Evaluating the Limits of Extended Producer Responsibility (EPR) in the Fashion Industry
-
Deborah King
- EPR, Fashion, Sustainability
Abstract
The contemporary fashion industry is the product of profound structural changes in global production systems. Factors including trade liberalization, profit incentives, and comparatively weaker environmental regulations in some developing countries have accelerated production and facilitated the relocation of manufacturing across global supply chains (Ford, 2021; Pouillard, 2023). As production has become geographically fragmented, manufacturing processes have been distanced from consumers, obscuring the social and environmental impacts embedded within garments (Peters et al., 2021). Alongside rising production, clothing consumption and resulting textile waste volumes have expanded across multiple stages of the supply chain (Maity et al. 2020). In response, policymakers are increasingly exploring circular economy mechanisms, including Extended Producer Responsibility (EPR), to manage rising textile waste.
This paper critically examines whether EPR represents an effective and equitable policy response within the fashion sector. Drawing on existing literature, the analysis traces the evolution of the modern fashion system, examines the persistence of linear production and disposal patterns, and considers the international circulation of second-hand clothing. Developments in European textile EPR policy are then used to evaluate the operational realities of contemporary textile waste management. Particular attention is given to infrastructure constraints, technological limitations, funding gaps, and design trade-offs that complicate the implementation of circular systems.
The analysis suggests that while EPR redistributes financial responsibility for end-of-life management, its ability to transform the underlying dynamics of fashion systems remains limited. Recovery infrastructure struggles to scale alongside growing material flows, and recycling technologies remain constrained in both scope and economic feasibility. Meanwhile, cross-border trade dynamics allow substantial volumes of garments to circulate beyond the practical reach of national EPR frameworks. These dynamics may also produce uneven impacts across the industry, potentially placing disproportionate pressure on smaller producers while leaving high-volume cross-border actors outside the scope of national systems. As a result, EPR appears more effective at managing downstream consequences of textile waste than addressing the structural conditions that generate it.
Ultimately, the findings suggest that circular policy instruments alone are unlikely to resolve the textile waste crisis if production volumes and global supply chain dynamics remain unchanged. Without confronting the incentives that sustain overproduction and accelerating consumption, EPR risks redistributing responsibility for waste without fundamentally altering the trajectory, or uneven impacts, of the contemporary fashion system.
Table of Contents
1.0 Evolution of the Global Fashion Industry
1.1 Fast Fashion’s Emergence and Impact
1.2 Textile Waste Generation
2.0 Fashion’s Current Linear Textile Waste Model
2.1 Export of Textile Waste to the Global South
2.2 Limits of a Take-Make-Waste System
3.0 Circular Economy
3.1 Operationalizing Circular Economy Principles in Fashion
4.0 Extended Producer Responsibility (EPR) in Fashion
4.1 Operational Challenges of EPR in the Fashion Sector
4.2 Financial Limitations
4.3 Design Trade-offs and Systemic Rebound
4.4 Distribution Costs Under EPR
5.0 Conclusions
6.0 References
1.0 Evolution of the Global Fashion Industry
Upon its early development in Europe, the fashion industry operated as a regulated trade governed by guilds, with production centralized in local “semi-clusters (Ford, 2021; Pouillard, 2023). Post-war restructuring began to separate manufacturing from retail, gradually loosening localized systems (Pouillard, 2023). However, it was late twentieth-century trade liberalization that fundamentally transformed the industry’s structure (Ford, 2021). The reduction of quotas and tariffs enabled the large-scale relocation of textile manufacturing to lower-cost regions, allowing brands to capitalize on cheaper labor and production inputs (Wyman, 2006; Remy et al., 2016).
Pressure to increase output accelerated outsourcing to countries in the Global South, where regulatory and labor protections were often less stringent (Maity et al. 2020). This geographic fragmentation reduced costs and distanced manufacturing from consumers, obscuring the environmental and social impacts embedded within garments (Peters et al., 2021).
