EUROPEAN COMMISSION

Brussels, 5.7.2023

SWD(2023) 421 final

COMMISSION STAFF WORKING DOCUMENT

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) 422 final}

Annex 11: Impacts of the policy measures/options

1-Textiles

Option 1: Supporting Member States to implement and enforce current provisions

Measure 1.1 – Clarifying definitions in relation to textiles and textile waste    

Measure 1.2 – Adopting EU wide waste prevention indicators for textiles    

Measure 1.3 – Providing Member States with guidance and support in dialogue on the management of textile waste between actors involved    

Option 2: Setting additional regulatory requirements to improve performance

Measure 2.5 – Setting sorting obligations for separately collected textiles and textiles waste    

Measure 2.6 – Adopting end of waste criteria    

Measure 2.8 – Setting requirements for shipments of textiles for reuse    

Measure 2.9 – Mandating the use of EPR    

Measure 2.14 – Setting reporting obligations for textiles    

Option 3: Prescribing performance targets

Measure 3.1 – Setting an EU textile waste reduction target    

Measure 3.4 – Setting a preparation for reuse target for textiles    

Measure 3.5 – Setting a reuse target    

Measure 3.6 – Setting a separate collection target for textile waste    

Measure 3.8 – Setting a recycling target for textiles    

Overall impacts of the measures    

2.Food waste

2.1.Impact of reduction scenarios on food waste quantities

2.2.Environmental impacts

2.2.1.    MAGNET model    

2.2.1.1.    Emissions    

2.2.1.2.    Land use    

2.2.1.3.    Footprints (consumption, households)    

2.2.1.4.    Virtual trade – systemic view    

2.2.2.    Bottom-up analysis    

2.2.3.    Comparison of the two approaches    

2.3.Economic impacts

2.3.1.    Demand impacts    

2.3.2.    Price impacts    

2.3.3.    Production impacts    

2.3.4.    Trade impacts    

2.3.5.    GDP and income    

2.3.6.    Estimated adjustment costs associated with food waste reduction    

2.4.Social impacts

2.4.1.    Employment    

2.4.2.    Income distribution    

2.4.3.    Food affordability    

2.5.Other impacts

2.5.1.    SDGs    

2.5.2.    Territorial impacts    

2.5.3.    Impact on SMEs    

2.5.4.    Bioeconomy and innovation    

2.5.5.    Food packaging    

2.6.Feasibility analysis

Annex 12: How do the options compare

1-Textiles

2-Food Waste

Annex 13: Preferred option

1-Textiles

Impacts on competitiveness

Impacts on third countries

2-Food Waste

Impacts on competitiveness

Impacts on third countries

3 - Combined effects of the preferred measures on textiles and food waste

Annex 14: Monitoring and evaluation

1-Textiles

2-Food Waste

Annex 15: SME test

1-Textiles

2-Food Waste

Annex 16: Related stakeholder and citizens’ engagement

1-Citizens’ Report from the European Commission’s citizens’ panel on food waste

Topic block I – Cooperation in the food value chain: From farm to fork

Topic block II - Food business initiatives

Topic block III - Supporting consumer behavioral change

Annex 17: Bibliography and list of figures

Bibliography for textiles waste

Bibliography for food waste

List of figures

Annex 11: Impacts of the policy measures/options

1-Textiles 

The present chapter summarises the main impacts that could be expected from the implementation of options and measures identified in Annex 10. All three options will have economic, social and environmental impacts through a variety of channels. Based on desk research and interviews with stakeholders, the most significant impacts have been identified. This section provides an assessment of the retained measures. A quantitative assessment was performed, whenever possible, and a justification provided why a quantitative approach was not feasible. Otherwise, a qualitative assessment is provided.

In all cases the costs and benefits assessed are considered to relate directly to the measures concerned i.e., causal costs and benefits are allocated to each measure. In cases where costs and benefits would be expected to accrue under the baseline only the additional costs and benefits stemming from the measure itself are included. In the case of measure 2.9, by way of example, the resulting amounts of textiles that would be collected, sorted, reused, recycled and disposed of are the same as in the baseline. The changes resulting from the measure itself relate to the way in which those changes are funded and compliance assessed. It is these causal impacts that are, therefore, presented in this Annex.

Option 1: Supporting Member States to implement and enforce current provisions

Measure 1.1 – Clarifying definitions in relation to textiles and textile waste

Sub-measure 1.1 – Definition of ‘textiles’

Assessment of impact alternative 1

Economic impacts

Defining textiles in line with the Textile Labelling Regulation would enable a full life cycle approach to be taken for textiles in relation to their initial labelling, their management under the WFD as regards their reuse and waste management at the end of their lifespan. The definition would include raw, semi-worked, worked, semi-manufactured, manufactured, semi-made-up or made-up products encompassing a broad range of textile goods including, for example, yarns, floor coverings and carpets and would make clear that action to mitigate the environmental impacts of this broad family of textiles should be taken addressing both pre-consumer and post-consumer textiles. However, this definition is far broader than what is considered in practice as textiles in Member States and what is currently separately collected. Hence additional textile goods would be subject to the obligations currently applicable with consequent changes in waste management systems given the currently low levels of separate collection of those materials.

The volumes of these additional textiles collected under this broader scope are estimated at 4 million tonnes per year. It could be expected that for at least a proportion of these textiles where options for reuse and recycling exist that increases in such activities would take place. As noted below under environmental impacts mattresses currently have a reuse and recycling rate of 20% across the EU and carpets have a rate of 1-3%. Including such materials in the scope of textiles under this definition and acknowledging the obligations that would then apply including the separate collection obligation under Article 11, these rates or reuse and recycling would be expected to increase. However, it is not possible to credibly quantify the additional tonnes that may be able to be reused or recycled due to insufficient data available.

This definition would pose challenges in relation to waste collection infrastructure, for example for floor coverings and carpets that are typically considered as bulky waste. Were Member States to collect 50% of this additional textile quantity (in keeping with the estimated trend for 50% collection of clothing and household textiles by 2035) the additional collection costs would amount to at least 660 million euro per year. Treatment costs for this broader family of textiles would vary given the nature of the materials collected. The reuse and recycling of floor coverings and carpets also bears little resemblance to the techniques applied to clothing and other household textiles and their possible comingling under this definition may hamper these processes rather than support them and separating them from the other less bulky textile wastes, predominantly clothing and household textiles, would entail additional costs. The manner in which these costs would be applied to this broader scope of products is likely to vary. In countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then costs may be met via the likes of disposal fees applied at the point of disposal or general taxation. The extent of these additional costs is difficult to determine. As noted in Annex 4, an impact of 0.6% of the cost of a textile item for collection, sorting and treatment has been identified as the nearest proxy for the costs of discarded textiles. A similar cost may be expected to be applied in the case of a broader scope of textiles under this sub-measure.

Footwear is not subject to the Textile Labelling Regulation. The textile component of footwear is addressed under Directive 94/11/EC relating to labelling of the materials used in the main components of footwear for sale to the consumer 1 . For those Member States that consider footwear to be included in textile waste under the WFD defining textiles based on the Textile Labelling Regulation would specifically exclude footwear for the purpose of the legislative measures within the WFD specifically targeting textiles despite the fact that the European List of Wastes does not provide a separate listing for footwear or shoes, and it is assumed that footwear is captured under codes 20 01 10 (clothes) or 20 01 11 (textiles). This contradiction could be somewhat tempered by making clear that Member States may choose to allow other apparel products such as shoes, belts or jewellery to be collected in the same collection systems as textiles (it is estimated by the JRC that footwear accounts for 5-7.5% of weight collected in separate collection systems at present). For the EPR scheme (measure 2.9), this would also cover the costs of collection and sorting of shoes and possibly other apparel included in the scope of the collection. Given the relatively small proportion by weight of these goods and their reuse value, the expected impact of allowing additional items to be collected is likely to be small but would in the case of lower quality footwear make schemes less profitable overall.

Leather clothing and apparel would also be excluded under this definition. Whilst by volume such goods are likely to represent a small fraction of the clothing and apparel market (less than 1% of the collected volume of materials included in textile collection systems) they have proven to have been captured in the systems employed by Member States for textile goods and their inclusion under this option would allow Member States to continue to collect some materials for the purpose of compliance with the requirements of the WFD that apply to textile goods overall.

The effectiveness and efficiency of this sub-option would be limited by the broad nature of textiles that would be addressed i.e., resources to address textile wastes would be spread over a much larger set of textiles than are currently addressed by Member State infrastructure that focusses on clothing and household wastes that make up most textiles discarded. Furthermore, in relation to efficiency this measure would potentially increase costs of textile waste management significantly in relation to the baseline, with the expected economic value of the textiles reused or recovered likely to be less than that for a more targeted definition of textiles and accompanying measures.

With regard to pre-consumer waste, including post-industrial, pre-consumer and post-consumer commercial textile waste, the existing waste regime presently requires that the waste producer treats the waste in line with the waste hierarchy. As noted earlier, it is assumed that where there is a market value for the textile waste and transport to the recycling infrastructure is economically feasible it is valorised in view of its clear and consistent composition that requires far less pre-processing for recycling. It is expected, therefore, that there would be no or only insignificant additional costs resulting from this alternative in comparison to the baseline.

Environmental impacts

The definition in line with the Textile Labelling Regulation would include raw, semi-worked, worked, semi-manufactured, manufactured, semi-made-up or made-up products encompassing a broad range of textile goods including, for example, yarns, floor coverings and carpets and would make clear that action to mitigate the environmental impacts of this broad family of textiles should be taken addressing both pre-consumer and post-consumer textiles.

The additional 4 million tonnes of textiles collected are likely to be subject to a significant change in their waste management given their currently low levels of separate collection. This would likely lead to a greater volume of textile goods that could be reused or subject to recycling, reducing the impacts of those wastes in comparison to their disposal which is the dominant destination for these other waste types at present.

There is a degree of differentiation to be made in relation to the additionally textiles types that would be collected and the likely environmental impact from their separate collection:

Pre-consumer textile wastes are raw, semi-worked, worked, semi-manufactured or semi-made up are likely to have a more significant environmental impact due to the possibility to recycle these materials more easily than for completed and post-consumer textile wastes. This is due to:

·Fewer disruptors (for example zips and buttons) in the materials collected making them easier to recycle than textile products that contain them.

·A better understanding of the textiles’ composition compared to post-consumer textiles that have a much greater variety of materials.

The recycling of fibres contained in pre-consumer textiles are estimated to be worth approximately 230 euro per tonne, with each tonne of recycled fibre saving one tonne of GHG emissions compared to its disposal. The percentage of waste volume that would fall into this pre-consumer grouping is likely to be 5-10% of textile waste generated. This would mean that approximately 200-400 000 tonnes of additional recyclable textiles would be collected. There are additional water savings through closed loop recycling because it avoids production of virgin fibre. These would equate to approximately 258M to 516M m3 of water per year 2 .

However, in relation to post-consumer textile wastes the situations is likely to be more challenging. By way of example, mattresses currently have a reuse and recycling rate of 20% across the EU and carpets have a rate of 1-3%. Developing the necessary infrastructure to collected, sort, reuse and recycle these types of textile wastes requires a different approach than for clothing and household textiles. Member States would require time to develop this infrastructure and it is unlikely that this would be feasible within the deadlines set under the existing WFD for separate collection. Therefore, the efficiency and effectiveness of this option is questionable.

Social impacts

The greatest social impacts would be linked to the need for higher levels of employment in the waste management sector. These result from Member States having to manage a broader set of products under the definition of textiles than is currently the case. In addition, there would be a reduction in the social costs of textile goods that are presently disposed and that are expected to be reused or recycled more under this measure. A clearer understanding of what textiles means in relation to the WFD is also likely to lead to more realistic and consistent data being collected whilst supporting a more level playing field between Member States. This would benefit all stakeholders including public administrations, businesses and citizens. However, the ability to split reporting to address particular textile product types is far more challenging as the Textile Labelling Regulation itself provides no such list of textile products, only a list of textile fibre names and textile products for which special provisions apply (such as specific labelling requirements or derogations). Providing reports based on textile fibre quantities by Member States is likely to be technically impossible given the mix of fibre types found in many textile products at present.

Administrative burden

Member States’ understanding of what constitutes textiles affect the practical implementation of measures to manage textiles and textile waste and affects the related data reported by Member States. A clarification of reporting obligations by Member States by more clearly defining the textile materials that should be captured by such reporting should reduce the administrative burden on Member States in determining their own textile reporting regimes against their own definition of what textiles comprise as is the case at present. More standardised reporting resulting from this measure should, therefore, help to reduce burdens whilst producing more reliable data.

In view of maximising administrative efficiencies and synergies with existing regulatory responsibilities in the waste prevention policy, the management of the data flow on re-use of products, including on textiles is better pursued by the EEA instead of the Commission which should, according to the Article 37 of the WFD be receiving the data from Member States. It is therefore proposed to amend Article 37 of the WFD envisaging that this data flow is to be reported to and managed by the EEA. This would require allocation of additional resources to the EEA for the fulfilment of this task.

Impact on SMEs and social enterprises

Most producers in the textiles’ ecosystem are micro-enterprises (88.8% of 127 000 enterprises), with only 0.2% of enterprises being large companies. Clarifying the definition of textiles according to the Textile Labelling Regulation is likely to have no significant additional administrative burden on SMEs as they already comply with the Textile Labelling Regulation (unless they are subject to the specific exclusions provided for in that Regulation). 3 On the contrary SMEs are likely to benefit from an alignment of the scope which makes the applicable rules easier to understand.

