COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste
Date: 2023-07-05
Institutions: Directorate-General for Environment, European Commission
Subjects: circular economy, environmental protection, extended producer responsibility, fight against wastage, food waste, footwear industry, prevention of pollution, single market, textile industry, waste recycling

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   EUROPEAN COMMISSION  Brussels, 5.7.2023  SWD(2023) 422 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste {COM(2023) 420 final} - {SEC(2023) 420 final} - {SWD(2023) 420 final} - {SWD(2023) 421 final}  
 
 
1.  WHAT IS THIS INITIATIVE ABOUT?  

This  impact  assessment  considers  a  possible  revision  of  the  Waste  Framework  Directive 
(WFD) to contribute to the ambition of the European Green Deal in terms of reducing waste 
generation  and  the  transition  to  a  circular  economy,  focusing  on  two  resource  intensive 
sectors: textiles and food.   

Total textile waste, covering clothing and footwear, home textiles, technical textiles, and post-
industrial  and  pre-consumer  waste,  in  2019  amounted  to  12.6  Mt  (10.9  Mt  post-consumer 
waste  and  1.7  Mt  post-industrial  and  pre-consumer  waste).  Clothing  and  footwear  waste 
amounted to 5.2 Mt, equivalent to 12 kg per person per year in the EU. Only about 22% of 
post-consumer  textile  waste,  which  represents  87%  of  textile  waste  generated,  is  collected 
separately  mainly  for  re-use  or  recycling  while  the  rest  is  incinerated  or  landfilled.  Despite 
progress,  separate  collection,  sorting  and  recycling  in  the  EU  are  insufficient  to  handle  the 
additional  quantities  expected  once  the  separate  collection  obligation  materialises  on  1 
January 2025 and textile consumption continues to grow. The problem stems from regulatory, 
market and behavioural drivers: 

  Funding gap to scale up re-use and recycling systems to achieve economies of scale. 
  Regulatory  uncertainty  on  the  application  of  the  definitions  of  ‘textiles’  and  ‘textile 
waste’ leading to gaps and inconsistencies in textile waste flows and hampering cross-
border movements. Increasing regulatory fragmentation due to different approaches to 
separate  collection  and  their  financing  models.  This  hampers  high-quality  feedstock 
needed to scale up re-use and recycling. 
‘Fast-fashion’  trends  flooding  the  market  with  low-cost  clothing  and  textiles. 
Consumers are mostly unaware of the negative environmental externalities of textiles 
across their life cycle, in particular their transboundary impacts on third countries. 

 

Boosting  the  circularity  of  textiles  would  lower  the  use  of  primary  materials  and  help 
mitigating  negative  environmental  externalities.  Harmonising  textile  waste  management 
would facilitate legal certainty on the quality, scale and consistency of the feedstock, thereby 
enabling  stakeholders  (e.g.  Member  States,  local  authorities,  social  enterprises,  waste 
managers, producers, consumers) to maximise re-use and recycling.  

The amount of food waste in the EU reached nearly 59 Mt in 2020. Over half of food waste 
(53%)  is  generated  by  households,  followed  by  the  processing  and  manufacturing  sector 
(20%). 

Despite  the  growing  awareness  of  the  negative  consequences  of  food  waste,  political 
commitments  made  at  EU  and  Member  State  levels  and  EU  measures  implemented  so  far, 
food  waste  generation  is  not  decreasing  as  required  to  make  significant  progress  towards 
Sustainable  Development  Goal  (SDG)  Target  12.3.  Target  12.3  calls  for  halving  per  capita 
global  food  waste  at  retail  and  consumer  level.  Action  taken  to  date  in  Member  States  is 
uneven  and  disparate  and  the  full  potential  for  food  waste  reduction  is  not  realised  as  both 
market and behavioural drivers are not adequately addressed.  

The problem stems from the following main drivers: insufficient consumer food management; 
inefficiencies and trade-offs in the food supply chain; lack of understanding and certainty as 
regards  implementation  of  food  safety  standards;  lack  of  evidence-based,  coordinated 
approaches in Member States, leading to food waste generation going largely unchecked.  

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2.  WHAT IS TO BE ACHIEVED AND WHICH POLICY OPTIONS HAVE BEEN ASSESSED?  

For textile waste, the specific objectives are to  reduce waste generation,  and increase re-use 
and recycling. Three policy options were assessed compared to the baseline: 

  Option  1  aims  to  support  Member  States  in  implementing  and  enforcing  current 
provisions  by  clarifying  definitions,  exercising  existing  Commission  mandates  for 
secondary  legislation,  and  improving  current  stakeholder  platforms  for  guidance  and 
exchange of best practices. 

  Option 2 envisages setting regulatory requirements in the Waste Framework Directive 
to  clarify  definitions  and  reporting  obligations,  set  minimum  requirements  for  the 
collection  and  treatment  of  used  and  waste  textiles  to  ensure  compliance  with  the 
waste  hierarchy.  A  flagship  measure  is  the  establishment  of  an  extended  producer 
responsibility (EPR) for textiles to secure the funding for re-use and recycling systems 
and R&D to maximise circularity of the sector. 

