A coalition of major European trade associations has issued a joint statement highlighting critical safety risks in the current implementation of textile waste rules.
Five major trade associations have warned that the inclusion of hazardous personal protective equipment (PPE) in new textile waste regulations poses significant risks to human health and safety.
The European Safety Federation (ESF), EDANA, CIRFS, EURATEX and EuroCommerce have issued a joint statement highlighting that a lack of distinction within the Directive’s Annex IVc has caused confusion during the implementation of Extended Producer Responsibility (EPR) for textiles .
The organisations noted that current Combined Nomenclature (CN) codes failed to distinguish between standard apparel and essential PPE or medical devices.
In a joint statement released on 8 December 2025, the groups warned that these products were engineered to protect users from hazardous environments, including chemical, biological and radiological risks.
Five major trade associations have warned that the inclusion of hazardous personal protective equipment (PPE) in new textile waste regulations poses significant risks to human health and safety.
The European Safety Federation (ESF), EDANA, CIRFS, EURATEX and Euro Commerce have issued a joint statement highlighting that a lack of distinction within the Directive’s Annex IVc has caused confusion during the implementation of Extended Producer Responsibility (EPR) for textiles .
The organisations noted that current Combined Nomenclature (CN) codes failed to distinguish between standard apparel and essential PPE or medical devices.
In a joint statement released on 8 December 2025, the groups warned that these products were engineered to protect users from hazardous environments, including chemical, biological and radiological risks.
They stated that these garments often became contaminated and were classified as hazardous waste, which required incineration – almost always with energy recovery – rather than recycling to ensure safety.
The signatories argued that including these products in standard textile EPR schemes posed significant risks, primarily regarding cross-contamination. They warned that mixing hazardous PPE waste with household textiles threatened human health and environmental safety.
Furthermore, the groups noted a regulatory conflict, as contaminated PPE disposal was already regulated under Articles 13, 17, 18 and 19 of the existing Waste Framework Directive.
They also highlighted the low circularity potential of the products. According to the statement, PPE constituted less than 1% of textile waste, with between 80 and 90% of that volume treated as hazardous or contaminated waste.
The statement added that sorting out non-contaminated PPE would need to be precise to prevent the potential contamination of household textile waste streams.
It said: “Products for professional uses, including safety uses, that can pose safety, health or hygiene risks, or raise security concerns should be excluded from the extended producer responsibility established for textile, textile-related and footwear products.”
The associations also called for guidance on safety shoes, noting that manufacturers could not guarantee product warranties or conformity for reused safety footwear.
They further highlighted that fee scaling for heavy items, such as steel-toed boots, remained unclear.
Recital 28 of the Directive stated that products posing safety or hygiene risks should be excluded from the EPR, but the groups noted this was being overlooked in national implementations, including in Spain and the Netherlands.
The signatories have urged the European Commission to issue clear guidance to Member States confirming that products complying with the PPE Regulation (2016/425) and the MD Regulation (2017/745) were outside the scope of the Textiles EPR.
