Brussels, 8 December 2025 – A coalition of European and sectoral associations published a joint statement expressing concern about the early national transposition of Directive (EU) 2025/1892 (the revision of the Waste Framework Directive introducing an Extended Producer Responsibility (EPR) scheme for textiles and footwear).
The signatories warn that personal protective equipment (PPE) and medical devices (MD)—including items such as surgical gowns and drapes—risk being incorrectly included in national EPR scopes because the Directive’s Annex IVc uses CN codes that do not distinguish between ordinary apparel textiles and regulated protective products. This is already creating confusion in some Member States, with risks of improper handling and disposal of potentially hazardous materials.
PPE and medical devices are engineered to meet strict requirements under the PPE Regulation (EU) 2016/425 and the Medical Devices Regulation (EU) 2017/745. Many PPE items, especially those used in healthcare and industrial settings, can become contaminated and must be treated as hazardous waste, often requiring incineration (frequently with energy recovery) under existing waste rules. Mixing these streams with household textiles could increase the risk of cross-contamination, with serious implications for human health and environmental protection.
The associations underline that Recital 28 of Directive (EU) 2025/1892 explicitly indicates that professional products that can pose safety, health, or hygiene risks should be excluded from the textiles EPR. They also request clarity on the treatment of shoes—especially safety shoes—where contamination risks, uncertainty on take-back conditions, and questions around eco-modulated fees (including weight-based approaches for heavy footwear like steel-toed boots) remain unresolved.
Finally, the statement notes that PPE waste represents less than 1% of textile waste in Europe, and an estimated 80–90% of that PPE waste is treated as hazardous or contaminated, leaving limited realistic potential for reuse or recycling at scale.
Recommendation
The signatories therefore urge the European Commission to issue clear guidance to Member States confirming that products compliant with the PPE Regulation (EU) 2016/425 and the Medical Devices Regulation (EU) 2017/745 are outside the scope of the textiles EPR, due to the health and safety risks they may pose.
Read the full statement.