1.1 Fast Fashion’s Emergence and Impact
These structural shifts enabled the rise of the fast fashion model, defined by its “low-priced, [and] trend-led products” (Peters et al., 2021, p.1). Facilitated by reduced trade barriers and dispersed supply chains, apparel production doubled between 2000 and 2014, surpassing 100 billion garments annually (Remy et al., 2016). By 2018, the industry’s estimated market value ranged between $2.4 and $3 trillion USD, with projected growth of 63% by 2030 (Anguelov, 2021).
Deliberate compromises in garment quality and durability underpinned the model’s expansion. To accelerate manufacturing cycles and suppress costs, brands accepted production trade-offs that shortened product lifespans (Maity, 2020; Pouillard, 2023). Workers were instructed to use inferior techniques, such as loosening thread tension to increase sewing speed, resulting in weaker seams and reduced garment longevity (Pouillard, 2023). At the same time, labor conditions intensified, with workers paid less and compelled to compete for precarious employment, culminating in what Pouillard (2023) describes as “the purest example of capitalism” (p. 1231).
This rapid production model fundamentally altered how clothing was valued and used (Peters et al., 2021). As garments became poorly constructed, repair often became “uneconomical or impossible” (Peters et al., 2021, p. 2). Cultural influences, including magazines, celebrity culture, and social media, reinforced cycles of accelerated consumption (Brooks, 2015). Clothing consumption is estimated to have doubled between 1980 and 2020 and is projected to triple between 1980 and 2050 (Maity et al. 2020). These projections may underestimate current trends given the emergence of ultra-fast fashion models in recent years, which utilize direct-to-consumer channels and often bypass traditional trade and border tracking mechanisms.
1.2 Textile Waste Generation
The dramatic increase in apparel production and consumption has significantly expanded textile and apparel waste streams. Waste arises across multiple stages of the supply chain:
• Post-industrial waste: fabric scraps, production samples, and manufacturing errors (Bhatia et al., 2025; Maity et al. 2020).
• Pre-consumer waste: unsold inventory, overproduction, and returns (Bhatia et al., 2025; Maity et al. 2020).
• Post-consumer waste: garments discarded at the end of their useful life (Bhatia et al., 2025; Maity et al. 2020).
Additional waste generated by adjacent industries, such as fashion shoots and runway shows, is often excluded from formal accounting, despite associated emissions and material loss (Norris, 2023).
When it was tracked, the US Environmental Protection Agency reported that textile waste generation increased by 868% between 1960 and 2018 (U.S. Environmental Protection Agency, n.d.). Although approximately 34% of textile waste was recycled or incinerated with energy recovery in 2018, an estimated 11.3 million tons of textiles were still landfilled (U.S. Environmental Protection Agency, n.d.). Globally, textile waste was estimated at 121 million metric tons in 2024 and is projected to reach 180 million metric tons in 2035 (Bhatia et al., 2025). At these levels, textile waste is a major concern, as it contributes to “resource depletion, air and water pollution, and the use of chemicals” across ecosystems (Eremia, 2024, p. 812).
2.0 Fashion’s Current Linear Textile Waste Model
Europe is often regarded as the global leader in textile policy, with integrated frameworks such as the EU strategy for Sustainable and Circular Textiles, the Ecodesign for Sustainable Products Regulation, and the Waste Framework Directive (European Commission, n.d.; European Union, 2022). These initiatives have prompted the gradual development of dedicated collection channels and more formalized waste governance structures across member countries. However, despite these policy developments, measurable outcomes remain limited. Although “less than 1% of textile waste is recycled into textile[s]” (Bhatia et al., 2025, p. 3) globally, Europe’s rate is only marginally higher, at “slightly above 1%” (Bhatia et al., 2025, p. 5).
Despite the density of regulatory instruments, approximately 55% of textile waste in Europe continues to enter conventional waste streams (Bhatia et al., 2025). An additional 10-15% is improperly disposed of through illegal dumping, while roughly 30% is diverted through thrift or take-back programs (Bhatia et al., 2025). Collection performance also varies significantly by country. Germany captures an estimated 60-65% of its textile waste, France approximately 30%, and the Netherlands around 45% (Bhatia et al., 2025). However, collection rates aren’t representative of effective processing.
