#Associations
Joint Statement: Urgent clarification needed on scope of Textiles EPR for PPE and Medical Devices
As Member States begin implementing the Extended Producer Responsibility (EPR) for textiles, a lack of distinction within the Directive’s Annex IVc is causing confusion. Currently, the specified CN codes do not distinguish between standard apparel and essential Personal Protective Equipment (PPE) or Medical Devices (MD).
The joint statement highlights that PPE and Medical Devices are engineered to protect users from hazardous environments, including chemical, biological, and radiological risks. Consequently, these garments often become contaminated and are classified as hazardous waste, requiring incineration—often with energy recovery—rather than recycling, to ensure safety.
Including these products in standard textile EPR schemes poses significant risks:
- Cross-Contamination: Mixing hazardous PPE waste with household textiles threatens human health and environmental safety.
- Regulatory Conflict: Contaminated PPE disposal is already regulated under Articles 13, 17, 18, and 19 of the existing Waste Framework Directive.
- Low Circularity Potential: PPE constitutes less than 1% of textile waste, with 80-90% treated as hazardous. The environmental benefit of recycling the remaining fraction is negligible compared to the transport required to aggregate sufficient volumes.
The statement also calls for guidance on safety shoes. Like other PPE, these items face contamination issues that limit recyclability. Furthermore, manufacturers cannot guarantee product warranties or conformity for reused safety footwear, and the fee scaling for heavy items (e.g., steel-toed boots) remains unclear.
Recital 28 of the Directive already suggests that products posing safety or hygiene risks should be excluded from the EPR. However, this is being overlooked in national implementations, such as in Spain and the Netherlands.
Therefore, the signatories urge the European Commission to issue clear guidance to Member States confirming that products complying with the PPE Regulation (2016/425) and the MD Regulation (2017/745) are outside the scope of the Textiles EPR.
