EU Textile EPR Registration: Country-by-Country Guide

EPR registration for textiles is the process of registering your brand as a producer in each EU Member State where you sell clothing, home textiles, or footwear. Under Directive (EU) 2025/1892, every producer must register nationally, join a Producer Responsibility Organisation (PRO), and report annually on the products they place on the market. Not sure if you qualify? Start with EPR for Textiles: Who Must Register and What It Costs.

This guide covers the practical side: country-by-country registration, PRO selection, annual reporting, and the data you should be collecting now, before national schemes go live.

Country-by-Country Registration: One Register Per Member State

There is no single EU-wide EPR register. Under Article 22b of Directive (EU) 2025/1892, every producer must register separately in each Member State where they place textile products on the market. Sell in four countries, register in four countries. Enter a new market next year, and add another registration.

The Commission will adopt a harmonised registration format by April 2027, and a central EU website will link to all national registers. But the registrations themselves remain national. Each one produces a registration number you will need to show to marketplaces, retailers, and distribution partners as proof of compliance.

Timeline: When National Systems Open

Member States have 20 months to transpose the WFD Amendment into national law, and 30 months to get their EPR schemes up and running. Here is what that looks like in practice:

France already operates a textile EPR system through Re_fashion, and the Netherlands, Belgium, and Sweden have also launched early schemes. Don't wait for registration portals to open. Data collection, CN code mapping, and PRO evaluation easily take months.

What Registration Requires

When you register in a Member State, you will need to provide:

• Company identification: Legal name, trademark, brand names, registered address, tax ID, and trade register number
• Product scope: The CN codes of products you place on that market
• Contact point: A single point of contact for the registration (this is not a named compliance officer, just a reachable contact)
• PRO details: Which Producer Responsibility Organisation you have joined, including a mandate from that PRO, or a declaration that you are fulfilling obligations through an individual compliance scheme
• Truthfulness statement: A signed declaration that the information you have provided is accurate

If you sell into the EU from another Member State through distance sales, you'll need to appoint an authorised representative in each country where you register. For companies based outside the EU, individual Member States may also require one. This works similarly to the existing General Product Safety Regulation (GPSR) requirement.

Online Platform Obligations

Under Article 22a(13) of the directive, online marketplaces must verify that producers are registered before allowing them to list textile products. If a producer can't provide a valid registration number and self-certification, the platform must suspend their listings. Major marketplaces like Amazon, Zalando, and About You will almost certainly require EPR registration numbers as a listing condition, just as they require VAT numbers today. Register early so you don't lose market access.

What Is a PRO? How Collective Compliance Works

A Producer Responsibility Organisation (PRO) is a collective compliance body. Instead of running collection and recycling on your own, you join a PRO that pools contributions from many brands and handles everything collectively: collection infrastructure, sorting, reuse and recycling contracts, public awareness campaigns, and consolidated reporting to national authorities.

Each Member State will typically have one or more authorised PROs for textiles. You join one in every country where you sell and pay fees based on your volumes and sustainability performance.

What to Look for in a PRO: 5 Point Checklist

Not all PROs are equal. As textile EPR schemes launch, here is what to evaluate:

1. 1.National authorisation. The PRO must be formally approved by the relevant Member State authority. Verify before signing.
2. 2.Geographic coverage. Does it operate in the Member States you need? Some cover multiple countries; others are national only.
3. 3.Transparent fee methodology. Can you model your costs in advance? Opaque pricing is a red flag.
4. 4.Track record. PROs with experience in packaging or electronics EPR bring operational maturity.
5. 5.Data management capabilities. Can it accept DPP-structured product data? Integration between your DPP platform and PRO will matter as reporting tightens.

PROs for textile EPR are being established now. Monitor developments in your key markets and begin conversations early.

Collection and Sorting: How DPP Data Helps

Your EPR contributions fund separate collection and sorting infrastructure in each Member State. The directive requires sorting for reuse to work at item level. For shipments of used textiles assessed as fit for reuse, records must capture product type, size, colour, and material composition.

This is where DPP data really pays off. A garment whose passport states "100% Tencel, no coatings" routes to recycling immediately. An unidentified garment needs laboratory analysis first, adding cost and delay. Better product data ultimately leads to lower collective EPR costs for everyone.

EPR Annual Reporting: What Data and When

PROs must publish annual data on behalf of their members, covering:

• Total quantity by weight of textile products placed on the market in that Member State
• Separate collection volumes by weight, including unsold products reported separately
• Reuse and recycling rates, including fibre-to-fibre recycling
• Other recovery and disposal rates
• Export rates for collected textiles

Article 22c(20) provides a lighter requirement for microbusinesses (fewer than 10 employees, annual turnover below EUR 2 million). They only need to report total quantities placed on the market. Everyone else provides the full data set through their PRO.

Reporting begins with the first full year of EPR scheme operation. For most Member States, that means 2028 data reported in 2029.

Data to Start Collecting Now

EPR reporting requires product data that many brands don't currently have in a structured, reportable format. Start building this infrastructure today:

• Product weight per SKU. EPR fees are based primarily on weight, with modulation for sustainability criteria. You need accurate weights for every product, including components and trims.
• Sales volumes by Member State. How many units placed on market in each country per year. If you sell through retailers, you need sell-in data from your distribution channel.
• CN code classification. Every product is mapped to the correct EU customs nomenclature code.
• Material composition. Required for fee modulation claims and for sorting facilities using DPP data.

Most brands have some version of this data scattered across PLM systems, supplier spreadsheets, and ERP databases. The real challenge is pulling it all into one structured, reportable format. Toileforge structures product data for DPP compliance, and the same data flows directly into EPR reporting. One data infrastructure, two compliance obligations covered.

Frequently Asked Questions

What is a Producer Responsibility Organisation (PRO)?

A PRO is a collective compliance body that manages textile collection, sorting, recycling, and reporting on behalf of its members. Fashion brands join a PRO in each EU Member State where they sell, pay fees based on sales volumes and sustainability performance, and the PRO fulfils their end-of-life obligations. Think of it as a compliance co-op. See how PROs work for more detail.

When do EU textile EPR schemes become operational?

Under Directive (EU) 2025/1892, national EPR schemes must be fully operational by April 2028. The harmonised registration format is due by April 2027. France, the Netherlands, Belgium, and Sweden already run textile EPR systems. See the full timeline.

What data do fashion brands need for EPR reporting?

Brands need product weight per SKU, sales volumes by EU Member State, CN code classification for each product, and material composition. Microenterprises (fewer than 10 employees and turnover below EUR 2 million) report only totals. See data to start collecting now for a full breakdown.

How do I register for textile EPR in the EU?

You register separately in each EU Member State where you place textile products on the market. Registration requires company identification, CN codes for your products, a point of contact, PRO membership details, and a statement of truthfulness. There is no single EU-wide register. See what registration requires and who must register.

Do online marketplaces need EPR registration numbers?

Yes. Under the directive, online platforms must verify producers' registration before allowing listings of textile products. Producers who cannot show a valid registration number and self-certification will have their listings suspended. Major marketplaces like Amazon and Zalando are expected to enforce this requirement, similar to how they currently enforce VAT numbers.

This article is based on an analysis of Directive (EU) 2025/1892 (the revised Waste Framework Directive, covering textile EPR). National implementation details vary by Member State. Consult legal counsel familiar with EPR regulation in each relevant jurisdiction.

Related reading:

• EU Textile Regulation: A Guide for Fashion Brands
• EPR for Textiles: Who Must Register and What It Costs