Infrastructure constraints and limited funding have placed increasing strain on existing systems, with some reportedly “on the brink of collapse” (Bhatia et al., 2025, p. 7). In Germany, despite high collection rates, only 19% of collected textiles are sorted (Bhatia et al., 2025). In France, Le Relais temporarily halted collection operations in 2025 and publicly protested underfunding by depositing unsorted textiles outside major retailers (Bhatia et al., 2025). These examples suggest that formal policy adoption doesn’t necessarily translate into operational resilience.
Collected textiles are ultimately directed to a limited set of pathways: fiber-to-fiber recycling (less than 1%), second-hand markets, downcycling into lower-value materials, conversion into Solid Recovered Fuel, landfilling, or incineration (Bhatia et al., 2025). While regulatory pressures are expected to reduce landfilling rates in Europe, it remains unclear which alternative pathway will absorb increasing volumes of waste given current capacity limitations (Bhatia et al., 2025). Incineration appears to be the most immediate substitute, effectively shifting the problem from material accumulation to carbon emissions (Bhatia et al., 2025).
2.1 Export of Textile Waste to the Global South
A widely utilized outlet for surplus textiles in high-income countries is the export of used apparel to developing nations. Garments not sold through domestic thrift channels are typically transferred to recyclers and salvage brokers, who bundle and ship them overseas (King, 2025). It’s estimated that approximately 80% of donated clothing is exported to countries with limited infrastructure to handle textile waste (Norris, 2023); a dynamic increasingly described as textile waste colonialism.
Following economic liberalization, sub-Saharan Africa emerged as a major destination for second-hand clothing exports (Brooks, 2015). In 2004, imports initially appeared to be welcomed, as an estimated 81% of clothing purchases in Uganda consisted of used garments (Dougherty, 2004). Over time, profit incentives began to distort the trade, as exporters reportedly mixed low-grade and unsellable clothing with higher-demand items to increase margins (Brooks, 2015). These dynamics soon produced unintended consequences, as legal and illegal imports of second-hand clothing began to outcompete and displace local textile and apparel manufacturing across African markets (Brooks, 2015).
Harms to importing countries have intensified, as the quality of exported garments has declined. Importers report that up to half of incoming shipments are of such poor quality that they must be discarded upon arrival (Quashie-Idun, 2024). As trade volumes continue to increase, Kantamanto Market in Ghana has become known as the world’s “largest second-hand market” (Quashie-Idun, 2024, p. 3). In 2022 alone, Ghana’s Port of Tema legally received approximately 121,934 tonnes of second-hand clothing (Quashie-Idun, 2024). This volume translates to about 2345 tonnes per week, nearly the equivalent of an Olympic-sized swimming pool of clothing.
Without sufficient infrastructure or funding to manage this volume, waste accumulation has become acute (Chua, 2024). Each week, up to half a million unsold garments from Kantamanto Market are discarded “in open spaces and informal dumpsites in the city and further afield in the countryside” (Quashie-Idun, 2024, p. 4). Greenpeace Africa reports that some textile waste is burned as fuel, and air quality testing has detected hazardous chemical concentrations exceeding “European safety standards” (Quashie-Idun, 2024, p. 8).
2.2 Limits of a Take-Make-Waste System
The persistence of the linear take-make-waste model reflects the absence of meaningful pre-emptive consideration for what occurs after a garment’s “useful” life (Maity et al. 2020). Historically, clothing was treated as a relatively low-value consumer good, and regulatory attention focused primarily on production and trade instead of end-of-life outcomes. As global output expanded, however, waste volumes increased in parallel, revealing structural blind spots embedded within this model.
Few widespread policies constrain manufacturing volumes, mandate durability standards, or establish robust sector-specific waste protocols (Maity et al., 2020). In this context, the absence of oversight may have enabled escalating production and disposal rates.
These structural limitations help explain why circular economy principles have gained traction as a proposed corrective. As waste streams intensify and disposal systems strain under growing volumes, policymakers increasingly frame circularity as a mechanism to address the downstream consequences of linear expansion (Maity et al. 2020).