Defining textiles according to the Textile Labelling Regulation would significantly expand the types of textiles to be collected under Article 11(1), potentially adding significant burden to social enterprises as well as any commercial SMEs that operate collection systems. Those systems would have to expand to include textiles that are currently not targeted. Such a broadening would have significant negative impacts on SME collectors and social enterprises which are currently focusing on the collection of reusable textiles due to their value. This impact may be offset if the differing nature of these other textile products in terms of their methods of collection storage and recycling was considered in identifying the relevant actors for their management. By way of example, discarded mattresses are unlikely to be resold in social enterprises and are more likely to be sent for recycling where their most valuable components (metals and foams) are removed by actual waste management companies means that Member States could not simply rely on the existing clothing and household textile collectors to manage mattresses – instead a more active engagement of waste management companies would be required to be implemented.

Stakeholder evidence

Stakeholders indicated that this is a useful measure if it includes a clear scope on what products are included – and excluded – in the term ‘textiles’ for the purpose of the WFD and “would help to establish what is to be included in separate collections” 4 . Stakeholders do not think it is necessary to regulate how collections are carried out but indicate that a common scope is essential.

Stakeholders consider that items thrown away should be deemed as waste. In a few EU countries, there are bins for both reusable and non-reusable textiles, but these are often mixed-up by consumers. The sorting needs to be carried out by professional sorters, therefore better labelling and/or definitions might not resolve this. The same respondent considered that over-the-counter donations should also be considered waste because the fact that a product is donated for an economic purpose (potentially ruling it out of being considered waste) is important, but not a determining factor as there is an economic factor behind many choices, including recycling and to align it with economic element would mean nothing would ever be classed as waste.

All alternatives are considered to be suitable alongside an EPR scheme.

Assessment of impact alternative 2

Economic impacts

Setting a definition in keeping with the CN Regulation would provide a definitive list of textiles for the purpose of the WFD. The CN codes themselves provide a list by which producers of post-industrial pre-consumer and post-consumer commercial textiles waste would be addressed by the codes addressing raw, semi-worked, worked, semi-manufactured, manufactured, semi-made-up or made-up products (generally chapters 50, 51, 52, 53, 54, 55, part of 56, 57 (with the exception of turf), 58 and 60) whilst post-consumer household waste should be easily identifiable using the codes under chapters 60, 61, 62, parts of 63 and parts of 65. Descriptions like ‘overcoats’, ‘shirts and blouses’ and the like being generally understandable to consumers discarding textiles as well for those who are likely to be involved in the subsequent treatment of textiles under the WFD. This improved delineation of textile products covered by the WFD - and subsequent national provisions - would enable a level playing field as it would provide a common understanding of the scope of textiles and textile waste in comparison to the present. It would also allow more targeted action to be put in place in comparison to alternative 1 that would address a broader and less clearly delineated set of textiles. Economically, this would ensure that action is focussed on those textiles that warrant action under the WFD and ensure a level playing field across the EU in terms of what is required of Member States.

Similarly to Alternative 1, since the existing waste regime already requires waste producers to treat their waste in line with the waste hierarchy, it is expected that there would be no or only insignificant additional costs resulting from this alternative in comparison to the baseline.

The impacts in terms of volumes of textile wastes separately collected, sorted and treated would be dependent on the final scope of CN codes included under this measure. If the scope remained similar to the scope currently employed by Member States (i.e. with a focus on post-consumer clothing and household textiles) flows would be unlikely to vary in comparison to the baseline. However, should additional textile types be included then the collection, sorting and treatment of those textiles would be expected to increase in keeping with obligations that currently apply to textiles including the separate collection obligation under Article 11. Whilst an increase would be expected, it has not been possible to quantify the potential increase in tonnes as not all Member States have provided details as to the scope of textiles that they currently consider in their own textile management schemes to allow such quantification to take place.

Footwear and leather clothing and apparel would be included under this definition. Given that these types of goods have proven to have been captured in the systems employed by Member States for textile goods their inclusion under this option would allow Member States to continue to collect some materials for the purpose of compliance with the requirements of the WFD that apply to textile goods overall. This would avoid a situation whereby Member States may otherwise feel the need to employ separate systems for such clothing and apparel that is unlikely to be economically viable given the relatively small quantities concerned.

Similarly, any addition in scope would entail additional collection, sorting and treatment. As for Alternative 1, in countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then costs may be met via the likes of disposal fees applied at the point of disposal or general taxation. Similarly for Alternative 1, the additional costs are likely to fall around 0.6% of total product cost with the application of those costs being absorbed by the producer, being passed on to the consumer or a mix of both.

Environmental impacts

The definition would include raw, semi-worked, worked, semi-manufactured, manufactured, semi-made-up or made-up products encompassing a broad range of textile goods including, for example, yarns, floor coverings and carpets and would make clear that action to mitigate the environmental impacts of this broad family of textiles should be taken addressing both pre-consumer and post-consumer textiles. This would mean that the separate collection provisions of Article 11(1) for which the majority of Member States have targeted clothing and household textiles could be defined as significantly broader, obliging Member States to provide for separate collection of other textiles types with the expected environmental benefit from greater levels of separate collection being higher levels of reuse and / or recycling of those materials than at present.

In comparison to alternative 1, alternative 2 offers the opportunity to include additional specific products such as entire mattresses, umbrellas and textile covered furniture by referring to the relevant applicable CN code allowing the environmental impacts of these specific product types to be addressed under the already existing obligation for separate collection under Article 11(1).

As outlined in the description of alternative 3, the WFD applies to a broad range of wastes with only certain exclusions as outlined in Article 2. Defining textiles based on a limited number of CN codes poses the risk of unnecessarily restricting the scope of measures for textiles under the WFD, thereby preventing action being taken on other problematic textile and textile like wastes. A long list has been drawn up as included in Table 39 but there may be additional materials containing textiles – for example Chapter 94 that includes furniture – that may warrant action that would be excluded in alternative 2. A possible solution to address this would be to make the list under this option progressive i.e., the list could subsequently be complemented as other textile containing products are identified that warrant action to address the waste management challenges associated with them.

Social impacts

A clearer understanding of what textiles means in relation to the WFD is also likely to lead to better and more realistic data being collected whilst supporting a more level playing field between Member States. This would benefit all stakeholders including public administrations, businesses and citizens. The ability to identify textiles by specific codes, in theory at least, allows greater precision of textiles and textiles waste reporting according to the CN code. However, whilst this granularity would provide more helpful information, requiring reporting for all the CN codes suggested for inclusion as the definition of ‘textiles’ is likely to prove overly burdensome in comparison to the usefulness of the data collected.

Administrative burden

As is the case for alternative 1, a clarification of what Member States should be reporting as ‘textiles’ should reduce the administrative burden on Member States in determining their own textile reporting regimes. More standardised reporting should help to reduce burdens whilst producing more reliable and comparable data. Given the greater clarity of scope of alternative 2, it is likely that the administrative burden reduced by alternative 2 would be greater than that of alternative 1. It is estimated that the administrative burden reduction stemming from a clarification of reporting obligations would result in savings of approximately 250 000 euro per year.

Impact on SMEs and social enterprises

As in alternative 1, given over 99% of producers of textiles are SMEs, clarifying the definition of textiles is unlikely to have any significant impact on SMEs as they already comply with the textile labelling Regulation unless subject to the specific exclusions provided for in that Regulation 5 . 

As under alternative 1 and depending on which CN codes are included, defining textiles according to CN codes could significantly expand the types of textiles to be collected under Article 11(1). This could potentially add significant burden to social enterprises as well as any commercial SMEs that operate collection systems to cover the textiles not currently targeted by their collection schemes. Such a broadening would have negative impacts on SME collectors and social enterprises accordingly in view of the increasing share of non-reusable fractions. However, using a list that is in keeping with current interpretations applied in most Member States would limit this potential impact. This is without prejudice to measure 2.9.

Stakeholder evidence

Stakeholders mentioned that aligning terminology and regulations will provide a common understanding and be the basis for better monitoring of a wider set of fibres and products. This should be combined with the JRC work on EoW criteria for textiles to ensure there is a clear definition of what are textiles and when they cease to be waste 6 . Stakeholders indicated that establishing clarifying definitions on waste and ownership of waste, and to what extent waste should be exported if it cannot be recycled is critical. 7 .

Assessment of impact alternative 3

Economic impacts

Alternative 3, in comparison to alternatives 1 and 2, would take a broad definition of textiles for the general purpose of the WFD, whilst allowing the targeting of specific measures to specific textile types. By way of example, defining textiles more broadly in relation to reporting requirements would allow the Commission to define data collection across several different textile product types in order to better understand the volumes of textile types placed on the market, the methods of their management when they become a waste and the challenges that may require action to be taken in the future. At the same time, narrowing specific measures to specific textile types using CN codes allows measures to be targeted more effectively than referring to textiles in general. A good example of where this may be best applied is in relation to Article 11(1) whereby a focus on the largest share of textile wastes – clothing and household textiles – would avoid Member States focussing efforts on other wastes that were not originally intended to be addressed by such measures or for which another different targeted approach should be applied. Such lists of textile types subject to specific measures based on CN codes need not necessarily be addressed in the definition Article of the WFD itself (Article 3) but could be included in an Annex of textile products to which specific measures are addressed.

Additionally, a broad reading of textiles would be at odds with the definitions currently applied by Member States, requiring them to expand the systems in place to address textiles in their implementation of the WFD. This alternative would avoid the necessity of those changes. This is particularly important for more specialist textile types such as tents, awning, umbrellas and other materials designed for particular use conditions. Such materials may be challenging in relation to recycling due to their composite material and the likely use of chemicals for the purpose of waterproofing in their everyday use. The reuse potential of these additional materials may also be hindered by the issue of scale of materials concerned i.e., they represent roughly 3% by weight of what would constitute textiles but are more specialist in their application.

As is the case with alternatives 1 and 2, the existing waste regime already requires waste producers to treat their waste in line with the waste hierarchy. Therefore, it is expected that there would be no or only insignificant additional costs resulting from this alternative in comparison to the baseline.

Furthermore, in keeping with alternative 2 the impacts in terms of volumes of textile wastes separately collected, sorted and treated would be dependent on the final scope of CN codes included under this measure. If the scope focussed on post-consumer clothing and household textiles flows would be unlikely to vary in comparison to the baseline.

Footwear and leather clothing and apparel would be included into the separately collection schemes under this alternative. Given that these types of goods have proven to have been captured in the systems employed by Member States for textile goods their inclusion would allow Member States to continue to collect some materials for the purpose of compliance with the requirements of the WFD that apply to textile goods overall. This would avoid a situation whereby Member States may otherwise feel the need to employ separate systems for such clothing and apparel that is unlikely to be economically viable given the relatively small quantities concerned.

However, should additional textile types be included that are not currently addressed by Member States under their obligations under the WFD then the collection, sorting and treatment of those textiles would be expected to increase in keeping with obligations that currently apply to textiles including the separate collection obligation under Article 11. Whilst an increase would be expected, it has not been possible to quantify the potential increase in tonnes given the data at the Member State level that dictates their current scope of textile waste management is not accessible across the EU but only for a proportion of Member States as presented in Annex 6.

Similarly, any addition in scope would entail additional collection, sorting and treatment. As for alternatives 2 and 3, in countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then costs may be met via the likes of disposal fees applied at the point of disposal or general taxation. Similarly for alternative 1 and 2, the additional costs are likely to fall around 0.6% of total product cost with the application of those costs being absorbed by the producer, being passed on to the consumer or a mix of both.

Environmental impacts

As is the case for alternatives 1 and 2, the definition used under this alternative would include raw, semi-worked, worked, semi-manufactured, manufactured, semi-made-up or made-up products encompassing a broad range of textile goods including, for example, yarns, floor coverings and carpets and would make clear that action to mitigate the environmental impacts of this broad family of textiles should be taken addressing both pre-consumer and post-consumer textiles.

In comparison to alternative 1 the opportunity exists to include additional specific materials such as. entire mattresses, umbrellas and textile covered furniture by referring to the relevant applicable CN code allowing the environmental impacts of these specific product types to be addressed.

As outlined in the introduction to alternative 3, the WFD applies to a broad range of wastes with only certain exclusions as outlined in Article 2. Defining textiles based on a limited number of CN codes poses the risk of unnecessarily restricting the scope of measures for textiles under the WFD, thereby preventing action being taken on other problematic textile and textile like wastes. A long list has been drawn up as included in the table above but there may be additional materials containing textiles – for example Chapter 94 that includes furniture – that may warrant action that would be excluded using the list provided. A possible approach to address this would be to make the list under this option progressive i.e., the list could be subsequently expanded to cover other textile containing products as deemed necessary based on their waste management challenges, for example furniture.

This alternative, under the broad heading of textiles as per the Textile Labelling Regulation, would continue to exclude certain products that require attention, for example mattresses that generate approximately 240 000 tonnes of textile waste per year and carpets that generate approximately 1.6 million tonnes of waste (the share of textiles is unknown). However, given the challenges in addressing the traditional use of a latex, water-based backing which cannot be removed from the pile fibres and creates a difficult-to-recycle material mix as well as the collection challenges related to textile waste this exclusion appears relevant given the lack of practicable options to address carpet waste as a textile at present. In the case of both mattresses and carpet an alternative categorisation exists under the WFD e.g., bulky waste, but for those Member States currently considering measures on mattresses under the textile heading these would generally be excluded as textiles using this definition. According to information provided by Member States, Hungary is the only Member State that currently considers carpets under their textile waste measures.