  Option 3 entails setting waste management performance targets. 

For food waste, the specific objectives are to (i) assign clear responsibility to Member States 
for  accelerating  reduction  of  food  waste  along  the  food  value  chain,  and  (ii)  to  ensure 
sufficient and consistent response by all Member States. As the lack of progress is mainly due 
to existing EU measures (regulatory and non-regulatory) not being used to their full potential, 
this initiative focusses solely on setting targets.  

Setting, at EU level, the same target for each Member State should lead each one to taking the 
most effective measures, tailored to its specific national situation. 

The  impacts  and  feasibility  of  three  policy  options  have  been  assessed  covering  different 
target levels set for different stages of the food supply chain – see table. 

2030 food waste reduction 
target on: 
primary production 
processing and 
manufacturing 

retail and consumption  

 Option 1 

Option 2 

Option 3 

n/a 

10% 

15% 

n/a 

10% 

30% 

10% 

25% 

50% 

Option 4 
(voluntary) 
n/a 

n/a 

voluntary 
target 50% 

3.  WHAT IS THE PREFERRED OPTION AND WHY?  

The  preferred  option  for  textiles  is  Option  2,  a  set  of  regulatory  requirements  to  scale  up 
textile re-use and recycling with positive net impacts, potentially complemented by setting a 
separate collection target for textiles (Measure  3.6). The preferred option includes  measures 
ensuring  harmonised  sorting  practices  across  the  EU  to  increase  re-use  and  recycling  and 
reduce the illegal  exports of textiles  waste disguised for re-use purposes  (Measures  2.5, 2.6 
and  2.8),  mandating  setting-up  harmonised  national  EPR  schemes  to  close  the  funding  gap 
(Measure  2.9),  improving  reporting  to  better  monitor  textile  flows  (Measure  2.14),  and 
potentially setting a separate collection target for textile waste (Measure 3.6). 

Regarding  food  waste,  Option  2  will  be  effective  in  providing  a  strong  policy  impulse  for 
Member States to take action to reduce food waste at national level while being proportionate 
and feasible. Therefore, this option is used as a basis to assess the cumulative impacts of this 
initiative (food and textile waste).  

Option  3  offers  the  most  significant  environmental  benefits  and  best  reflects  the  political 
commitment of the EU and its Member States to contribute to the achievement of SDG Target 

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12.3.  However,  given  the  limited  progress  made  across  the  EU  and  therefore  doubtful 
technical feasibility, achieving the target set in this option – by 2030 – will be challenging. 

4.  WHAT ARE THE IMPACTS OF THE PREFERRED OPTION?  

On textile waste, the expected impacts are as follows: 

  The EPR would entail costs for producers/importers placing textiles on the EU market, 
which  may  be  passed  on  to  consumers.  The  costs  are  expected  to  account  for 
approximately  0.6%  of  the  total  cost  of  the  product  (or  €0.12  per  t-shirt),  while 
providing  €3.5-4.5  billion  annual  holistic  returns  for  collection,  sorting,  re-use  and 
recycling investment. The recovery of value is estimated at 58% of the costs.  

  The negative environmental externalities are expected to decrease with greater re-use 
and  recycling,  including  €16  million  savings  from  GHG  emission  reductions  and 
reduced negative impacts on third countries. 

  The social impacts in the EU and third countries are expected to be mitigated. 8 740 
jobs would be created in the waste management sector, including in textile recycling, 
supporting social enterprises in managing used textiles. 

The  textiles  industry  is  dominated  by  SMEs.  Microenterprises  (representing  about  88%  of 
companies and 12% of industry turnover) would be exempted from EPR fees. The impact of 
the preferred option on competitiveness is overall positive. 

Food waste reduction targets are expected to deliver significant environmental benefits (e.g., 
Option 2 leads to a 25% reduction in GHG emissions compared to the baseline) and financial 
savings for consumers (€439/household/year). As reducing food waste can lead to a reduced 
demand for food, the initiative may have some limited impact on farm income and reduce the 
need  for  farm  labour,  which  however  can  be  offset  by  other  measures  (e.g.,  increase  in 
organic farming) and gains in non-food sectors. 

This initiative is considered as relevant for SMEs. However, countries that have undertaken 
coordinated action focus so far on larger businesses and voluntary measures.    

5.  MEASURING SUCCESS?  

The  impact  of  the  preferred  option  for  textile  waste  would  be  monitored  –  if  maintained  – 
through the target set out in Measure 3.6. and based on the improved data flows on textiles as 
a  result  of  Measure  2.14.  The  latter  would  also  future  proof  the  legislation  enabling  further 
performance  target  setting  that  is  currently  assessed  as  not  feasible  under  Option  3. 
Monitoring is based on annual data on textiles reported.  
Monitoring of progress towards food waste reduction targets will be done based on Member 
States’  annual  reporting  according  to  rules  established  already  under  the  WFD.  Moreover, 
implementation of national food waste prevention programmes is subject to periodic reviews 
by the European Environment Agency.  

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