3.0 Circular Economy
The circular economy seeks to “revalorize resources” (Pandit et al., 2020, p. 9) by maintaining materials in continuous use without significant loss of value (Eremia, 2024). The term, introduced by Stahel and Reday in 1976, conceptualized an “economy of loops” (Maity et al., 2020, p. 2) in which value is progressively retained through reuse, repair, reconditioning, and ultimately recycling (see Figure 1). Rather than prioritizing throughput, this model aims to extend product functionality and preserve material integrity for as long as possible.
Source: Adapted from Maity et al. (2020).
At its core, the circular economy is intended to be restorative and regenerative, operating through coordinated production systems that minimize waste and reduce resource extraction (Maity et al., 2020). It promotes design strategies that extend product lifespans and reduce material loss, while encouraging more deliberate consumption practices (Maity et al., 2020).
In its idealized form, circularity permits only two end-of-life pathways: biological or technical outputs (Maity et al., 2020; Norris, 2023). Biological materials are designed to safely decompose and return to natural systems, while technical materials are recovered and reintegrated into industrial processes (Maity et al., 2020; Norris, 2023). This framework aligns with McDonough and Braungart’s concept of “design for sustainability,” introduced at the World’s Fair Expo in 2000, which emphasizes extending product life and eliminating the notion of waste (Maity et al., 2020).
Maity et al. (2020) identify four core principles underpinning circular economy theory:
“(i) preservation of the natural capital;
(ii) optimization of the available resources;
(iii) risk reduction; and
(iv) renewable flow of resources and products” (p. 244).
From this perspective, mass production, characteristic of the fast fashion model, directly conflicts with circular principles by accelerating resource extraction and overexploiting natural capital (Maity et al., 2020). Peters et al. (2021) similarly argue that the contemporary fashion industry operates in opposition to circular logic, as it neither maximizes the services derived from “material and energy flows provide[d], nor does it limit these flows to what nature tolerates” (p. 1).
3.1 Operationalizing Circular Economy Principles in Fashion
While circular economy theory presents an idealized model of closed material loops, its practical implementation within fashion remains uneven. Small and independent fashion brands often lead in experimentation with circular strategies, whereas larger firms face structural constraints limited by scale, supply chain complexity, and profit expectations.
Many circular initiatives focus on extending product life, aligning with the inner loops prioritized by Stahel:
• Fitzroy Rentals enables consumers to rent special-occasion dresses, reducing the need for single-use purchases.
• Eileen Fisher and Birds of North America have implemented take-back programs that resell, repair, or repurpose returned clothing, attempting to retain value within the system.
Other initiatives aim to reduce material throughput at the production stage:
• Brands including Copious Fashions and Supramorphous incorporate deadstock and unwanted thrifted materials into new collections.
• Zero Waste Daniel designs garments from pre-industrial waste, cutting scraps.
• Malaika New York uses zero-waste pattern cutting to eliminate production offcuts.
Recycling represents the outermost loop of circularity and is sparingly employed across the industry:
• Canadian brand Simply Merino partners with a US-based textile recycler to process its mono-fiber wool production scraps.
Some larger luxury brands have begun experimenting with digital tools to reduce waste indirectly. Versace, for example, has explored augmented reality technologies that allow consumers to virtually try on garments, intending to minimize returns and associated disposal (Lal, 2023; Norris, 2023)
Despite these initiatives, system transformation remains limited. Anguelov (2021) argues that there is currently no abatement technology capable of offsetting the environmental impacts of large-scale textile production. Although larger brands could invest in cleaner production, financial incentives remain aligned with volume growth rather than material reduction (Anguelov, 2021). In this context, voluntary circular practices coexist with continued overproduction.
Escalating waste volumes and rising landfill costs have therefore prompted some regulatory intervention. France became the first country to formalize textile waste governance through Extended Producer Responsibility (EPR), codified in Article L-541-10-3 of the Code de l’Environnement (King, 2024). The emergence of EPR marks a shift from voluntary experimentation toward mandated producer responsibility.