Social impacts

As is the case under alternatives 1 and 2, a clearer understanding of what textiles means in relation to the WFD is also likely to lead to better and more realistic data being collected whilst supporting a more level playing field between Member States. This would benefit all stakeholders including public administrations, businesses and citizens.

The alignment with the Textile Labelling Regulation in the definition of textile products would allow to harmonise this term across legislation applying textiles.

On the other hand, under this alternative it would be possible to define by CN-code specific measures addressing a subset of textile products and including non-textile wastes which currently are also captured in the same systems employed by Member States for textile goods.

Administrative burden

As is the case for alternatives 1 and 2, a clarification of reporting obligations should reduce the administrative burden on Member States in determining their reporting regimes against their current definition of what ‘textiles’ comprises. More standardised reporting resulting from this measure should, therefore, help to reduce burdens whilst producing more reliable data. Given the more specifically defined scope of reporting by specific textiles types, the administrative burden reduced by alternative 3 would likely be greater than alternative 1.  It is estimated that the administrative burden reduction stemming from a clarification of reporting obligations would result in savings of approximately 250 000 euro per year. 

Impact on SMEs and social enterprises

As noted under alternatives 1 and 2, in relation to producers of textiles, most companies involved in the textiles and clothing industry are micro-enterprises with only 0.2% of enterprises being large. Clarifying the definition of textiles according to the Textile Labelling Regulation is likely to have no significant additional admin burden on SMEs as they already comply with the Textile Labelling Regulation (unless they are subject to the specific exclusions provided for in that Regulation). 8 On the contrary SMEs are likely to benefit from an alignment of the scope which makes the applicable rules easier to understand.

Alternative 3 offers the greatest flexibility to both make sure that textiles in their entirety are addressed by using the definition of textiles from the textile labelling Regulation whilst targeting specific measures within the WFD at specific textile types by referring to specific CN codes. Depending on the limit of the textiles determined to be addressed under this option, defining textiles according to CN codes could significantly expand the types of textiles that to be collected under Article 11(1), potentially adding significant burden to social enterprises as well as any SME commercial operators that operate collection systems to expand those systems to address textiles that are currently not targeted by their collection schemes. Such a broadening would have significant negative impacts on SME collectors and social enterprises accordingly. However, using a list that is in keeping with current interpretations applied in most Member States would limit this potential impact for the likes of Article 11(1) by focussing on clothing and household textiles whilst ensuring greater consistency of application of these measures for SMEs and social enterprises across the EU.

Stakeholder evidence

Stakeholders felt that a clear definition of reusable/recyclable is needed for textiles as currently, no specific criteria exist for an objective classification of discarded textiles into reusable or recyclable. This lack of definitions directly hampers a homogeneous classification of garments and the application of the waste hierarchy. 9

For all alternatives there was consensus that any definitions should be EU-wide. This would ensure consistency which will drive ease of sharing, exports, and economies of scale. In addition to this, these definitions should be equally enshrined within all the different EU legislations to ensure shared indicators/reporting and objectives. This should include definitions of legally responsible economic operators as well as business related activities such as repair, remanufacture (remake) and second-hand must also be clearly stated and harmonized within all EU legislations 10 and possible beyond (i.e., Norway). 11

Comparison of alternatives 1, 2 and 3 in terms of scope

Given that one of the most notable differences between alternatives 1 and 2 is in relation to the scope of textile products that would be addressed, the table below summarises the differences in scope that would be seen. Alternative 3 captures all elements in green for alternatives 2 and 3. However, under alternative 3 it would be possible to specify particular textile categories for different measures i.e., the overall definition of textiles would be broad as in alternative 1 but specific measures could be targeted at specific CN codes using an approach defined under alternative 3. By way of example, an Annex could be added to the WFD containing a list of textiles by CN code for which measures such as separate collection, EPR, reporting should be applied. This would be more precise than under alternative 1 but would prevent the exclusion of textile materials from the broader measures that might otherwise be the case under alternative 2. However, the data and information currently collected through official statistics applies the CN code approach, and thus would ensure consistency and complementarity, in particular in view of the proposed EPR scheme (Measure 2.9).

Table 1: Scope of the three alternatives

Table 2: Summary of impacts for measure 1.1 – Alternatives 1-3 definition of ‘textiles’

Sub-measure 1.2 – Definition of ‘textile waste’

Assessment of impact alternative 1

Economic impacts

Setting a definition that requires all separately collected textiles to be considered waste would enable a consistent approach across all Member States in comparison to the status quo.

However, the application of waste status to all separately collected textiles carries with it the possibility to place burdens on actors, particularly social enterprises that are required in some cases to have the necessary authorisations to collect and sort waste in one Member State when a neighbouring Member State does not require such authorisations as textiles only become waste later in the processing of the materials collected. Data from the social enterprise sector 12 indicates that the majority of those involved in the separate collection of wastes, including social enterprises, are already in ownership of the necessary waste management permissions and so whilst some impacts are likely for a minority of actors the negative impacts of this measure are likely to be limited.

Additionally, applying waste status at the point of collection risks a deterioration in the quality of textile materials collected in separate collection systems – if those depositing textile materials are told that all textile materials are welcome because they will be subsequently sorted into reusable and recyclable, then lower quality materials may be collected, increasing the costs of collection and sorting for sorters, including social enterprises whilst lowering the quality of feedstock for preparation for reuse and recycling. This effect can be and is already addressed by instructions that are typically found on separate collection bins and other separate collection systems. It would be important in the application of this sub-option, therefore, to ensure that such instructions are maintained to minimise this risk from materialising in practice.

In relation to data needs, determining waste status at the point of collection sets a clear demarcation line for reporting purposes. This would assist in the present reporting requirements under Commission Implementing Decision C(2020) 8976 for reporting on reuse as the total fraction of reused textiles could be set against the total amount of textile waste separately collected through all collection systems using the same starting point as to when those materials became waste. It would also allow any new reporting requirements to have the same starting point in the future.

Environmental impacts

This alternative would put in place the protections under the WFD in relation to the correct handling of those materials following their collection and the application of the waste hierarchy to the materials contained therein. It would also address the high risk of waste that forms a part of the materials separately collected being falsely considered as non-waste and its potential export to third countries. Whilst measure 2.8 that would set requirements for the shipment of textiles for reuse, would offer some protection in this respect, in the absence of that measure the risk would remain high.

This definition also acknowledges that those depositing textiles are not always able to determine whether a textile is suitable for reuse/recycling or not, which leads to reusable textiles being discarded as waste and non-reusable or recyclable textiles being deposited in separate collection systems. Determining that all such materials are waste until they are professionally sorted into their respective reuse, recycling and disposal fractions addresses this problem directly by requiring waste management approaches to be applied from the outset. Measure 2.5 specifically addresses sorting obligations with the link in mind.

MWE, representing public waste management organisations 13 highlighted that the ‘use and dispose’ culture mindset is largely fostered across the entire textile supply chain. It is, in turn, adopted by consumers, driving increasing volumes of textile waste generation. This is matched by a lack of consumer understanding of the true costs of textile production beyond the purchasing price as identified during the first stakeholder workshop by an NGO. A stakeholder representing the social enterprise, reuse and repair sector 14 , noted that the consumer to consumer (C2C) textile market is flourishing but this does not prevent the sale of new textiles. Indeed, when people know that they can sell their products on C2C platforms they may tend to buy even more products in what is known as the rebound effect. Stakeholders also identified the lack of sufficiently robust data on used textiles and textile waste as a barrier to developing sufficient waste prevention programmes. 

Social impacts

Applying waste status at the point of collection should ensure that the materials contained therein are managed as waste. In the context of existing issues with the export of used clothing and textiles to third countries under the guise of used (but not waste) textiles that are subsequently disposed of in third countries, this would be less likely to occur in the context of all materials having to be handled as waste until sorting had taken place to differentiate between waste and non-waste (reusable) fractions.

Impact on SMEs and social enterprises

As noted under economic impacts the application of waste status to all separately collected textiles carries with it the possibility to place burdens on actors, particularly social enterprises that are required in some cases to have the necessary authorisations to collect and sort waste in one Member State when a neighbouring Member State does not require such authorisations as textiles only become waste later in the processing of the materials collected. Data from the social enterprise sector 15 indicates that the majority of those involved in the separate collection of wastes, including social enterprises, are already in ownership of the necessary waste management permissions and so whilst some impacts are likely for a minority of actors the negative impacts of this measure are likely to be limited.

SMEs other than social enterprises are unlikely to be significantly impacted by this measure as they are already likely to hold the necessary authorisations to collect and sort waste.

Assessment of impact alternative 2

Economic impacts

Setting a definition that requires all separately collected textiles to be considered as waste only after sorting would lead to greater consistency of approach across all Member States. Materials that are in fact waste would be defined accordingly following sorting and so the scope of materials subject to the requirements of the WFD would be reduced in comparison to alternative 1 and the costs would also, therefore, be less. Using this approach, reusable products would remain products rather than being classified as waste upon collection.

In relation to data needs, determining waste status at the point of sorting would not assist in reporting by Member States. The current focus of Commission Implementing Decision C(2020) 8976 for reporting on reuse would likely be more difficult as these materials would never reach waste status under this sub-option and Member States may simply determine that such quantities should not be reported in the future under the WFD. This would be counterproductive to understanding how the waste hierarchy is being applied in practice for textiles.

Environmental impacts

Changing the point at which separately collected textiles become a waste is somewhat at odds with the definition of waste under the WFD that refers to the intention of the holder to discard a material as determining its waste status.

Additionally, as noted earlier, those depositing textiles are not always able to determine whether a textile is suitable for reuse/recycling or not, which leads to reusable textiles being discarded as waste and non-reusable or recyclable textiles being deposited in separate collection systems. By removing controls that are in place in some Member States where such materials are currently considered as waste as well as the confirmation for all others that such separately collected textiles are not waste is more likely to elevate the risk of waste materials being inappropriately categorised and exported to third countries as a non-waste.

Social impacts

Categorising materials as non-waste at the point of discard would remove waste controls on the materials contained therein. In the context of the potential of waste materials to be mixed in with reusable items and ongoing challenges with the export of unsorted EU textiles to third countries this situation would continue to exist under this option to the disadvantage of the citizens of the receiving countries.

Administrative burden

Removing waste status at the point of collection would remove administrative burden in relation to the need for collectors to obtain the relevant waste management authorisations to collect and sort waste where these are currently applied. There is no standard set fee for the relevant authorisations at the EU level. However, by way of example in DK the annual fee is approximately 200 euro per year 16 and in DE it varies by Lander and by type of waste activity. In Hamburg, for example, the fee varies between 95 and 1 000 euro per year 17 . These fees are likely to be amongst the highest in the EU, with the average likely to sit below 200 euro per year. As a result of a lack of data on the numbers of enterprises concerned it is not possible to quantify the total impact across the EU of removing these licensing costs.

Impact on SMEs and social enterprises

As noted under alternative 1, data from the social enterprise sector 18 indicates that the majority of those involved in the separate collection of wastes, including social enterprises, are already in ownership of the necessary waste management permissions so these would no longer be necessary. The same will be the case for SMEs.

Stakeholder evidence

Stakeholder evidence tended not to differentiate between the definition of textiles in general and the definition of textile waste. The stakeholder evidence should be read with this in mind.

Stakeholder feedback generally considered that clarification of definitions was a useful measure, if it includes a clear scope on what products are included – and excluded – in the term “textiles and would help to establish what is to be included in separate collections” 19 . There is not necessarily a need to regulate how collections are carried out, however, a common scope was seen as essential.

If items are thrown away, it was deemed that this should be considered as waste. In some EU states, there is the option of reusable and non-reusable bins for textiles, which often are mixed-up by consumers, so this definition and sorting needs to be carried out by a professional sorter, therefore better labelling and/or definitions might not resolve this. The same respondent considered that over-the-counter donations should also be considered waste because the fact that a product is donated for an economic purpose (potentially ruling it out of being considered waste) is important, but not a determining factor as there is an economic factor behind many choices, including recycling and to align it with economic element would mean nothing would ever be classed as waste 20 .

It was stated that it would be useful to align terminology and regulations and provide a common understanding and basis for monitoring which will extend to a much wider set of fibres and products. This should be combined with the JRC work on EoW criteria for textiles to ensure there is a clear definition of what textiles are and when they are waste 21 . It was viewed as critical to establish clarifying definitions on waste and ownership of waste, and to what extend we should export away waste if it can't be recycled - and only focus on exporting to countries that can recycle (keeping in mind the potential decrease for demand in 3rd countries that are developing and the increase in demand for second-hand in Europe) 22 .

A stakeholder considered that new terms such as “renewable textiles” may need to be added and these should all be aligned across the states to provide a level playing field. These definitions should extend across new types of materials (i.e., renewable materials) as well as across blends and fibres. The decision as to what this is aligned with should be developed through in-depth consultation with stakeholders 23 .

It was felt that a clear definition of reusable/recyclable is needed for textiles as currently, no specific criteria exist for an objective classification of discarded textiles into reusable or recyclable. This lack of definitions directly hampers a homogeneous classification of garments and the application of the waste hierarchy. However, once waste is classified as reusable or recyclable, rules for shipment and exports are different regarding controls, notifications and assurance 24 .

For all alternatives, there was consensus that any definitions should be cross-state and should drive consistency which will drive ease of sharing, exports, and economies of scale. In addition to this, these definitions should be equally enshrined within all the different EU legislations to ensure shared indicators/reporting and objectives. This should include definitions of legally responsible economic operators as well as business related activities such as repair, remanufacture (remake) and second-hand must also be clearly stated and harmonized within all EU legislations 25 and possible beyond (i.e., Norway) 26 .

