New Rules, New Rewards: How Your DPP Data Can Cut Textile EPR Costs

From 2028, textiles officially enter the EU’s Extended Producer Responsibility (EPR) system due to the revision of the Waste Framework Directive (WFD) (Directive 2025/1892). That means if you are the first to place a textile, textile-related or footwear product on the market in an EU Member State, under your own name or trademark, you’re considered the producer. You’ll need to register, join a producer responsibility organisation (PRO), and help finance the collection and treatment of used products.

Sounds like another layer of regulation as confusing as your basic Yorgos Lanthimos movie? Maybe not,or at least closer to The Favourite than to Dogtooth. The rules come with a long runway and, most importantly, a built-in opportunity for companies that already manage product data well.

What’s covered:
Most household-type textile and footwear products — clothing, home textiles, accessories, shoes — as defined by Combined Nomenclature codes in Annex IVc of the new Directive.

Who’s excluded:
Self-employed tailors producing custom-made textiles for individual clients; companies placing used textiles assessed as fit for re-use or upcycled products derived from them; and products for professional use (including military) that pose safety, health or hygiene risks or raise security concerns.

Key timeline

• By June 2027: Member States must transpose the new rules and create producer registers (Art. 2(1)
• From April 2028: EPR for textiles becomes operational across the EU (New Art. 22(a)(11) to WFD)
• From April 2029: Micro-enterprises (under 10 employees / €2 million turnover) join in (New paragraph to Article 41 of WFD)

In practice, every brand or importer will have to:

• Register once (through harmonised national/EU portals)
• Join a PRO for textile waste management
• Report basic product data annually — with lighter obligations for SMEs

The revision of the WFD links directly to the Ecodesign for Sustainable Products Regulation (ESPR) (Regulation (EU) 2024/1781) and its upcoming Digital Product Passport (DPP) system.
The ecodesign requirements set out through the ESPR framework (such as the delegated act for textiles upcoming in early 2027) will serve as the foundation for eco-modulated EPR fees, meaning that these requirements will form the basis for calculation of financial contributions to be paid to a PRO by a producer (new Art. 22c(5) of the WFD).

The ecodesign requirements set out in the ESPR for the actual product properties will be monitored through information shared in the relevant product’s DPP.

In short: the better your verified product data, the better your design choices, and the lower your EPR fee.
Because, of course, it’s Brussels, the detailed criteria for eco-modulation will be defined in forthcoming Commission implementing acts (new Art. 22c(7) of the WFD), but the direction is clear: better design and better data mean better economics.

The biggest advantage of collecting DPP data today isn’t only compliance — it’s foresight.

When you start mapping your supply chain for the Digital Product Passport, you also start seeing what drives the environmental footprint of your products. And that same footprint will determine your EPR costs once eco-modulated fees come into force.
In simple terms: the cleaner and more circular your inputs, the cheaper your end-of-life bill.

See the difference before the fees kick in

Every supplier choice you make — from fibre source to dyeing process — leaves an environmental trace that will soon translate into euros.
Collecting comparable data now lets you:

• Benchmark your suppliers based on their energy, water, and chemical use, and the recyclability of their outputs.
• Simulate product-level footprints and understand which materials will likely attract higher or lower EPR coefficients once fee-modulation rules are adopted.
• Spot hidden cost drivers — like high microfibre shedding, short lifespans, or difficult-to-recycle blends — before they turn into higher fees.

While the exact weighting of criteria will be confirmed through Commission acts, the key parameters already defined under the ESPR — such as durability, repairability, and recyclability — will form the core of those future calculations (Art. 5, Regulation 2024/1781).

Instead of waiting for the regulation to set the numbers, you can already model where your products will stand — and start improving margins before the competition does.

For companies starting now, the message is simple: the earlier you structure your data, the more leverage you gain. That’s where preparation meets practice — and where the right tools turn data into decisions.

Ovido makes product data easy to collect, compare, and act on — turning compliance data into business intelligence. Our platform doesn’t just gather information for reporting; it helps you use it.
With Ovido, you can:

• Map your entire supply chain and see the environmental impact of each material or supplier in one dashboard.
• Compare scenarios — how swapping a fibre, dyeing process, or finishing treatment affects both footprint and potential EPR exposure
• Collaborate with suppliers to improve data quality and product design without the complexity of multiple spreadsheets or systems.
• Use real data to make strategic sourcing choices that future-proof your business against eco-modulated fees.

This isn’t about “green add-ons”. It’s about redesigning how businesses create and capture value.

Preparing for the DPP now doesn’t just make you compliant — it makes you competitive. Instead of scrambling when EPR rules finally kick in, you’ll already have the understanding on how to minimize your EPR fees — you’ll be able produce smarter, source better, and pay less.

Better data. Better margins. Lower risk. That’s what being open for business means.

The ESPR and the new textile EPR rules are both designed to reward good design.

The ESPR defines what better products look like — durable, repairable, recyclable, and made with safer materials.

The EPR reform ensures that better performance pays off — by linking producer fees to those same design qualities and to the verifiable data that proves them.

Together they turn circular design into an economic advantage: well-designed products backed by transparent data will cost less to place on the market and to manage at end-of-life.

Compliance isn’t paperwork. It’s your new growth channel.Data turns design into measurable value — and that’s precisely where our work at Ovido begins.

Book a coffee with us, and let’s start your digital transition.

Legal references
Directive (EU) 2025/1892 amending Directive 2008/98/EC on waste.
Regulation (EU) 2024/1781 on ecodesign for sustainable products.