Legal Alert: New EU requirements on preventing food and textile waste – changes to the Waste Framework Directive

On September 9, 2025, the European Parliament adopted amendments to Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing certain directives (the so-called Waste Framework Directive). The new rules introduce the first binding EU targets for reducing food waste and establish extended producer responsibility (EPR) for textile producers.

These changes reflect growing awareness of the scale and consequences of waste. Each year, nearly 60 million tonnes of food waste (about 132 kg per person) and 12.6 million tonnes of textile waste are generated in the EU. It is estimated that around 20% of food produced in Europe is wasted, resulting in significant economic and ethical losses, as well as unnecessary resource use and greenhouse gas emissions. The textile sector is also among the most resource-intensive, as clothing and fabric production consumes vast amounts of water and energy, and textile waste is an increasing environmental burden (textiles account for about 5% of the EU’s total environmental footprint). In addition, synthetic fibres released when washing clothes are a significant source of microplastics in the oceans. In response to these challenges, the EU has decided to take legislative action as part of a broader circular economy strategy and the objectives of the European Green Deal.

The amendment to the Waste Framework Directive introduces, for the first time, binding food waste reduction targets that Member States must achieve at the national level by 31 December 2030. These targets are divided by stages of the supply chain and set as percentages relative to the average annual amount of food waste generated in 2021–2023:

• 10% reduction – by 2030, food waste in the food processing and manufacturing sector must decrease by 10% compared to the 2021–2023 baseline. This target applies to the entire food processing and production industry.
• 30% reduction per capita – by 2030, food waste per capita at the distribution and consumption stages (combined) must be reduced by 30%. This covers retail, food services (such as restaurants and catering), and households. The reduction is measured as the combined decrease in waste generated by these sectors per inhabitant.

These targets are intended to fulfill the EU’s commitment under the UN 2030 Agenda, although the EU has set the reduction target at 30% (instead of 50%) as a more realistic goal under current conditions. Achieving these objectives will require decisive action throughout the supply chain. Member States will need to update their food waste prevention programs within two years of the new rules coming into force, including educational campaigns, support for innovation, and changes in distribution models.

The Directive clearly states that these targets must not compromise food quality or place an excessive burden on agricultural suppliers. Instead, the focus is on supporting innovative solutions and best practices among both businesses and consumers.

National administrations are likely to introduce new regulations affecting business practices, such as mandatory reporting of food waste levels, setting sector-specific sub-targets, or promoting voluntary agreements with industry. An important element will also be the obligation to facilitate donations of edible food (e.g., to food banks) instead of disposal. For businesses, this means the need to establish efficient mechanisms for redirecting unsold products for social purposes.

The second pillar of the amendment concerns textiles, introducing EU-wide extended producer responsibility (EPR) rules. Until now, textiles have not been covered by a unified EPR system—although, from 2025, Member States must ensure separate collection of textile waste, there has been no EU-level mechanism for funding and managing their recycling. Now, textile producers will be required to finance the entire waste management process, similar to existing systems for electrical equipment or the planned packaging solutions in Poland.

The EPR system will cover virtually all textiles and footwear placed on the consumer market, including clothing, accessories, headwear, footwear, blankets, bedding, table linen, and curtains, regardless of material. Additionally, Member States may extend obligations to mattress producers. This broad scope is intended to prevent circumvention of the rules by reclassifying products or changing customs nomenclature.

Each EU country will have to implement a national EPR system for textiles within 30 months of the amending directive’s entry into force. In practice, this means that by around 2028, all companies manufacturing or importing textiles into the EU market will have to participate in a registration system and pay fees covering the costs of separate collection, sorting, recycling, and disposal of waste. Member States will be required to establish public producer registers and ensure that collection systems cover the entire country. Fees may vary, for example, being higher for less durable products and lower for those designed for reuse or recycling.

Producer obligations include:

• Financing the collection and processing of textile waste – producers (individually or through EPR organizations) must cover the costs of managing all textiles, including those ending up in mixed waste or collected by social organizations.
• Registration and reporting – obligation to register in each EU country where products are placed on the market, providing identification data and reporting product mass. Non-EU sellers will be required to appoint an authorized representative in the EU.
• Ecodesign and consumer education – fees will depend, among other things, on product durability or recyclability, and producers/EPR organizations will be required to conduct consumer education activities.