Bringing the textile labelling and CN classifications together would need to also include definitions for fibre-to-fibre recycling, reusable, recyclable textile waste as well as new terms like ex. renewable textile (post-consumer cellulose-based fibres that can be chemically converted into new fibre types etc). Developing these definitions would need to be done as part of an extensive stakeholder engagement process.

Table 3 : Summary of impacts for measure 1.1 – Alternatives 1-2 definition ‘waste’

Competitiveness impacts of measure 1.1

The following competitiveness impacts have been assessed for this measure overall.

Table 4 - competitiveness impacts of measure 1.1

Measure 1.2 – Adopting EU wide waste prevention indicators for textiles

Assessment of impact Measure 1.2

Economic impacts

The EEA is developing a monitoring framework to track waste prevention progress at the EU level. It will be utilised using data that Member States are already collecting and reporting to the Commission under waste and other policies. It will also facilitate the monitoring of waste prevention in the textile sector as part of the efforts of measuring municipal waste reduction. However, it does not cover specific indicators on textile waste specifically. The EEA is currently setting up a reporting system (online tool) for reporting of reused textiles (in line with Implementing Decision 2021/19). Data on reuse will be available from 1 July 2023. It is not expected that developing and using mandatory prevention indicators will require additional reporting from Member States or from the economic operators because specific reporting on textiles is already envisaged under the Implementing Decision 2021/19 which, together with the EEA monitoring framework indicators, would be used as a basis for the development of indicators.

A monitoring framework may be used to identify countries that perform well and good practices/policy measures implemented at national level. Their dissemination would then indirectly contribute to the success of waste prevention measures in the EU27 overall with a consequent reduction of textile waste to be managed by the waste management sector. These impacts cannot be monetised as the impacts in volume terms are unknown.

No impacts on prices of goods are foreseen under this measure as the measure itself looks to share data between Member States on waste prevention using indicators. No additional costs of reporting are foreseen and so no additional costs are required to be priced into the cost of goods.

Environmental impacts

Setting indicators in relation to textile waste prevention approaches adopted by Member States as well as overarching data in relation to the volumes of textile wastes generated, collected, sorted and reused will provide an overview of the progress made by Member States over time in relation to waste prevention using comparable data for the first time. Additionally, such information may be used to identify good performers and to perform further analysis to identify the positive practices implemented by the Member States. This would allow a more objective assessment of Member States’ practices as demonstrated by the examples of existing prevention measures in different Member States collected by the European Environment Agency 27 . A list of such examples is provided below, albeit drawing conclusions as to the most successful of these measures is challenging in the absence of an indicator of success, as would be defined under this measure.

Table 5 : Examples of textile waste prevention measures listed in national waste prevention programmes

Source: EEA, 2021.

Developing indicators that allow waste intensity to be determined i.e., illustrating the decoupling of textile waste generation both in relation to textiles sold but also in relation to economic growth using statistics already available from Eurostat would act as a good marker to demonstrating progress in textile waste prevention. Using statistics on the environmental costs of textile production and disposal available from the likes of Payet 28 and applying data from Eurostat, calculation of the impact of preventing textile waste production on the estimated CO2e emissions from placing textiles on the EU27 market, which was estimated in 2020 as 198 million metric tonnes 29 and its reduction in impact in the future should be possible to be calculated.

Social impacts

Waste prevention is at the top of the waste hierarchy as the avoidance of generation of waste in the first place is the preferred option. Monitoring progress on textile waste generation and identifying best practices employed by Member States should subsequently allow to determine the extent to which the social impacts of textile waste can be addressed by reducing those wastes in the first place.

As noted under economic impacts, a reduction in waste through more effective monitoring of waste prevention measures would result in less waste being generated and consequently an impact on employment in the waste management sector would be likely, albeit small in comparison to the waste management sector overall.

Impact on SMEs and social enterprises

No significant impacts on SMEs were identified for this measure. SMEs, including social enterprises, are the majority of those involved in the placing on the market of textiles (including used, repaired textiles) as well as in separate collection, sorting of wastes. The purpose of the waste prevention monitoring is to identify practices and actions that have a waste reduction impact and facilitate their use further. Therefore, in the context of applying waste prevention measures as required under Article 9 of the WFD, Member States should facilitate the creation of circular business models, support those with regulatory and economic measures. In view of the composition of the sector, this would benefit the SMEs and social enterprises.

Stakeholder evidence

Stakeholder insight described EU waste prevention indicators as essential in confirming commitment to goals and setting out a direction of travel for textiles waste management 30 . Concerns were raised however, over the potential for prevention targets to create challenges for reuse, by causing confusion between “old” and “new” products, and not doing enough to drive activity further up the waste hierarchy 31 . The optional measures could also be challenging to implement uniformly and could potentially have disproportionate impacts across areas. Concerns were also raised around the complexity of using preventative indicators which could lead to incentivisation of malpractice 32 .

Feedback suggested that the WFD should go beyond indicators to include quantitative targets for preparation for reuse and waste prevention, separate to recycling. This should further encourage reuse by providing economic incentivisation for reuse operators who meet waste prevention targets, particularly social enterprises 33 . Whilst the waste prevention indicators in themselves would not be enough to drive action at company level, the impact from administration should act as a catalyst to drive action. The administration required for reporting should then be aligned with the ESPR and embedded into a Digital Product Passport 34 .

Insight gathered through interviews and workshops highlighted that the waste prevention angle is not the fundamental point to focus on, as what is needed is strong infrastructure which can sort and collect textiles to retain their value. It was felt that the focus should be on investing in technology which can expand the capacity to upscale and increase the volumes of products able to be accepted beyond simply high value used products 35 . Prevention of waste should be driven through a wider set of enablers, including better materials and production processes, and fostering of reusability and repair to involve consumers 36 .

Where the indicators are established, stakeholder input suggested that full life-cycle data should be used to design the most environmentally friendly systems and indicators which fully reflect the most desirable outcomes. This should include impacts from transporting, processing and production for recycling and reuse 37 .

Administrative burden assessment

There would be no additional administrative burden from this measure beyond those identified in relation to the application of measure 2.14.

Table 6 : Summary of impacts for measure 1.2

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 7 - impacts on competitiveness of measure 1.2

Measure 1.3 – Providing Member States with guidance and support in dialogue on the management of textile waste between actors involved

Assessment of the impact Measure 1.3

Economic impacts

The sharing of best practice and knowledge through both guidance and a platform would be expected to have positive impacts for textile management stakeholders. Guidance documents can help competent authorities and other stakeholders to improve practices in relation to waste management. To produce such guidance documents, the Commission will need to identify best practice and disseminate the information to the key EU stakeholders in all EU languages.

The measure would raise awareness of circular textiles models with the most potential for growth. The Commission SWD accompanying the proposal for a Regulation establishing a framework for setting ecodesign requirements  38 shows that 9% of SMEs have already adopted Circular Business Models, and on average 20% of businesses are already familiar with Circular Business Models. With the support from the public sector, there are good reasons to believe that circular economy business models will continue to increase in relation to textiles via the sharing of practices. The SWD also notes that recent trends suggest that demand for Circular Business Models will continue to grow in future years, pushed by significant policy measures at EU and Member States level, as well as generational trends and a growing appetite for sustainable products. Generation Z and Millennials are notably boosting demand for refurbished products and easy reparability options.

The measure has the potential to significantly increase textile collection, sorting and subsequent treatment based on the sharing of practices that have been proven to work by frontrunners such as DE and SE who currently collect over 60% of waste clothing and household textiles in relation to collection schemes. This would be of greatest benefit to those Member States that are far behind such collection rates including BG, CY, CZ, EE, EL, ES, HR, HU, LV, PL, PT, RO, SI and SK. However, as the sharing of best practice does not require Member States to then implement such practice the precise impacts in terms of flows of textile waste, collection, sorting and treatment is difficult to quantify. An improvement in such processes would, however, be expected to be achieved.

Any additional collection, sorting and treatment performed as a result of the application of this measure would entail costs. In countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then costs may be met via the likes of disposal fees applied at the point of disposal or general taxation. However, these costs would be a fraction of waste generated and collected, and consequently the costs that would be applied would not be for the entire volumes of textiles collected, sorted and treated but rather the additional costs for the additional wastes collected. Given that the total costs for all wastes account for an approximate increase per product of around 0.6%, this measure would likely result in smaller overall costs per product. Should the additional collection equate to a 20% increase in the waste collected, for example, then the application of costs to all goods sold would result in an increase in costs per item of around 0.12% of total price.

Environmental and Social impacts

Positive environmental impacts would stem from the sharing of best practices that could improve textile waste management across the EU. Social impacts are also likely to be positive since moving textile waste management up the waste hierarchy will generate more jobs that require skilled staff, particularly in the reuse sector where a lack of technical knowledge on repair and understaffing have been identified 39 .

Administrative burden

The provision of guidelines can be managed internally by the Commission or externalised to an agency or a contractor. The costs to create the additional guidance would include the travel and event costs, i.e., the cost of holding any necessary guidance development meetings and developing the guidance. Additional to this, the cost of the staff necessary to draft the reports would need to be added. Considering the ToRs used by IMPEL in the development of their own Guidance on Effective Waste Shipment Inspection Planning, the total cost of all meeting events for detailed guidance would be approximately 135 000 euro per guidance with about 50 individuals from multiple organisations making input encompassing time and travel costs for the staff involved in the development of the guidance.

The costs associated to the set-up of a platform depends very much on the final scenario selected. If the platform takes the form of an online platform only, managed as part of a wider dissemination activity following the Ecodesign website model, it is likely that the administrative cost will be limited to the cost of Commission personnel for both the extra development of the platform and its population and updates. 

Impact on SMEs and social enterprises

Given SMEs, including social enterprises, are the majority of those involved in the placing on the market of textiles as well as in separate collection of wastes, the guidance and support platform would have the largest impacts on SMEs overall.

Stakeholder evidence

In the second textiles stakeholder workshop this measure was seen as a useful tool for providing organisational information which could help users design effective collection schemes and create shared learnings, which can help ‘level the playing field’. This was identified as a critical element – along with clearer definitions (see Measure 1.1) and EU wide end-of-waste criteria for textiles – in developing a clear framework across member states and it was suggested during the interview that some of the measures be grouped to increase cumulative impact. This could be particularly useful if implemented early, to drive cohesion before individual systems are established.

Without a mandate, this measure will not be enough to ensure consistency in EPR systems for textiles, with Member States likely to develop their own potentially diverging guidance, and organisations historically driven by profit rather than environmental impact dominating discussions 40 . In the absence of guidance and a platform to share information, there is a risk of substantial administrative burdens, particularly for obligated producers 41 . It is important that, to operate efficiently, PROs must collaborate and share policy recommendations with one another as well as with the European Commission to ensure co-ordinated approaches and investment 42 .

Where different systems operate, there is likely to be a lack of incentive for investment in R&D since fragmented policies would lead to inefficiencies 43 . Non-harmonisation is also likely to have cost, time and labour implications as different reporting and fee systems overlap across boundaries 44 . Clarifying definitions, developing guidance and the sharing of stakeholder experience and EU wide end-of-waste criteria for textiles, when combined, could drive simplification and harmonisation which would simplify shipping and exporting and potentially encourage investment 45 .

To avoid competition between the reuse and preparing for reuse sectors, several stakeholders requested that an impact assessment must be carried out in the development of EPR schemes to identify measures to avoid the two competing. This was raised within the interviews, during which stakeholders outlined that different EPR systems across the EU would struggle to drive economies of scale needed for recycled content 46 .

Table 8 : Summary of impacts for measure 1.3

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 9 - impacts on competitiveness of measure 1.3

Option 2: Setting additional regulatory requirements to improve performance

Measure 2.5 – Setting sorting obligations for separately collected textiles and textiles waste

Assessment of impact Measure 2.5

Economic impacts

Additional sorting would ensure that greater volumes of textiles are removed from the mixed waste stream and processed for reuse and recycling for either onward sale within the EU or export for sale to third countries in the case of reuse or as feedstock for textile recycling.

According to current baseline predictions approximately 1.879 million tonnes of additional textile sorting would be undertaken within the EU by 2035 encompassing both the envisaged growth in separate collection of 1.4 million tonnes as well as the approximately 475 000 tonnes of textiles sorting that is currently undertaken in third countries and that is expected would take place within the EU under this measure. This would have the potential to lead to an additional 702 000 tonnes of textiles separated for reuse with an estimated value of 534 million euro per year and 590 000 tonnes available for recycling with an estimated value of 117 million euro per year. At the same time, additional sorting and subsequent treatment carries with it additional costs. An additional sorting capacity along with subsequent treatment (preparation for reuse, closed loop and open loop recycling) would carry operational costs of approximately 913 million euro per year by 2035 with 20% of this cost attributable to collection and 80% to the subsequent collection and treatment. Additional minor operational costs would be necessary to implement the required criteria in the sorting process. Given the flexibility that would be provided to Member States in the application of these criteria it is not possible to provide a definitive cost. This means that in general approximately 70% of the costs of application of the measure would be likely retrieved via the economic value of the textiles sorted.

