since 1 July 2024 (point 35); the State Environmental Service (Valsts vides dienests) decides on the management contracts and on the exemption from the natural resources tax provided for in it (points 1.6 and 4). This comparison does not analyse the Latvian system. likumi.lv — Cabinet Regulation No 359 ↗

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.