These obligations do not apply to companies exclusively selling used clothing or to tailors making bespoke garments. Micro-enterprises will have an extended adaptation period and will be required to comply with EPR requirements one year later than other producers.

It is worth noting that with the expansion of business obligations regarding reporting, registration, and financing waste management, updates to the catalogue of sanctions in national regulations can also be expected. Member States will be required to ensure effective implementation of the new rules in accordance with Article 36 of the Waste Framework Directive, which in practice may mean the introduction of new administrative penalties for violations of EPR obligations and food waste reduction requirements.

The amending provisions also introduce new definitions into the Waste Framework Directive, including in particular:

a)    Producer of textile, textile-related, or footwear products (as listed in Annex IVc) – any entity that manufactures, imports, distributes, or places such products on the EU market for the first time under its own brand, regardless of the distribution channel, including online sales, as well as foreign entities selling directly to consumers in the EU. Exemptions include, among others, suppliers of used clothing and individual tailors making bespoke garments.

b)    Producer responsibility organisation – a legal entity that acts on behalf of producers, taking over the obligations related to the EPR system. This organisation is responsible for organizing and financing the collection, processing, and reporting of textile waste, as well as conducting educational activities and cooperating with relevant supervisory authorities.

The amendment also introduces other terms, such as “making available on the market,” “online platform,” “social economy entity,” and “unsold consumer product,” which provide greater precision and a uniform interpretation of the new obligations across the EU.

The new provisions will formally enter into force 20 days after publication in the EU Official Journal. Member States will have 20 months to adopt national legislation implementing the new solutions set out in the amending directive, while EPR systems themselves must be operational no later than 30 months after the rules enter into force (for micro-enterprises – within 42 months).

For companies in the food sector, the new regulations mean the need for more effective supply chain management and the introduction of measures to reduce food waste, including monitoring and reporting. In practice, this may involve obligations to report losses, make unsold food available for social purposes, or implement technological and process solutions that help minimize waste.

The textile industry will face not only formal registration and reporting requirements, but also the need to adapt business models to the costs of operating within the EPR system—including participation in producer responsibility organisations, managing new financial burdens, and ensuring compliance at the national level. For many companies, especially those operating in the fast fashion model or internationally, this will mean increased costs, the need to analyze supply chains, and the development of offerings in line with ecodesign principles. At the same time, the new regulations are expected to foster new business models (e.g. recycling, reuse, textile sorting services) and may serve as an impetus for investment in sustainable solutions.

The 2025 amendment to the EU Waste Directive marks a breakthrough in reducing food and textile waste. For the first time, binding food waste reduction targets will be introduced across the EU, requiring commitment from both governments and businesses. Extending producer responsibility to the textile sector means fundamental changes for the fashion industry, promoting recycling and more sustainable solutions. The new regulations are designed to support the circular economy, reduce unnecessary emissions, and address the problems of microplastics and landfill waste. For companies, early adaptation of business models to the new requirements will be crucial—not only to avoid sanctions, but also to build a competitive advantage in an increasingly sustainable EU market.

Awareness of new obligations is one thing, but effective implementation within a company requires detailed knowledge and planning. Our team closely monitors legislative developments in Brussels as well as preparations for the implementation of these regulations in Poland and other EU countries. We offer comprehensive support for companies in the sectors affected by the amendment, in particular:

• Legal requirements analysis – we will conduct an audit of your company’s current compliance status with upcoming regulations and identify areas that require adjustment.
• Advice on loss reduction and reporting – we will help you develop and implement internal procedures for monitoring food waste, waste reporting, and prevention programs, so you can meet future national requirements while optimizing operational processes.
• Preparation for the EPR system – we will advise you on how to best prepare for new obligations regarding textiles: from support with EPR system registration, through verification of contracts with business partners in light of new requirements, to strategies for managing product fee costs. We can also represent your company in dialogue with EPR organizations and administrative authorities when shaping the details of the system.