The additional sorting and treatment performed as a result of the application of this measure would entail costs. In countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then costs may be met via the likes of disposal fees applied at the point of disposal or general taxation. However, these costs would be a fraction of waste generated and collected, and consequently the costs that would be applied would not be for the entire volumes of textiles collected, sorted and treated but rather the additional costs for the additional wastes collected. Given that the total costs for all wastes account for an approximate increase per product of around 0.6%, this measure would likely result in smaller overall costs per product as the additional amount of sorting and treatment infrastructure in comparison to the baseline would be approximately half of the total necessary infrastructure that would already be in place. Consequently, and recognising that the full costs of the necessary increases infrastructure could be applied across all produced textile goods (and not just the fraction that would be additionally sorted and treated) an increase in costs per item of around 0.3% of total price is estimated to result from this measure.

The actual replacement of virgin textile materials by their recycled equivalent is particularly challenging to calculate. This is because the ability to recycle textiles is very much dependent upon the materials within the textile products, the presence of disruptors, colour of the textiles and other variables. In its study on the technical, regulatory, economic and environmental effectiveness of textile fibres recycling 47 , the European Commission identified that mechanical recycling leaves 5-20% of the input fraction as spinnable fibres for natural fibres and 25-55% in the case of polycotton or polyester. However, it is acknowledged that the quality of these fibres is lower than the quality of virgin fibres. In the case of thermal recycling for synthetic fibres, the recycled polymers are mixed with virgin material to produce new fibres. Full fibre recycling is not yet possible. Similarly, chemical recycling of cotton results in materials that are generally blended with virgin materials, whereas for PA6 and PET monomer, recycling can result in high-purity virgin grade PET and inputs for virgin grade PA6. Whilst it is clear that recycling of textiles will result in the replacement of virgin textile fibres with subsequent economic and environmental benefits resulting from such recycling the volumes of displacement are highly uncertain. Using a basic assumption that between 20 – 50% of the volumes available for recycling being replace virgin fibres would result in 118 000 to 295 000 tonnes of virgin fibres would be replaced by recycled fibres under this measure.

Waste management operators that are reliant on disposal revenues for textiles would face a reduction in revenues from less textile waste being sent to disposal. With the expected increase in collection under the baseline and the obligation for sorting under this measure the result would be a diversion from landfill of approximately 530 000 tonnes per year by 2035. Several Member States also impose both an incineration and a landfill tax. Therefore, the reduced tonnage of waste sent for disposal would also lead to a reduced tax revenue. Using an average landfill tax revenue of 50 euro per tonne 48 revenues for waste management operators would fall by approximately 26.5 million euro per annum by 2035. On the other hand, many Member States are increasing their per tonnage rates of these taxes to promote recycling.

The sorting operators also will incur costs to monitoring and adapting their practices to ensure that their sorting protocols (i.e. the granularity of sorted fractions for re-use) are adapted to the specific re-use markets in the countries where their produced sorted textiles may be shipped to. Therefore, information will need to be generated and kept for inspection to demonstrate how the sorters have identified the needs of the receiving re-use markets and adapted their sorting protocols to respond to those findings. There are re-occurring (depending on the amount of traders used by the sorters) costs to the sorting facility operators (to note that under measure 2.9 this cost is due to producers subject to an extended producer obligation) to gather data about the countries (including third countries) where textiles are exported for reuse and an analysis of data and subsequent adaptation of the facilities’ sorting protocols and training of sorting staff to adapt to the new sorting protocols. This entails gathering information from their trading partners where their textiles are being shipped to, which can be attained through contractual means.

The adoption of an implementing act in the future by the Commission would facilitate the monitoring and enforcement activities of the competent authorities since a more detailed set of requirements would provide more clarity on the regulatory expectation. It would also facilitate the compliance costs for economic operators as it would ensure a level playing field across the EU and entities that operate in several countries.

This obligation would be enforced as part of the other permitting requirements for the sorting facilities; therefore, allowing for synergies with the existing enforcement processes. Depending on the national permitting and registration systems, the permitting or registration conditions for sorting operators may need to be revised. There may be need for additional staff to perform such inspections as well as operator time to assist in such inspections. It is assumed that, as part of the existing national inspection policies for the permitting processes, the inspections of the requirements in this measure, would take place once every three years and entail three days of effort on behalf of competent authorities entailing preparation for the inspection, undertaking the inspection and recording the results of the inspection.

·One day of assistance per operator per inspection would be required.

·The annualised costs per inspection would be approximately 208 euro per competent authority and 78 euro per operators for the additional inspection.

Importers in third country businesses that currently manage unsorted textiles - exported outside the EU as non-waste - and that perform preparing for reuse activities, are likely to receive less unsorted waste in the future. They would receive unsorted textiles classified as waste and therefore would need to abide by waste rules in carrying out sorting activities which would increase costs. However, the sorted textiles, meant for reuse that they will receive are expected to be more suitable for their market and this should contain limited amounts of waste, reducing the costs of disposing it in an environmentally sound manner.

With regard to pre-consumer textiles, the different fractions of textiles materials and textiles items would be required to be kept separate at the point of waste generation in order to facilitate subsequent preparation for reuse or recycling and subject to recovery operations. This may require changes to the way in which wastes are separated at the point of generation and collected by waste operators. Whilst the volumes of waste being generated would not change, the manner of their storage and collection would change. This may, in turn, generate some small additional costs to enact.

Environmental impacts

Requiring sorting is likely to have two main environmental impacts. Firstly, an obligation to sort textiles in order to export them for reuse, would assist in the strong reduction of textiles that are not actually reusable (i.e., they are waste) as these would either be retained within the EU and be disposed of or would be exported unsorted (i.e., as waste) and subject to the requirements of the WSR. The negative impacts of the materials that are in fact waste and are currently exported as reusable textiles would, therefore, be mitigated. Secondly, an obligation to sort textiles according to EU wide criteria is likely to result in a more consistent sorting process that maximises reuse and recycling of textiles in the first instance, ensuring that a greater volume of textiles are managed higher up the waste hierarchy and, as a result, the environmental impacts of those materials are mitigated to the extent possible.

The effect of displacement of new textiles by reused textiles is also likely to take place. However, there is little certainty as to the level of displacement that would take place. In an assessment of the environmental benefits of reusing clothes 49 Farrant et al examined the displacement of new clothing purchases through second hand clothing sales and found that the purchase of 100 items of second-hand clothing was estimated to reduce the purchase of between 60 and 85 virgin clothes, depending on the place of reuse. At the same time, however, it is important to note that only approximately 15% of clothing suitable for reuse following separate collection in the EU is actually reused within the EU, with the rest exported to third countries for reuse. Consequently, the effect of increased sorting and reuse within the EU on sales of new textiles equivalents is likely to be limited. Using the lower estimate of Farrant et al of 60 percent replacement and the changes in sorting and reusable fractions foreseen under this measure the additional volume of displacement would be approximately 58 500 tonnes by 2035, or approximately a 1% effect on new textile sales in the EU. A displacement effect outside of the EU is also possible but given the wide variety of nations that receive EU used textiles the effects in those recipient countries cannot be quantified.

Additionally, the recycling of textiles would replace some virgin fibre production with recycled fibres. As noted under the economic impacts using a basic assumption that between 20 – 50% of the volumes available for recycling would replace virgin fibres would result in between 118 000 tonnes and 295 000 tonnes of virgin fibres being replaced by recycled fibres under this measure. Under such circumstances the environmental impacts of virgin fibre production would be avoided. McKinsey 50 uses values from the Stockholm Environmental Institute to calculate land use for the production of virgin fibres whereby ~2 hectare per tonne of fibre output as an average all fibres is applied to calculate the land-use saved through displacement of virgin fibres by recycled fibres. Additionally, McKinsey calculates water consumption of approximately 600m3 per tonne of fibre output using data from Mistra Future Fashion which in itself summarises various data points. Applying the same values to the potential savings in virgin fibre production calculated under this measures would result in land use savings of between 236 000 hectares and 590 000 hectares and water savings of between 71 million and 177 million m3 per year.

The volume of textiles exported from the EU to third countries each year was predicted in the Commission Impact Assessment accompanying the proposal to amend the WSR 51 that indicated that exports beyond 2030 would equate to over 2 million tonnes. As noted under the impacts for measure 2.8 that looks at waste shipment practices in the main receiving countries of EU textile waste, the recycling infrastructure in those countries is limited and high levels of landfilling and open dumping of waste is prevalent. Using a conservative estimate that 8% of the materials sent to third countries that is disposed could otherwise have been recycled would entail a reduction in CO2e emissions of approximately 160 000 tonnes per year equalling 16 million euro year of environmental damage avoided by greater recycling by 2035. Additionally, impacts from the release of pollutants due to incineration and / or landfilling in third countries would be avoided, including air pollution, water and groundwater pollution and release of microplastics.

The expectation is that exports of textiles that are not actually reusable (i.e. they are waste) will be retained within the EU and managed accordingly or exported outside the EU for further treatment in accordance with the Waste Shipment Regulation which once the recast regulation enters into force will entail a verification mechanism that waste is exported only to those countries that have an appropriate waste management policy and infrastructure that ensures an equivalent treatment requirements for the waste than in the EU. The negative impacts of the materials that are waste and are exported at present would therefore be mitigated.

Social impacts

Setting sorting requirements would be expected to lead to additional employment in the sorting, the reuse and further treatment of materials sectors, in the EU or in third countries. Whilst it is difficult to determine the downstream processing employment that would result, in terms of sorting capacity alone, 8 740 jobs are expected to be created to handle the increase in textile waste generation foreseen.

Additionally, the social impacts of textiles waste in third countries is emphasised in the Commission’s Staff Working Document accompanying the ecodesign proposal 52 that notes that garments exported for reuse often end up being burnt, which impacts the local environment and inhabitants as developing countries generally do not have the suitable infrastructure to discard them safely. The same SWD quotes that 40% of the clothing traded at the Kantamanto Market (Ghana) ends up in landfill almost immediately due to its poor quality. McKinsey 53 also notes that exports of used clothing and household textiles to third countries are partly legitimate and aligned with the waste hierarchy as some goes to reuse. However, McKinsey also identifies that there is simultaneously a large problem with textile-waste management, especially in some of the Global South countries to which European textiles are exported—particularly the exports of unsorted textile waste as many of these countries do not have the capacity to recycle this waste, and, as a consequence, much of it ends up in landfills or incineration. Whilst several NGOs have highlighted the challenges resulting from exports of textile from the EU to third countries Greenpeace 54 , the Plastic Soup Foundation 55 and the movie ‘Textile Mountain’ 56 , the challenges of fast fashion have also been acknowledged by UNEP 57 and the OECD 58 at the end of textile life. The export of these quantities also leads to additional transport, further weighing down on the environmental impact of textiles. Ensuring that better sorted textiles are sent to third countries for reuse should add to the value of those exports and to those receiving them in third countries whilst negating the waste management costs that currently arise through the contamination of reusable textiles with waste.

The further targeting of textile wastes sent to such third countries would undoubtedly reduce the volumes of materials dumped and open-burned in such a manner, having a positive impact on the social wellbeing on people in proximity to such waste sites as well as in relation to the health and safety of those currently involved in such waste management activities. Conversely, however, the employment of those currently involved in sorting textiles in third countries may be negatively impacted from an economic standpoint as sorting may instead be taking place within the EU (otherwise the requirements of the WSR would apply to protect workers in the country of receipt). It has not been possible to quantify the number of jobs that would be impacted but the number would almost certainly be higher than the number of additional jobs expected to be generated within the EU through additional sorting as a result of the more automated sorting practices that take place within the EU in comparison to third countries.

Finally, as noted in the Commission Staff Working Document accompanying the proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products 59 workers in third countries are most often not protected against the health risks related to the pesticides and chemicals involved in the production of cotton and cotton products, as they generally work without a contract and / or without social security benefits 60 . With a salary below the minimum wage, workers can barely afford housing, food, education, and medical treatment. Child labour is also common across the production line, because of the strong demand for cotton and garments, poverty, and weak legislation 61 .

Impact on SMEs and social enterprises

Given the majority of those involved in collecting textiles and their subsequent sorting are SMEs and social enterprises as well as some commercial SMEs the obligation to make sure that textiles are sorted would generally fall on these enterprises, without prejudice to Member State right to engage other actors in implementing the separate collection obligation, including public waste management entities, and measure 2.9 in this initiative. As noted above, with increasing sorting, the revenue from reuse and recycling is also likely to increase to partially offset the additional costs that will be required to implement the sorting requirements. This additional cost incurred by the sorting operators would bring economic benefits to operators placing used textiles on the market or producing textiles using recycled textiles due to the economies of scale that would reduce the cost and improve the consistency and availability of these materials of high quality. The additional costs of meeting the sorting criteria are expected to be minor where measure 2.9 (EPR schemes for textiles) is in place and would facilitate their operations since the cost of managing residual waste is assigned to the EPR.

An additional 0.5 FTE would be required within the European Commission to adopt the necessary implementing act setting out harmonised sorting requirements for re-use and recycling.

Stakeholder evidence

Stakeholders focused on two key challenges in relation to sorting. Textile value chain representatives 62 considered that a lack of harmonization for sorting criteria and fragmentation of the sorting market at the EU level hinder large scale circulation of used textiles and textile wastes. Industry representatives indicated a particular challenge is the cost of manual sorting and the lack of automated sorting technologies. All stakeholder groups have recognized the available information by NGOs that place unsorted or badly sorted textiles in the EU as one of the culprits of unsustainable textile waste management in the third countries.

