Debate Intensifies Over Germany’s Extended Producer Responsibility Textile Law

Industry groups raise concerns over compliance burden and classification of footwear under proposed framework
Debate has intensified in Germany following the publication of a new textiles law in late March that outlines plans for an Extended Producer Responsibility (EPR) scheme. Industry representatives have raised concerns about the scope of the proposed regulation, particularly regarding its impact on footwear manufacturers and brands.
The Federal Association of the Footwear and Leather Goods Industry (HDS/L) has warned that incorporating footwear into a textiles-focused EPR framework could overlook the greater material complexity of shoes and may affect competitiveness due to increased compliance requirements and uncertainty.
In a press release, Torben Schütz, Managing Director of HDS/L, criticised the proposed legislation, stating: “The German textiles law published in late March places a considerable burden on our footwear manufacturers and brands.”
He further added, “This is not a measure to promote the international competitiveness of our companies. Instead of reducing bureaucracy, it imposes significant burdens and, further, incalculable costs on our members. This is anything but a business-friendly, efficient policy.”
According to the HDS/L, the proposed law does not adequately address challenges related to fast fashion. The association has specifically raised concerns about treating footwear and clothing under a single regulatory framework, citing differences in product structure and material composition.
“You cannot compare shoes and clothing on a one-to-one basis. The material compositions are much more complex in shoes,” Schütz stated, adding, “What do underpants, t-shirts and sweaters have to do with over-knee boots?”
Germany’s Environment Minister Carsten Schneider has presented key elements for an Extended Producer Responsibility (EPR) scheme for textiles, which forms the basis for a potential national textiles law.
The proposal comes at a time when the CDU/CSU and SPD, German political parties, are indicating a wider reform agenda for the country, referring to a limited “reform window” extending into the summer.
Source: World Footwear