4.0 Extended Producer Responsibility (EPR) in Fashion
Global waste generation has reached unprecedented levels. As of 2025, the World Bank estimates that “two billion tonnes of waste” are produced annually, with projections suggesting this figure could double to four billion tonnes by 2050 (Zhang et al., 2025, p. 1). Rising waste volumes impose significant financial strain on municipalities, which traditionally subsidize collection and disposal through public funds. Against this backdrop, policymakers have increasingly turned to EPR as a mechanism to reallocate these costs to producers (Atasu, 2019).
EPR is a policy framework that extends producer accountability across the product lifecycle, including end-of-life management (King, 2024). Rather than managing waste directly, producers typically fulfill their obligations by paying fees to a Producer Responsibility Organization (PRO), which oversees collection, sorting, recycling, reporting, and compliance (King, 2024). In France, for example, most fashion brands operate under the PRO Refashion, formerly Eco-TLC (King, 2024). Through this structure, EPR seeks to internalize costs that were previously externalized to municipalities.
Beyond financial reallocation, EPR was originally conceived as a design-for-environment instrument (Atasu, 2019). By linking fees to product recyclability, the policy aims to incentivize producers to reduce environmental impacts upstream (Atasu, 2019). In theory, products that are easier and less costly to process at end-of-life should be rewarded within the system.
If functioning as intended, EPR would progressively increase material recovery rates, scale alongside growing waste volumes, and remain fully funded through producer contributions. It would thereby redistribute financial responsibility and stimulate systemic shifts in product design and material use.
4.1 Operational Challenges of EPR in the Fashion Sector
Designing an effective EPR system for textiles requires extensive physical infrastructure and coordination across multiple stages of the waste management chain (see Figure 2).
Source: Author’s illustration.
A. Clothing Drop-Off
To ensure equitable participation, collection points must be accessible across urban, rural, and remote communities. These sites require protection from weather and pests to prevent material degradation and contamination. Without appropriate design and maintenance, drop-off points risk becoming overflow locations, which can lead to dumping and reduce the usability of collected garments.
B. Collection and Storage Depots
Once collected, textiles must be transported and consolidated at regional depots prior to sorting. Collection schedules must be carefully coordinated to prevent capacity overload as consumption volumes continue to rise. Depots, therefore, require sufficient space to scale with increasing textile flows and must be equipped to store material safely until processed. Maintaining these systems requires coordinated vehicle fleets and storage infrastructure capable of handling large material volumes while preserving the integrity of collected garments.
C. Sorting
Sorting represents one of the most significant bottlenecks in textile EPR systems. Despite ongoing innovation, no scalable technology currently exists that can reliably sort garments across the full complexity of fiber types, blends, dyes, and chemical finishes (King, 2024).
Manual sorting also presents substantial challenges, as garment labels are often missing, illegible, or inaccurate. Additionally, the growing volume of textiles makes individual inspection increasingly impractical (Norris, 2023). While experienced sorters may rely on tactile assessment to identify fibers, this method cannot account for chemical treatments embedded within fabrics (Norris, 2023). As material heterogeneity increases, the complexity and labor intensity of sorting rise accordingly.
D. Recycling
Even when materials are successfully sorted, recycling technologies remain limited in both scope and scalability. Mechanical recycling degrades fiber quality and typically requires blending with virgin inputs, limiting the potential for true circularity (Bhatia et al., 2025). Chemical recycling offers the theoretical possibility of closed-loop recovery without quality loss, but remains cost-intensive and technologically constrained (Bhatia et al., 2025; King, 2024).
Textile blends present a particularly acute challenge. Current chemical processes can isolate only one fiber type within blended materials, destroying the remaining components (King, 2024). Given that the majority of garments on the market are estimated to contain blended fibers, large-scale fiber-to-fiber recycling remains structurally constrained (Dottle & Gu, 2022). As a result, Anguelov (2021) argues that under current technological conditions, it is impossible to “recycle clothes in a way that can constitute an ecological improvement” (p. 59).
4.2 Financial Limitations
In addition to the operational and technological constraints outlined, each stage of a textile EPR system requires significant financial investment. Beyond these logistical costs, recycling itself remains economically intensive. Scaling fiber-to-fiber recycling infrastructure requires substantial capital investment in specialized facilities and processing technologies (Bhatia et al., 2025). At the same time, the environmental performance of emerging recycling technologies must still be evaluated to ensure that emissions reductions outweigh the energy and resource inputs required for their operation.