Table 10 : Summary of impacts for measure 2.5

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 11 - impacts on competitiveness of measure 2.5

Measure 2.6 – Adopting end of waste criteria

Assessment of impact Measure 2.6

Economic impacts

Minimising divergence of approaches to end-of-waste criteria ensures a level playing field and provides the opportunity to ensure that sorted textiles for re-use are fit for re-use and there is consistency in the sorting outputs for the variety of re-use markets. The criteria would have a notable benefit for the textile recycling sector by ensuring sufficiently consistent feedstock from the sorting processes as input to the recycling processes and the certainty of a product status for the outputs of recycling. This certainty would foster recycling techniques that are dependent on a sufficiently defined supply of materials to reach commercial viability in the future. This would encourage investment in infrastructure projects and promote a market for high quality secondary textile materials. This would also ensure a level playing field for the operators based in different countries to avoid distortion of competition which could otherwise create more favourable circumstances for companies, for example, that are operating in countries with national end of waste criteria. However, given the precise scope of the textiles that may be impacted by the final end-of-waste criteria is unknown it is not possible to state with certainty the changes in flows by volume that would actually take place. However, as a result of materials reaching end of waste status the costs of managing those materials is likely to reduce, albeit by a relatively small amount. The extent to which these savings may be passed on to consumers is unknown, and in reality it is likely that any savings will be felt by businesses rather than directly by consumers of textile goods. This would, in turn, not result in a change in prices to consumers but may result in an increase in profitability for the reuse and recycling sector within the EU

The JRC 63 notes that for certain wastes, end-of-waste criteria can promote the production of higher quality secondary products by defining technical and environmental minimum requirements to be fulfilled by the materials. Information on the product characteristics facilitates their comparison, enhance the final quality of the final product and may alleviate user prejudice. These would all lead to an increase in their demand and their recycling rates.

This echoes messages identified in relation to end-of-waste criteria for other wastes including metal scrap 64 . Harmonised EU criteria would ensure free movement of textile materials within the EU as intra-shipment will no longer be in relation to a waste but will be in relation to a textile material that is no longer waste.

Textiles come in a variety of types of material and scope of application. It is expected that end-of-waste criteria will need to be developed for this broad family of materials over time and developing end-of-waste criteria may be delayed for certain textile materials whilst priority textiles are initially addressed. This would allow investment to be focussed on the most environmentally important textile wastes in the first instance and to be addressed more efficiently than is presently the case.

Certainty on the end-of-waste status for sorted re-usable textiles exported outside the EU would positively impact the re-use operators as it would reduce their waste management costs since the potential waste fraction within the textile bales would be minimised through more rigorous sorting in the EU (this is the combined impact of measures 2.5, 2.6, 2.8).

Environmental impacts

Article 6 of the WFD makes clear that end-of-waste can only apply if the use of the substance or object will not lead to overall adverse environmental or human health impacts. In keeping with this provision it is considered that there are unlikely to be any significant negative environmental impacts resulting from this measure. The application of the criteria will facilitate the shipments of waste for the treatment as well as end of waste material across the Union and outside. For end of waste material, the rules of the Waste Shipment Regulation would not apply and therefore would facilitate the shipments outside the EU. The end-of-waste criteria, that build also on measure 2.5. and 2.8, will minimise the risk that the loads exported as sorted textiles may contain waste fractions.

In relation to the potential replacement of primary products with end-of-waste products it would be expected that this replacement would have environmental benefits by driving down the need for virgin materials in the future and the environmental impacts of the production of virgin materials. It is not possible to quantify these impacts as the precise scope of textiles that would impacted by the end-of-waste criteria is unknown.

In view of the production of textiles consumed in the EU largely taking place outside the EU and the majority of textiles collected and sorted for re-use being destined to global re-use markets, the environmental benefits are largely allocated in third countries.

Social impacts

No significant social impacts have been identified.

Administrative burden

Under the current EU regime, waste textiles even if they may be suitable for reuse or as a feedstock for recycling, are subject to a waste control mechanism for the movements between Member States. The development of end-of-waste criteria would mean that the shipment of waste for recovery that meet those criteria would be facilitated. The materials that meet the criteria for the output of the recovery operation would no longer be subject to waste legislation and controls. This would remove the administration in relation to the waste status and simplify shipments of textiles accordingly both within and outside the EU. Inspections of shipments for compliance with the waste legislation would be facilitated as compliance would be checked against a set of harmonised rules in the EU; furthermore, the criteria would also provide for the evidence (traceability and quality check requirements) to demonstrate compliance.

An additional 0.5 FTE would be required within the European Commission to adopt the necessary implementing act setting out harmonised end of waste criteria.

Impact on SMEs and social enterprises

Given SMEs, including social enterprises, are the majority of those involved in the placing on the market of textiles as well as in their waste management (sorting, transportation, recycling and re-use), the application of end-of-waste criteria is most likely to provide benefits to SMEs and social enterprises above other stakeholders.

Stakeholder evidence

Both the industry and a major NGO recognise that there is a need to define end-of-waste criteria and that this measure plays a crucial role in establishing shared systems and understanding 65   66 . Due to their capacity to support coordination of systems across states, addressing definitions, guidance development and sharing of best practice and the adoption of EU end-of-waste criteria for textiles were regarded as key enablers, and suggestions were that they should potentially be applied together. Combined these would reduce the administrative burdens, cost and exporting challenges in relation to certain textile materials, whilst driving economies of scale. In turn, this would decrease costs for recyclers as well as brands, retailers and consumers by reducing the price for recycled materials52. These measures could also be further paired with EPR to accelerate their impact 67   68 .

The role of harmonisation across states was also identified as vital to avoid distortion of competition which could create more favourable circumstances for some companies 69 .

The Commission – through the JRC – is already exploring end-of-waste criteria for textiles and there is need for further understanding on textile waste vs used textiles. The Commission should develop guidance on end-of-waste status (both when a product becomes a waste and when a waste becomes a product). Harmonising those rules at European level is key to facilitate preparation for reuse targets 70 . Participants particularly desired a better understanding of how to treat and process textile waste as a resource which will create the volumes needed to make recovery worthwhile and scalable.

As is the case with other measures, feedback indicated the need for end-of-waste criteria to align with the focus of other key regulatory initiatives such as the ESPR, alongside investment in recycling. It was also suggested that EoW criteria be focused on high volume materials such as pure cotton streams which could allow for key learnings to be captured which would inform application to other textile waste streams. EoW criteria should then be considered for the wider range of fibre and blends used across the industry, to ensure investment in technologies which can also recycle these 71 . In addition, the textile-related definitions currently being developed by the European Committee for Standardization should be fully considered in the revised directive 72 .

Table 12 : Summary of impacts for measure 2.6

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 13 - impacts on competitiveness of measure 2.6

Measure 2.8 – Setting requirements for shipments of textiles for reuse

Assessment of impact Measure 2.

Economic impacts

Implementation of this measure would entail costs in relation to:

Member States setting up the templates for the presentation of the information required upon inspection. However, the requirements in the measure are focused on factual information. Therefore, there should not be much room for national adaptations. Furthermore, this information is already readily available to the operators. This information is to be held by the entities transporting used textiles. Since this information is likely to be already available, no significant additional costs would be attributed to the compliance with these requirements.

Operators would need to provide a declaration that the textiles exported are not waste. This is expected to be less than an hour per declaration, with the main cost related to the reporting of materials to the relevant competent authority once per year under the existing reporting obligations. This would amount to approximately 208 euro per operator per year affected 73 . It is unknown how many enterprises would be affected by such an obligation as the total number of relevant exporters is not recorded at the EU level.

The requirements in relation to the preparation of the bales of sorted textiles for transportation reflect the best practice of the industry to ensure that the value of the products is maintained; therefore, no significant additional costs would be attributed to the compliance with these requirements for the sorters or transporters of goods.

With regard to the enforcement activities of the competent authorities, the requirements for the availability of documentation proving the product status of textiles should facilitate the existing enforcement and inspection processes carried out by the authorities in the enforcement of Waste Shipment Regulation. Therefore, a reduced administrative burden is expected for inspectors that could not be quantified precisely.

Inspections in the third countries receiving textiles are not foreseen under this measure so there is no additional administrative burden.

New business opportunities for entities (based in the EU or outside the EU) to assist the sorting operators in data collection in third countries where textiles are exported for reuse and data analysis may be expected and reduced textile waste management costs to the reuse operators within or outside the EU on account of reduced share of potential waste fractions in the bales of sorted textiles for reuse imported from the EU should be realised.

Potential impacts on flows of textile waste are presented under environmental impacts below.

No significant impact on the price of textile goods would result from this measure.

Environmental impacts

The majority of exports from the EU to third countries of used clothing and clothing accessories, blankets and travelling rugs, household linen and articles for interior furnishing and textile materials including all types of footwear and headgear are to non-OECD countries. An examination of data from Comext 74 for the period 2017-2021 shows that in 2021, 61 countries received 98.8% of volumes exported from the EU, amounting to at least 1 000 tonnes of used textiles from the EU. The controls in place for the management of these materials are likely to vary dramatically.

The top ten destination countries for EU exports the period 2017-2021 are shown below.

Table 14 : Destination countries for EU exports of used textiles

Stakeholders in the context of the impact assessment accompanying the proposal for a revision of the Waste Shipments Regulation 75 raised the issue that third countries often welcome EU wastes as they are generally well sorted and have a higher economic value compared to domestic waste or waste from other countries. However, the import of EU wastes can displace domestically generated wastes in other countries with even less effective management of waste or cause them to be simply disposed or even dumped rather than being managed appropriately as shown in Table below.

An examination of waste management practices in the top destination countries of used EU textiles listed using data from the World Bank 76  notes a high level of landfilling and open burning in those countries.

Table 15 : Waste management practices in importing third countries

Source: World Bank, 2020

In general (except Turkey) within OECD and EU countries only 35% of waste is landfilled 77  meaning that these countries have more effective waste management in place in comparison to those countries receiving used EU textiles. This would support the hypotheses therefore that EU textile wastes are likely to be contributing to the blocking more effective management of domestic wastes in those third countries. Placing a financial cost on such displacement is not possible. However, ensuring that textiles exported are fit for reuse and are not a waste would clearly have a positive impact on the management of waste in those countries and the related environmental benefit.

To determine the environmental impacts resulting from textile waste management in third countries in comparison to the EU the support study used the dedicated waste LCA-model EASETECH 78   also used by the JRC applied the datasets describing open dump and open burning activities for individual waste materials. In the absence of a specific dataset for textile the impact of textile waste has been approximated as a mix of plastic (15%) and paper/cardboard (85%) based on the assumption that ca. 15% of the textile is composed of biological fibres while the rest is synthetic (Riber et al. 2009 79 ). To calculate the net environmental benefits of managing textile wastes in the EU in comparison to third countries the following results from EASETECH have been applied: a GHG saving by treatment in the EU in comparison to third countries of 1.7 tonnes CO2e per tonne of textiles disposed of and saving in terms of externalities when 285 euro per tonne has been applied 80 .

It is difficult to determine the volumes of waste textiles currently included in total exports of EU clothing to third countries. Using the rejection rate of collection bins (approximately 10%) on the 475 000 tonnes of textiles sorting that is currently undertaken in third countries, would result in 47 500 tonnes of textiles being waste. Alternatively, using Comext values for all EU exports of used textiles in 2021 of 1.325 million tonnes and applying the same 10% waste content of all such shipments would mean that for 2021, 132 500 tonnes of textile wastes may be found in materials currently exported. If the values reported in relation to Staff Working Document accompanying the ecodesign proposal 81 of 40% of the materials exported being waste were used these values would climb to between 190 000 and 530 000 tonnes. Managing these wastes within the EU in comparison to third countries would result in CO2 eq savings of approximately 81 000 – 225 000 tonnes per year and externality savings of between 13.5 million and 37.7 million euro per year using the 10% waste value and 54 million euro and 150.8 million euro per year.

Social impacts

The social impacts of textiles waste are emphasised in the Commission’s Staff Working Document accompanying the ecodesign proposal 82 that notes that garments exported for reuse often end up being burnt, which impacts the local environment and inhabitants as developing countries generally do not have the suitable infrastructure to discard them safely. The same SWD quotes that 40% of the clothing traded at the Kantamanto Market (Ghana) ends up in landfill almost immediately due to its poor quality. McKinsey 83 also notes that exports of used clothing and household textiles to third countries are partly legitimate and aligned with the waste hierarchy as some goes to reuse. However, McKinsey also identifies that there is simultaneously a large problem with textile-waste management especially in some of the Global South countries to which European textiles are exported—particularly the exports of unsorted textile waste as many of these countries do not have the capacity to recycle this waste and as a consequence much of it ends up in landfills or incineration. Whilst several NGOs have highlighted the challenges resulting from exports of textile from the EU to third countries (Greenpeace 84 , the Plastic Soup Foundation 85 , and the movie ‘Textile Mountain’ 86 ), the challenges of fast fashion have also been acknowledged by UNEP 87 and the OECD 88 at the end of textile life. The export of these quantities also leads to additional transport further weighing down on the environmental impact of textiles.

This measure with regard to textile wastes sent to third countries would undoubtedly reduce the volumes of materials dumped and open-burned in such a manner having a positive impact on the social wellbeing on people in proximity to such waste sites as well as in relation to the health and safety of those currently involved in such waste management activities. Conversely, however, and in keeping with the social impacts of measure 2.5, the employment of those currently involved in sorting textiles in third countries would be negatively impacted from an economic standpoint as textiles would be better managed within the EU requiring less sorting to take place in third countries.

Impact on SMEs and social enterprises

Given the majority of those involved in collecting and sorting textiles are SMEs including social enterprises which currently largely take care of textile collection the obligations under this measure (proper preparation of bales for shipment transportation, documentation preparation, as well as support for related inspections by competent authorities) would fall on such enterprises. The requirements in relation to the preparation of the bales of sorted textiles for transportation reflect the best practice of the industry to ensure that the value of the products is maintained; therefore no remarkable additional costs would be attributed to the compliance with these requirements for the sorters or transporters of used textiles.

