Extended Producer Responsibility (EPR) Compliance

What is Extended Producer Responsibility?

EPR regulations require companies to pay for the waste they produce.

Extended Producer Responsibility (EPR) is a policy approach that makes producers, importers and retailers responsible for the environmental impacts of their products from production through end-of-life. This includes funding of waste management systems like:

Transport of collected materials
Sorting of different fibers and product types
Processing materials into new, high-quality products
Consumer collection systems (e.g., return points, take-back programs)
Program oversight and reporting (management and operational costs)

Goals
Laws & Scope
Reporting
Fees

Goals

EPR programs aim to reduce waste.

Reducing waste at the source

The goal of EPR is to prevent waste and promote circularity. Companies can reduce product impacts across lifecycles (and avoid EPR fees) through:

Durability: Longer-lasting products
Recyclability: Materials stay in use
Traceability: Prevents excess use and wasted materials
Circularity: Turns used materials into high-quality recycled content

Document & Certify Environmental Performance

Laws & Scope

Scope depends on product type and jurisdiction.

Extended Producer Responsibility in the United States

U.S. EPR regulations are defined at the state level, specifying product categories and reporting obligations.

Textiles
- California 2024 Responsible Textile Recovery Act
- California 2013 Used Mattress Recovery and Recycling Act
- California 2010 Carpet Stewardship Law
- Rhode Island 2013 Responsible Recycling, Reuse and Disposal of Mattresses
- New York 2022 Carpet Collection Program Law
- Oregon 2022 Mattress Stewardship Act
Medical
- California 2018 Pharmaceutical and Sharps Waste Stewardship Program
Hardgoods
- Connecticut 2023 Act Concerning Extended Producer Responsibility for Tires

Extended Producer Responsibility in Europe

In the EU, EPR is governed by directives from the European Commission, with each member implementing national laws.

EU Textile EPR law (2025):

Requires brands and retailers to report volumes and pay waste management fees
Covers apparel, footwear, accessories and home textiles
Member states will establish national EPR schemes by April 2028
Companies should prepare data and compliance systems now

EU Factsheet: EPR for Textiles

Reporting

EPR Reporting Requirements

Verified and traceable data supports compliance.

Companies must track product data, including materials, origin and supply chain, to show compliance with EPR programs.

This data gives authorities the information they need to manage waste, recycling and recovery systems (e.g., product categorization and recyclability).

Many reporting requirements are annual, but are required more frequently in some regions. Requirements vary by region and product category and typically include:

Volumes
Weights
Material types
End-of-life management data
Waste treatment processes

Maintaining accurate, organized data ensures reporting and audit efficiency.

Examples of data points for reporting by sector:

Textiles: Quantity, category (e.g., apparel, household), material composition, recycled content %, take-back participation, labeling/consumer information, disposal/recycling processes, fee payments
Hardgoods (non-electronic): Unit sales, weights, material types (e.g., wood, metal, plastics), durability and repair potential, recycled content, collection and recycling/recovery programs, disposal practices, fee payments
Certain medical devices: Applicable categories (e.g., single-use products, electronics-based devices), material composition, disposal pathways, collection/recovery initiatives, and in some cases, specific safety and traceability data

Fees

EPR Fees

Companies are responsible for all EPR compliance costs for their products.

Most EPR programs require a contribution fee (also called an eco-fund), which covers the collection, recycling or proper disposal of end-of-life products. Fees are usually calculated based on product weight, material type and environmental impact.

Other EPR costs could include:

Registration: Enrolling products/companies with relevant authorities/Producer Responsibility Organizations (PROs)
Administrative: Internal labor for reporting and data management
Verification: Third-party audits or inspections to prove compliance
Penalties: Fees for non-compliance, underreporting or late submissions

What is Eco-Modulation?

Companies can cut down on EPR costs by producing more sustainable products.

Eco-modulation is a method of adjusting EPR fees based on a product’s environmental performance.

For example, products made from durable, recyclable or low-impact materials may have reduced fees, while single-use or non-recyclable products may result in higher fees.

This approach encourages companies to integrate sustainable design principles and waste reduction strategies from the product development phase.

As of October 2025, eco-modulation applies in France, Hungary, Latvia, Sweden and the Netherlands. Methods of fee adjustment or reimbursement differ by country. Ongoing adoption of eco-modulation by EU member states is expected.

Design for Less Waste

Sustainable production starts at the design phase.

Linear Model showing one way flow: Take-Make-Consume-Dispose. Circular Model shows Take, Make, Consume, Repair, Reuse/Recycle, back to Make — A linear economy ends in waste, while a circular economy keeps products and materials in use to conserve resources and reduce environmental impact. Opportunities exist across every stage of design to build circularity from the start.

You can reduce waste by creating products that are durable, repairable and easier to recover at end-of-life.

Testing helps companies understand how their products will perform across their entire lifecycles. It also verifies claims and provides the data companies need to back up reports.

Longer-lasting products reduce the need for new materials
Reliable performance helps products last longer and supports sustainability goals
Comfortable and odor-resistant textiles encourage longer use and reduce waste
Washability ensures products maintain their quality through repeated use
Proper fit results in fewer returns
Products that biodegrade reduce landfill waste and environmental pollution
Effective chemical management helps prevent recalls and wasted inventory

OEKO-TEX® Podcast Episode: How Can We Make Our Clothes Last?

Partner for EPR Compliance

Better products mean less waste. Less waste means lower EPR costs.

EPR rules are complex. Hohenstein brings 75 years of research and development expertise to make compliance manageable. Our team supports extended producer responsibility and regulatory requirements with reliable data, smart testing and practical consulting.

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