A. Funding Growth Within Textile EPR Systems
Evidence from France illustrates the financial pressures facing textile EPR systems. Eco-fees collected through the national PRO have increased substantially in recent years (see Figure 3). Reported collections rose from €25.5 million in 2019 to €139.1 million in 2024, reflecting growing policy efforts to fund textile recovery systems (Eco-TLC, 2020; Refashion, 2025). Despite this rapid growth in fee revenues, available analyses suggest that funding levels remain insufficient to support the infrastructure required for large-scale textile collection, sorting, and recycling (Bhatia et al., 2025).
Source: Author’s compilation based on Eco-TLC and Refashion reports (Eco-TLC, 2020; Roccanova, 2021; Refashion, 2022; Refashion, 2024; Refashion, 2025).
Note: Eco-TLC rebranded as Refashion in 2020. Financial data for 2022 was not publicly disclosed.
B. Material Flow Pressures Within the System
Rising fee revenues must be considered alongside the volume of textiles entering the system. As illustrated in Figure 4, the quantity of textiles placed on the French market has steadily increased in recent years, while collection volumes have grown modestly. In 2024 alone, approximately 891,000 tonnes of textiles were placed on the market in France, compared with roughly 289,000 tonnes collected through recovery systems (Refashion, 2025).
Source: Author’s compilation based on Eco-TLC and Refashion reports (Eco-TLC, 2020; ESS France, 2021; Refashion, 2022; Refashion, 2023; Refashion, 2024; Refashion, 2025).
Taken together, these trends suggest that even as funding mechanisms expand, textile production continues to outpace recovery capacity. The Boston Consulting Group notes that existing EPR systems remain structurally under-resourced relative to the scale of textile waste generated (Bhatia et al., 2025). In particular, available financing mechanisms do not yet align with the volume of materials entering the system (Bhatia et al., 2025). As a result, recovery infrastructure may expand incrementally, but it struggles to keep pace as overall material throughput continues to rise.
4.3 Design Trade-offs and Systemic Rebound
EPR frameworks often prioritize recyclability within product design (Lakhan, 2025). While this objective aligns with circular theory, it introduces important trade-offs. Designing garments for ease of recycling may compromise durability or functionality (Atasu, 2019). From a life-cycle perspective, it remains unclear whether prioritizing recyclability over longevity yields a net environmental benefit (Atasu, 2019).
France’s system illustrates another potential distortion, as EPR textile fees are calculated based on garment weight (King, 2024). This pricing structure may incentivize producers to reduce garment weight in order to lower their financial liability. Such design responses risk undermining garment durability, thereby shortening use phases and accelerating replacement cycles.
EPR may also generate unintended rebound effects. Similar to Jevons’ paradox, where efficiency gains lead to increased overall consumption, enhanced end-of-life management may create the perception that clothing consumption carries fewer environmental consequences. This perception could inadvertently reinforce purchasing behaviors instead of moderating them (Atasu, 2019).
4.4 Distribution Costs Under EPR
Under most EPR frameworks, fees are paid by the brand owner or licensee (Kennedy, 2024). If these entities are not locally established, the importers or retailers assume the obligation (Kennedy, 2024). While this structure captures domestic retail sales, it may not adequately address ultra-fast fashion models that rely on direct-to-consumer cross-border sales.
In these cases, garments are shipped directly from overseas warehouses to consumers, bypassing domestic importers and retailers that would normally be responsible for EPR compliance. As a result, companies operating primarily through this model, such as Chinese ultra-fast fashion retailer Shein, may fall outside the practical reach of national EPR schemes.
Although figures are not publicly disclosed, estimates suggest that Shein generated over $48 billion USD in sales in 2024 (ECDB 2025). Given that Shein’s average item prices range between $5 and $15, this revenue could represent between 3.2 and 9.6 billion garments sold in a single year. As illustrated in Figure 5, the company’s rapid growth highlights the scale that direct-to-consumer cross-border distribution models can reach. The volume of garments associated with this business model raises important questions about the practicality of nationally bounded EPR frameworks. As larger quantities of clothing enter markets through cross-border e-commerce channels, enforcing producer responsibility becomes uncertain when producers operate outside the jurisdiction of national EPR schemes.
