RREUSE’s Feedback to the 2023 Targeted Revision of the Waste Framework Directive
RREUSE supports the proposed revision of the Waste Framework Directive, recognising its significance in acknowledging the pivotal role of social enterprises in promoting textile re-use. Social enterprises are key enablers of the transitioning to a circular and sustainable textile value chain, all the while creating local jobs and fostering inclusion for people distanced from the labour market.
Nonetheless, further clarification and improvements on certain aspects of the legislation are needed to increase both effectiveness and ambition, especially on provisions linked to upcoming EPR schemes on textiles.
Firstly, the text tends to refer to social enterprises as “non-waste operators,” despite their accreditation as waste operators. More clarity on this point is needed to create legal certainty for social enterprises involved in textile waste collection and management within EPR schemes.
Furthermore, the proposal should provide more guidance about the needed involvement of social enterprises in the decision-making procedures of the EPR schemes. The introduction to the proposal emphasises the importance of involving social enterprises in the governance of EPR schemes, but this is not reflected in any provision within the legal text, representing a missed opportunity to realise higher environmental and social benefits through the establishment of EPRs for textiles. The EPR fee is also a crucial tool for providing the necessary incentives for a more sustainable textile value chain, but it can also be employed to foster the inclusion of vulnerable people through employment in social enterprises involved in the textile re-use, repair and recycling of textiles. To this end, a portion of the EPR fee should be earmarked to fund training and inclusion activities carried out by social enterprises, on the model of the French “Solidarity Re-use Fund”.
On the environmental side, strong eco-modulation is a prerequisite to encourage the manufacturing more circular and sustainable textiles. However, the proposal currently excludes certain products from the scope of eco-modulation, thus distortingincentives for circularity, including for product categories with significant sustainability challenges such as footwear and leather. RREUSE believes that all products in the scope of the EPR should also be in the scope of eco-modulation to ensure that the right incentives are in place to design more circular textile products to facilitate collection and management in the context of EPR schemes. Furthermore, encouraging competition between PROs should be avoided to prevent races to the bottom lowering environmental standards, including by reducing the amount of EPR fees. The absence of quantitative targets for prevention and (preparation for) re-use is unfortunately a glaring omission that overlooks the EPs call for such targets, which are already in place in several Member States. Therefore, RREUSE continues to advocate for the establishment of such targets to drive investments and collaboration to increase the circularity of textiles.
In conclusion, RREUSE sincerely welcomes this revision of the Waste Framework Directive, but also highlights areas for improvement and anticipates fruitful collaboration with policymakers and stakeholders interested in fostering higher environmental and social responsibility in the circular textile value chain.