10-07-2025
What Textile-to-Textile Recyclers Want From EU Legislation
As far as the T2T Alliance—T2T being short for textile-to-textile, as in recycling—is concerned, the European Union's ecodesign for sustainable products regulation has one massive flaw: it doesn't provide sufficient latitude for different kinds of textile waste.
It's the legislation's exclusion of post-industrial waste from recycled content targets that served as a 'huge, huge, huge' reason for the industry association's formation, said Dolly Vellanki-Seijger, sourcing and public affairs manager at Circ, a Virginia-based firm that aligned itself with the likes of Circulose, Syre, Samsara Eco and Sanko's Re&Up Recycling Technologies after realizing they were dealing with the same issue. As the 'defining textile policy of 2025,' the ESPR is poised to introduce market-entry ecodesign requirements that mandate a marked boost in recycled textile fibers by 2028. This cannot happen by artificially restricting waste to the post-consumer kind, she added.
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'Whether you're a policymaker or a brand or a recycler, we all want to see textile-to-textile recycling scale,' Vellanki-Seijger said. 'Post-industrial waste isn't a low-hanging fruit or just a fallback; it's a viable starting point for us to start building these circular textile-to-textile recycling supply chains. It'll be really difficult to scale if we narrow ourselves down to only one type of waste stream and if that waste stream is post-consumer.'
That's because sourcing exclusively from post-consumer textiles waste as of 2028 is simply not feasible, the T2T Alliance wrote in its inaugural position paper on the forthcoming ESPR delegated act on textiles, meant to amend or supplement non-essential elements of the legislation. And with revisions of the waste framework directive continuing to be subject to delays, pushing back extended producer responsibility schemes to 2028 at the earliest, there won't be enough time to cue up the necessary collection, sorting and processing for recycling capacity, it said.
Other experts agree. Europe's sorting infrastructure is currently primed for reuse, with limited capacity or skill to sort for recycling. There's also the fact that the continent's used textile value chain is itself against the ropes because of the deluge of low-quality, low-value 'fast' fashion amid increasing operational costs. This has left the sector, in the words of organizations like RREUSE and Zero Waste Europe, 'on the brink of financial collapse.'
'Including post-industrial waste in recycled content definitions makes sense given current infrastructure realities,' said Priyanka Khanna, scaling director at Fashion for Good, a sustainable innovation platform headquartered in Amsterdam. 'While post-consumer recycling systems are still developing globally, post-industrial waste provides an immediate source of materials for textile recycling technologies.'
Recyclers prefer post-industrial—or pre-consumer—feedstock because it's easier to obtain large quantities of uniform material with predetermined fiber compositions. Post-consumer waste, with its more dubious provenance, on the other hand, is an iffier proposition, particularly since castoffs collected curbside can have higher levels of contamination from liquids or food waste that can render them unsuitable for recycling.
Critics of allowing the inclusion of post-industrial waste argue that it could incentivize overproduction, drive market distortions or make conditions worse for European collectors and sorters, especially if it's shipped from the global South, where garment manufacturing is in greater abundance. With separate collection systems for used textiles having gone into effect in the EU only in January, however, Vellanki-Seijger said that it will take time not only to socialize the concept but also to gain critical mass in terms of volumes that can be relied upon with some kind of predictable cadence. It's important, she said, to allow things to scale so that 'they can be ready for us when we are open to welcome and accept these types of feedstock.'
'Regardless of how many changes you make in the design practices in optimizing your efficiency, you will always have post-industrial waste,' she added. 'A lot of that post-industrial waste that is sitting in manufacturing regions has historically been directed towards mechanical recycling or downcycling. So what we're offering is a solution for turning that into higher-value recycling so that it can go back into textiles.'
Clara von Luckner, director and fashion lead at advisory and investment company Systemiq, which recently published a report about enabling a textile-to-textile recycling breakthrough in Europe, said that one way of managing the short-term supply gap would be to allow a portion of recycled content to come from post-industrial and pre-consumer waste while 'phasing in a mandatory post-consumer share over time.' Without appropriate guardrails, she said, allowing post-industrial waste as a feedstock source could undercut the core policy objective: bringing Europe's growing volumes of post-consumer textile waste into circular material loops, rather than exporting or incinerating it, often in geographies lacking adequate waste management systems.
'This is especially pressing given the social and environmental consequences visible in places like Ghana and the Atacama desert,' von Luckner said.
Another area of concern would be where the feedstock comes from, something that the position paper doesn't address and is a 'live policy debate 'in other sectors such as packaging and automotive manufacturing. It's a quandary von Luckner expects to come to the fore as policy proposals mature: Should recycled content be sourced from within Europe to support local circularity and investment, and if so, how could this be achieved in practice?
There are other questions, too, such as how much recycled content—no matter where from—is enough? Overall, the T2T Alliance wants to see 'ambitious but realistic' and gradually increasing performance requirements for recycled content at the product level. The organization is suggesting 10 percent by 2028, 15 percent by 2030 and 30 percent by 2035. Right now, Vellanki-Seijger said, there isn't a clear benchmark that it can 'advocate for or go against.'
Phased targets for recycled content can also create the definitive market signals required to drive investment in textile-to-textile recycling innovations, Khanna said. Her experience working with technology companies shows that 'gradual, realistic requirements help brands plan their sourcing strategies while encouraging the investment needed to scale breakthrough recycling technologies.'
Khanna also echoed the T2T Alliance's call for chain-of-custody verification that can 'ensure transparency and build industry trust' with robust tracking systems. A stronger mass balance approach is also needed, perhaps with the aid of emerging digital technologies, she said. While detractors of the practice say it allows companies to make recycled content claims without guaranteeing that the product contains actual recycled materials, proponents say it's necessary to scale sustainable practices.
'We know that in other industries, mass balance has been receiving a little bit of controversial opinion, especially in terms of the information that is given to the consumers,' Vellanki-Seijger said. 'But I think with the other delegated acts—with the digital product passport—we can provide more information to the consumers than what is simply on the label.'
That's where the information requirements that the T2T Alliance is urging come in, as well. Without 'clear, traceable' data on the recycled content within products, validating claims and verifying compliance becomes tricky, paving the way for potential greenwashing, whether inadvertent or not. Vellanki-Seijger, returning to the organization's prime reason for existing, wants to see the opposite by ensuring that the origin of where recycling takes place is without doubt.
'We want to be able to point out if the material is coming from post-industrial or post-consumer sources,' she said. 'And we also want to make sure that what percentage of recycled material is actually in a product is also clear. But this needs to go hand in hand with the performance requirement first.'
As Circ's sourcing czar, Vellanki-Seijger has a personal stake in all this. The company will throw open the doors of its first commercial-scale plant in Saint Avold, France, in 2028. Its expected capacity? 70,000 metric tons of polycotton textiles—a small fraction of the overall market, to be sure, but a sizable amount for a somewhat nascent technology.
'So I'll need to source quite a big volume to be able to feed that facility,' she said. 'And if I only rely on post-consumer, I'm not going to meet the feedstock requirements that I have. So we also need to spread our risk and diversify in terms of where we're sourcing from. And at the end of the day, all waste streams need a solution, not just post-consumer.'