Stakeholder evidence

The NGO stakeholders as well as sorters have raised concerns about the impacts on third countries as a result of import from the EU of used textiles due to illegal shipments or legal shipments of used textiles which may nevertheless contain large fractions of non-reusable textiles placing burden on the waste management systems in those countries. These views have been raised in the stakeholder textile workshops, targeted consultation as well as in materials submitted as evidence during this assessment 89 .

Table 16 : Summary of impacts for measure 2.8

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 17 - impacts on competitiveness of measure 2.8

Measure 2.9 – Mandating the use of EPR

Assessment of impact Measure 2.9

Due to a lack of data on pre-consumer textiles, post-commercial textiles and post-industrials textiles the assessment of impacts below focusses on the post-consumer fractions of textile waste.

Economic impact

The intention behind an EPR is to ensure that the producers of textiles take into account the costs of end-of-life management of the textiles that they produce. According to the evidence collected the management of discarded textiles both across the EU and within EU Member States is fragmented with a mix of different actors from the public, private and social enterprise sector involved in different aspects of collection, sorting, reuse, recycling and disposal. This inevitably leads to inefficiencies in waste management and the transfer of overall responsibility from this mix of actors to EPR would look to address these inefficiencies whilst making sure that the actors already involved in such waste management as well as new actors in the future are given a role in the operation of EPR as required under Article 8a(6) of the WFD. In this respect and reflecting on the economic impacts addressed in the individual elements in Annex 10, the costs that would be moved from the variety of actors that currently and in the future would be managing waste to PROs acting on behalf of producers under EPR would equate to approximately 2.28 billion euro by 2035 or approximately 3.5% of the turnover of the clothing sector in 2022 90  and 1.5% of the turnover of the textiles sector overall. Approximately 457 million euro of the total relates to collection costs with the remaining 1.8 billion euro related to sorting and treatment costs. At the same time approximately 1.1 billion euro of reusable textiles would be available to the market as well as 188 million euro of textiles for feeding into closed loop recycling and 49 million of textiles for open loop recycling – these impacts may be expected to take place under the baseline but the funding necessary to ensure that this is the case would be far more unsure across the EU than under an obligatory EPR scheme.

It is also important to note that much of these costs are not additional but are instead otherwise covered through general waste management funding at the Member State level including through general taxation. Therefore, this entails a transfer of costs from public authorities and waste management actors to the producers. In effect 58% of the costs would be recovered through the onward reuse and recycling of the textile wastes collected, sorted and subsequently resold or recycled.

The impacts on the price of textile goods would equate to an average cost increase of 0.6%. For an average T-shirt this would be a maximum of 12c per T-shirt with the actual cost likely to be lower. For more complex textiles items containing disruptors such as zips and buttons the cost per item in cents would be higher but as a proportion of the total cost of the product is likely to remain the same

It is important to note that the introduction of EPR has the potential to change the nature of the organisations involved in the collection, sorting and subsequent reuse, recycling and disposal of textiles. As noted in Annexes 5 and 6 in all countries where data is available the major share of used textile collection is currently carried out by charitable and commercial collectors. In Denmark, Finland, Latvia and Sweden, the collection is dominated by charitable organisations. In Lithuania, commercial collectors are responsible for 54 % of collection. 91 In France, Germany and the Netherlands, commercial collectors also have a reportedly high share of the market, though there are no concrete figures on how big this share is. 92 Municipal waste companies play an increasing role in used textile collection in many countries. In Estonia, due to legal obligations, municipalities carry out 37 % of all collection, and in Lithuania they have a 30 % share. 93 Collection by municipal waste companies in Denmark, Netherlands and Sweden are thought to be lower. In Denmark for example municipalities had a share of 5 % in all collection in 2017, but this is increasing over time. 94 Implementation of EPR has the potential to change this approach as Member States may increasingly look to municipalities and commercial operators to ensure the collection of textiles wastes and their subsequent sorting and treatment.

The measure foresees the need for Member States to ensure that social enterprises are involved in the operation of EPR schemes as well as in an active dialogue in implementation in accordance with Article 8 of the WFD in order to mitigate the potential negative impacts of EPR on their operations. However, it is expected that the costs of collection and sorting would increasingly fall upon commercial operators and municipalities, particularly given the likely fall in the quality of textiles for reuse that would result from increased collection in the future. The funding generated by EPR is likely, therefore, to focus on the additional collection and sorting that will take place in the future with municipalities and commercial waste collectors and sorters receiving the majority of funds generated through EPR to address these costs. This will be particularly important for the recycling sector that requires funding to support research and development and is not the primary focus of textile collections operated by social enterprises that focus on reuse. This is ably demonstrated by the estimated costs of the likes of the ReHubs initiative that has identified costs of implementation of 6-7 billion euro up to 2030 but for which funding is sought 95 . Additionally, the geographical scope of Rehubs envisages five Member States acting as recycling centres - Belgium, Finland, Germany, Italy and Spain. These Member States would also serve other EU Member States. However, this leaves a gap geographically in central Europe, particularly for the likes of Romania, Bulgaria, Greece, Hungary and Slovakia that are some distance from the nearest Rehub, each requiring textile wastes to transit over at least one other country to reach the necessary recycling centre. The need to ensure sufficient and cost-effective recycling is provided for these Member States would also likely require PRO funding.

The development of a producer register would require a new register to be developed. Setting up a register will generate additional costs both in terms of establishment and in terms of maintenance of the system. In ascertaining the costs of such a system an examination of the costs identified in the application of registration under the WEEE Directive has been performed. In the impact assessment accompanying the proposal to recast the WEEE Directive in 2008, the costs of drawing up registers of producers across the EU was determined as 14M euro in total. Adjusted for inflation the present-day cost would be 18.7M euro for the EU in total. However, these registers for WEEE address almost 90 000 producers in the EU overall. Depending on the inclusion of exclusion of micro-enterprises (see Table 59 below) the number of producers likely to be impacted in the EU for textiles would more likely sit between 16 500 and 68 000 producers. The costs for textiles would, therefore, be lower and more likely sit between 2 and 12.3 million euro. It is likely that the upper bound is still overestimated since it should be feasible to reduce the costs by integrating the register into other existing systems for producer registers under other EPR schemes; it is a practice in several Member States to operate producer registers that serve simultaneously several EPR systems.

With the two systems already in operation in France and the Netherlands, the average cost per Member State would, therefore, be between 80 000 and 492 000 million euro per Member State dependent on the inclusion or exclusion of micro-enterprises. Maintenance costs, in keeping with the estimated maintenance costs of registers at the EU level as presented in the Commission Impact Assessment accompanying the proposal to revise the Waste Shipments Regulation are estimated at between 11 200 and 69 000 euro per Member State per year.

Additional costs would apply in relation to producers registering with the system. The main costs would be in completing producer details to enable the generation of the relevant Producer number. Such costs would expect to equate to 0.5 day per producer to complete the relevant details with a total cost of 104 euro per registration. Whilst the total number of Producers that would be impacted is unknown for those not manufacturing products within the EU, for manufacturers of textiles within the EU this would be a one-off cost and is assessed below.

Table 18 : Indicative one-off costs for registering in a national producer register

As can be seen, should micro-enterprises be included in the scope of EPR, the majority of costs would fall upon this fraction of EU textile manufacturers. Should micro-enterprises be excluded the total administrative burden would decrease from 13.35 million to 1.35 million euro for the EU overall.

The calculations of the one-off registration costs reflect on a situation whereby each producer registers in one producer register. However, there are likely to be situations whereby producers place goods on the market of more than one Member State. The one-off costs identified above would, therefore, multiply in the case where producers place goods on the market of more than one Member States. If, for example, producers placed goods on the market of five different Member States which even for smaller producers is possible with the rise of online sales, the total costs would be approximately five times higher as whilst the basic requirements should be the same across the EU the variations in actual systems of registration and language requirement will likely result in little saving in terms of time taken to register in additional countries once registration has taken place in another. The measure therefore provides that the information requirements that producers need to submit to the register are harmonised and specified in the WFD so that it is clear from the outset of the WFD revision across the EU and reduce compliance costs for producers operating across several countries.

In the case of producers selling goods in Member States where they have no legal registration they will need to register with an authorised representative in the country of sale. An authorized representative is a natural or legal person who assumes EPR obligations in a country on behalf of such a producer. Authorised representatives will charge fees to represent producers in third countries. By way of example, a service provider 96 offering authorised representative services to both producers located within the EU and producers based in third countries charges an annual fee of approximately 1 800 euro per year plus an hourly rate of 225 euro per hour for additional support. In the case of medical devices that also require an authorised representative a figure of approximately 2 000 euro per year is quoted 97 . In both of these examples the services include the costs in relation to product standards that are likely to be higher in terms of resources required to be expended by an Authorised Representative in relation to EPR. With this in mind, the lower cost quoted of approximately 1 800 euro per year for the appointment of an authorised in any given Member State is considered representative in this case. These fees would apply per country of sale and, thereby, should a producer sell in several countries using an authorised representative in each the costs would be multiplied by the additional number of countries concerned. There is also the possibility for PROs to operate as an Authorised Representative for producers in other Member States placing goods on the market for the Member State within which they are the PRO. In this case the costs of registration with a PRO in the previous paragraph would apply.

Additionally, producers will be required to provide information on the volume of products placed on the market and in relation to the eco-modulation of fees to determine the fees payable on the basis of the eco-modulation criteria applicable to their products. The production of data addressing the overall volume of goods placed on the market would be similar to the costs of initial registration i.e., 0.5 day per producer. The costs highlighted above for one-off registration would, therefore, be duplicated for this reporting measure i.e., the total costs would be approximately 13.4 million euro per year should micro-enterprises be included and 1.35 million euro per year were they not. The production of data in relation to the eco-modulation of fees, however, will require more time and effort. In the case of the French EPR, the sustainability, integration of recycled materials from household waste and integration of recycled materials from production scrap alongside the base EPR fees effectively results in almost 50 categories to be considered in reporting of eco-modulation fees applicable. The costs are, therefore, dependent on the record keeping of producers against these criteria in any production year to simplify overall reporting alongside any efficiencies that may be achievable by providing standardised reporting tools to producers to assist them in their reporting and calculations. The time taken to report against a similar set of criteria applicable in France is estimated as 2 working days per enterprise or 416 euro per producer. The costs applicable in relation to both of these annual obligations is addressed below. Cost mitigation aspects of this measure entail: mandating the reporting under the PRO to take place annually and envisaging a mandate to the Commission to develop harmonised rules for the fee modulation purposes, including on the product category granularity for fee application.

Table 19 : Indicative annual costs of reporting total quantities of goods placed on the market as well as data on eco-modulation for EU manufacturers of textiles

In keeping with existing EPR obligations under the acquis addressing electric and electronic equipment, batteries and packaging, Member States would be able to decide whether the register of producers is publicly accessible or not. In order for the online platforms to fulfil their obligations under this measure as a verifier of traders using their services, it would be necessary for online platforms to have access to national registers. This should not entail significant costs to the producer registers; also noting that similar obligations are also relevant for other EPR schemes and their producer registers.

With regard to the manufacturing of wearing apparel sector, the complete exclusion of micro-enterprises would effectively require the remaining 10.1% of enterprises to address the costs stemming from the exempted entities that represent 89.9%. However, by weight of goods, this represents an additional cost to SMEs and larger operators of approximately 16% of their EPR costs and this is likely to be a small additional cost. This approach would also minimise the administrative cost of applying EPR to 116 000 enterprises across the EU, and the enforcement costs for the competent authorities in ensuring that all such micro-enterprises are compliant with the EPR scheme.

A potential impact of the exclusion of micro-enterprises from EPR obligations is the possibility of the costs for products resulting from micro-enterprises falling upon other SMEs (i.e., those enterprises that have between 10 and 250 employees). As noted in the Eurostat statistics for manufacturers of textiles within the EU 98 the percentage of total turnover by enterprise size as well as the average turnover by enterprise is shown in the table below.

Table 20 : Total percentage of EU turnover and average turnover per enterprise resulting from the manufacture of wearing apparel in the EU

Comparing the administrative costs of EPR per enterprise, it is clear that in the case of micro-enterprises the impact as a percentage of turnover is far higher than for other sizes of enterprise – almost 0.6% of turnover compared to around 0.06% for the next largest category of 10-19 persons, 0.02% for 20-49 persons category, and a negligible impact for the larger sizes of enterprises.

The cost of exempting micro-enterprises can be shifted to the fees applicable to products put on the market by enterprises of other sizes. This would result in the following changes.

Table 21 : Cost shifting to the exemption of micro-enterprises to larger enterprises

The largest additional costs would fall on enterprises with 250 persons or more employed, followed by enterprises with 50-249 persons employed. Enterprises from 10-49 persons employed would see the smallest increase in costs.

Alternatively, the application of a single low flat fee for micro-enterprises would mean that at least a partial contribution to the relevant EPR scheme is made by enterprises that contribute to the textile waste generation. For example, in France, a flat fee of 75 euro per year is applied to producers with less than 750 000 euro turnover per year or if they sell less than 5 000 products in France. Should the same fee be applied to micro-enterprises, the revenue raised would be around 8.695 million euro per year. This option would also raise the costs of EPR scheme administration as well as enforcement for the competent authorities. This cost is estimated at around 525 euro per year. Therefore, the contribution of a flat fee for micro-enterprises seems disproportionate as it adds a significant amount of effort on micro-enterprises while raising less than 9 million per year.