Source: Adapted from ECDB (2018)
Note: Shein does not publicly disclose detailed financial statements. Figures represent widely cited industry estimates.
Furthermore, while EPR is framed as shifting costs to producers, these expenses are frequently passed on to consumers through price adjustments (Kennedy, 2024; Lakhan, 2025). This dynamic may disproportionately affect smaller apparel businesses operating on thin margins, potentially making ultra-fast fashion alternatives even more price-competitive as they remain outside the fee structure.
Finally, although EPR reduces municipal waste management expenditures, these public funds are not returned to taxpayers and are instead reallocated within broader fiscal systems (Lakhan, 2025). In this sense, the financial burden associated with textile waste is redistributed rather than eliminated.
5.0 Conclusions
Fashion is deeply intertwined with culture, art, and identity (Maity et al., 2020). However, the contemporary system has reduced garments to low-cost, rapidly disposable goods. Circular economy discourse promises improved resource stewardship and slower material cycles. In this context, EPR represents a logical policy response to rising textile waste by reallocating end-of-life costs to producers.
However, this analysis highlights several limitations of EPR when applied to the fashion sector. Operational bottlenecks, technological constraints, funding insufficiencies, design trade-offs, rebound efforts, and uneven global enforcement all complicate the implementation of textile EPR systems.
While large multinational firms may be able to absorb or pass on compliance costs, smaller producers and artisans operating on narrow margins may face disproportionate financial pressure. At the same time, ultra-fast fashion companies operating through direct-to-consumer cross-border sales channels may fall outside the reach of national EPR schemes. Without careful policy design, these dynamics risk reinforcing existing inequalities within the industry.
More fundamentally, neither circular economy framing nor EPR directly addresses the scale of production and consumption driving textile waste generation in the first place. As long as incentive structures reward high-volume output, the underlying drivers of waste remain intact. France provides a telling example: despite implementing textile EPR nearly two decades ago, the volume of textiles entering the French market has continued to increase (see Figure 4). During that same period, fast fashion consumption has remained robust, with France reported to be the fifth largest market for ultra-fast fashion retailer Shein (FRANCE 24 English, 2026). Together, these trends raise important questions about whether EPR meaningfully transforms production systems or primarily manages their downstream consequences.
Critics, therefore, argue that meaningful reform requires confronting deeper political and economic structures, including calls to “decolonize the industry” and reconsider who benefits from existing trade relationships (Norris, 2023). Although this analysis focused primarily on waste governance, textile policy cannot be separated from broader social conditions embedded within global apparel production. The industry employs approximately 300 million workers worldwide and fails to provide basic economic and social foundations for many (Norris, 2023). Unsafe conditions, forced labor, and poverty remain persistent realities in many regions responsible for producing clothing for global markets. Policies designed to address textile waste must therefore account for both environmental outcomes and their broader distributional effects.
Ultimately, if circular policy instruments fail to confront production volumes and transboundary power dynamics, they risk reinforcing the very system they aim to reform. As Kennedy (2024) observes, “even the most well-designed textile EPR regulation cannot fix the most significant contributors to the problem of textile waste: the overproduction and overconsumption of textile waste” (Kennedy, 2024).
Acknowledgements
This paper was developed as part of the Master of Environmental Studies (MES) program at York University and forms part of the author’s ongoing research into circular economy policy, textile waste, and global fashion systems.
Deborah King
Deborah is a sustainable fashion expert located in Toronto, Canada. She’s an Industrial Engineer with a post-grad in Sustainable Fashion Production, and is currently pursuing a Master in Environmental Studies. She grew up on the tiny island of Tortola in the British Virgin Islands, and has been sewing her own clothing since the age of 10. She founded Global Measure to help authentically sustainable and ethical fashion businesses stand out from the greenwashing noise through third-party certification.
Curious to explore EPR further or interested in potential collaborations? Dive into our comprehensive Case Study for a deeper understanding.
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