Based on these considerations, it is proposed that micro-enterprises manufacturing textiles should not be subject to the EPR requirements in view of the effectiveness and proportionality principle.

The nature of the textiles industry is such that it is heavily dominated by micro-enterprises for which it is considered that the costs of application of the EPR obligations would be high as a fraction of their turnover whilst the additional administration for PROs and Member States in dealing with the large number of micro-enterprises would also be high. For this reason, the measure has been targeted to exclude micro-enterprises to mitigate this economic impact. Similarly social enterprises involved in the resale of textiles would be excluded given the possible impacts on their operational models and the citizens that benefit from their operation.

Addressing the full costs of waste management would apply the polluter pays principle and with greater investment in the management of textile waste would assist in driving forward to reuse repair and recycling sectors for textile by ensuring that adequate funding is in place.

The actual costs per textile item are expected to be low. By way of example Eco-Logic 99 notes that Eco-TLC the French PRO for textiles calculates the EPR fees based on the number of items placed on the market. The categories of fees are divided into 4 levels of scale depending on the size of the items: very small, small, medium and large items (Eco TLC  2019). Eco-modulation is applied on top of the standard fee, which in turn is based on the durability of textiles as well as the recycled content of textiles. Ecologic notes that the French EPR fees along with eco-modulation make a very small part of the price of the product in France.

Table 22 - EPR and modulated fees for textiles in France

A significant economic advantage that cannot be quantified relates to the standardisation of EPR schemes for textiles across the EU under this measure. As noted in Annexes 6 and 11 FR is currently the only Member State with an EPR for textiles in place. The NL, which was due to implement EPR for textiles on 1 January 2023 (and has been delayed until summer 2023 according to the latest information available) will be the second Member State to implement EPR for textiles and SE is likely to be the third. However, the scope and operation of the EPR schemes varies and the potential for other competing yet different EPR schemes for textiles across the EU risk the development of rapidly diverging schemes that would significantly hamper producers from accessing Member State markets other than their main Member State of business given the likely levels of confusion that would result from this divergence. A good example of this possible divergence is provided in the table below that considers the scope of the EPR schemes for FR, NL and SE.

It is apparent that different choices in relation to the scope of the EPR schemes have or are likely to be made, meaning in turn that producers of different types of textile goods are likely to encounter different requirements in different Member States. The reporting dates also vary, and the application of the requirements to SMEs may also diverge depending on the decisions still to be taken in SE and NL. Finally, the eco-modulation of fees is likely to vary given the different criteria listed in FR, NL and SE. In each of these cases variation of the requirements is likely to result in a lack of level playing field across the EU for producers and a lack of consistency in application of requirements when selling goods in more than one Member State.

In relation to the adoption of Implementing Acts in relation to the content of the Producer Registers as well as the eco-modulation of fees approximately 1.2 FTEs would be required in the European Commission. Member States would also be asked to make input to the necessary implementing act with the total cost of inputs of Member States of approximately 135 000 euro per implementing act with about 50 individuals making input.

Textiles have been confirmed as a priority product under ESPR following the stakeholder consultation 100 , and the technical work supporting the Delegated Act on textiles under the ESPR is underway. It is estimated that the Delegated Act would be adopted in 2024/25 which coincides broadly with the possible adoption and entry into force of the Waste Framework Directive rules on Extended Producer Responsibility considered in this assessment. Therefore, full alignment is possible both at the policy development and implementation stage. Full alignment between the two legislations in terms of scope and standards (e.g. on the design factors and measurement tools) is a top priority for the Commission. In practice, it is important to ensure that fee modulation under EPR is fully consistent with the ESPR sustainability criteria and their measurement standards. This will provide the clearest policy signal and prevent unnecessary administrative burdens. This approach is also strongly supported by the textiles industry.

Environmental impacts

The application of EPR should both ensure that adequate infrastructure for management of textile waste is funded as well as addressing communication to waste holders enabling to better understand the need for and opportunities for separate collection of textiles in the Member State concerned as well as on the overall impacts of textiles on the environment and the contribution of consumers, including in the purchase of used textiles. The environmental impacts may be expected to take place under the baseline, the main advantage of EPR being that the necessary funding to pay for the textiles management necessary to achieve these impacts would both be more likely and more consistent across the EU. Consequently, the indirect environmental impacts of textiles that would otherwise be discarded in residual waste should therefore be more likely to be reduced under this measure including in relation to GHG emissions through both greater reuse of textiles as well as recycling of textiles in comparison to their disposal as well as emissions to air, water and land through the avoidance of disposal in the future. As a proportion of total textile waste generation in the EU disposal would drop from 74% at present to 56% by 2035 with a drop of nearly 670 000 tonnes in total. Notably in relation to recycling, the plans of the European Apparel and Textile Confederation (EURATEX) to significantly boost recycling of textiles is dependent on certainty in relation to the volumes and nature of the feedstock produced. EPR would target both aspects feeding into a textiles recycling market that the industry calls for to ensure investment certainty.

As noted under measure 2.5 in relation to the displacement of new textile products and virgin fibres through increased reuse and recycling, the environmental benefits in all cases outweigh the costs of production of new products and virgin fibres. Using values provided by EuRIC 101 the following savings would be anticipated to be supported through the introduction of EPR in terms of water use.

Furthermore, in the case of recycling approximately ~2 hectare per tonne of fibre output as an average all fibres is applied to calculate the land-use saved through displacement of virgin fibres by recycled fibres. It is expected, therefore, that the support of EPR to recycling activities would support actions that would result in significant saving in terms of land use of up to 1.6 million tonnes by 2035.

Social impacts

The application of EPR would assist in both driving employment by improving investment in textile waste management as well as mitigating the impacts of poor textile waste management for both citizens of the EU as well as in those third countries receiving used textiles from the EU in comparison to the disparate and inconsistent approach that might otherwise develop in the absence of EPR. It has not been possible to quantify these impacts. Sorting and recycling at scale will create jobs and ensure competitiveness in light of increasing raw material and energy costs and ensure that recyclers have the necessary dependable feedstock to significantly increase closed loop recycling within the EU. By driving forward the necessary changes in textile management it is estimated that an additional 5 500 jobs would be created by 2035, supported directly by the introduction of EPR.

With regard to the impact of the EPR obligations on the cost of product, it is not possible to assess with certainty whether the producers will internalise the cost or pass it onto the consumers. Considering that the textile market is fiercely competitive, it may be possible that the producers will internalise the costs. On the other hand, the costs per item are low as shown in the table above so the overall effects are expected to be limited even if the fees applied are passed on to consumers.

Impact on SMEs and social enterprises

Given the majority of those involved as producers are SMEs, the report assessed the implications of excluding certain categories of SMEs (micro enterprises) from the EPR obligations as producers. The same was done in relation to the reuse sector that has a significant proportion of social enterprises involved in the resale of reused textiles. The impacts of their inclusion or exclusion were assessed and conclude with their exclusion. In addition, the implementing acts envisaged harmonising the formats for the producer register registration and fee modulation, including the application of the harmonised criteria on sustainable textiles developed under the ESPR, as well as the obligations for the PRO membership and reduction of reporting to the PRO to annual exercise are all specific measures aimed at minimising the compliance costs for SMEs. Several features of the proposed EPR scheme aim to ensure that the role of the social enterprises in the management of textile waste for re-use purposes is maintained or strengthens with the establishment of the EPR schemes, namely, through setting an obligation for the EPR schemes to allow their participation in the collection networks and to finance the treatment of recyclable and residual waste generated by the textile sorting operations operated by social enterprises. These measures should avoid disrupting the business model of social enterprises and in fact facilitate it.

An additional 1.2 FTE would be required within the European Commission to adopt the necessary implementing acts setting out harmonised fee modulation and producer register registration format.

Stakeholder evidence

Stakeholders from across the textile value chain including NGOs and social enterprises active in the sector recognise the importance and relevance of introducing EPR to facilitate a harmonised approach to managing textile waste in the EU and consider its introduction as a high priority. In respect to support to the recycling sector, in particular, the industry considers EPR as an important funding mechanism to address the R&D and funding gap for such activities. NGOs have also emphasised the importance of EPR for textiles to implement the polluter pays principle. 102  Diverging EPR systems were raised as a concern within the workshops, mainly due to the potential for complex administration and potential high costs for exporting organisations 103 .

Due to the complexity and ambition of the measure, it was highlighted that the scheme would benefit from the parallel application of other models such as the Ecodesign for Sustainable Products Regulation (ESPR) to enhance the effect of the targets set 104 . Industries should also be further encouraged to reuse and repair their products as part of circular economy and materials that are no longer reused should be separately collected. This can potentially increase the currently low textile-to-textile recycling rate as well104.

There is an overwhelming support for mandating EPR for textiles among the industry and NGO stakeholders. There are however some differing opinions in terms of the level of harmonisation that the scheme should pursue acknowledging that both the industry and Member States may require some regulatory flexibility to take inventive measures 105   106 . Others have argued the opposite that providing guidelines or encouraging an implementation of the scheme on a voluntary basis would not be expected to work as effectively as a mandated EPR. 107 Additionally, the latter group suggested that the mandated EPR should be accompanied by a set of harmonised rules for the separate collection and sorting of textiles as well as for the used textiles and textile waste market102. The EPR organisations should be managed by representatives of the key stakeholders such as producers waste collectors sorters and recyclers as well as NGOs102. It is additionally recommended that license fees should not apply to second-hand clothing as it is expected to hamper reuse activities102.

A stakeholder group supported the mandated EPR measure as it was stated that it will ensure compliance with the requirements set across MS, increase the effectiveness of the eco-modulation fee and enhance the research and development of new preparation for recycling and recycling technologies in Europe. Industry stakeholders outlined that different EPR systems across the EU would struggle to drive economies of scale needed for developing recycling capacities to support increased uptake in textiles 108 .

Regarding the expected economic impacts of an EPR mandate stakeholders underlined the substantial recurring fees105  which one interviewee considered to be a potential obstacle for Eastern European Member States some of which may be unable to meet the set objectives on affordability reasons 109 . Additional costs may occur from data collection and validation as well as from adaptation to new labels 110 .

Furthermore, it was highlighted that measure 2.9 in combination with ESPR and other high-priority measures can enable price reductions for recycled textiles and other secondary raw materials which would create a competitive market for them. By extension and due to ESPR performance targets such materials will be rendered more accessible to recyclers brands retailers and consumers as with cost savings both the demand and supply of recycled fibres will increase. Specifically, on an EPR mandate across the EU a stakeholder group stated that the framework would reduce the operational costs of producers associated with different reporting systems on products placed on the market and the fee structure110. Because of that the EPR should focus on establishing a harmonised reporting format and on strengthening EU-wide collaboration between PROs to secure the alignment of such systems throughout Member States.110

The design of the EPR measure should also consider how to avoid competition between the reuse and preparing for reuse sectors. Lastly a key impact area of the mandated EPR measure is the climate. Stakeholders realise the significance of the role of EPR to keep in line with climate objectives however they note that more circular business models (such as repair reuse remanufacturing and rental) should accompany the scheme to improve its effectiveness and efficiency104. The EPR mandate in combination with circular business models will additionally support sorting and recycling initiatives and further minimise waste generation and unsuitable waste management practices110 106.

Table 23 : Summary of impacts for measure 2.9

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 24 - impacts on competitiveness of measure 2.9

Measure 2.14 – Setting reporting obligations for textiles

Assessment of impact Measure 2.14

Economic impacts

The adjustments to existing reporting mechanisms would ensure that the entire management process of textiles within the EU is better understood at present and in the future to improve the ability to identify infrastructure investment needs more easily. Whilst data on the post-consumer fraction of textiles would be subject to an improvement by eliminating reporting on textile wastes that are not related to the waste fraction of concern under this initiative – removing textile packaging reporting from the scope of textiles - the most significant change would be achieved for the data on pre-consumer, post-commercial and post-industrial wastes for which little information is available at the level of granularity necessary to monitor waste management practices at national and EU levels, their compliance with the waste hierarchy and waste management planning. For these waste generation sources, the data would be most valuable to identify the recycling potential since the waste generated is expected to be of more homogeneous and known composition and consistency and purity in quality.

More cohesive data flow management would also reduce the burdens on the economic operators that operate across several Member States and improve the level playing field among them.

Given the limited cost of additional reporting foreseen (see the administrative burden assessment presented below) represents approximately 1 thousandth of one percent of the turnover for the clothing and apparel sector no noticeable additional cost increases in textile goods are likely to take place to address the additional costs of reporting.

Environmental impacts

No direct environmental impacts are expected as a result of the additional data collected. However, it is expected that an improved knowledge base on the sectors generating textile waste will lead to better targeted measures to improve their treatment in line with the waste hierarchy and the inherent environmental benefits it brings.

Social impacts

No social impacts have been identified in relation to this measure.

Administrative burden assessment

The WFD already lays down several obligations for Member States regarding the collection and reporting of waste data; therefore, the necessary data management systems are already in operation at national, regional and local levels. In the majority of the Member States, electronic data management systems are in use.

With regard to the adaptation of the reporting practices for the post-consumer textiles (i.e. those subject to measure 2.9 and defined in accordance with the approach in measure 1.1.1.2), the expected administrative burden is no or low cost, because the data is largely already collected and reported and changes would concern small scope adjustments, inclusion of certain operations that are currently voluntary, but concern data that would already exist with the economic operators.

In relation to data on pre-consumer, post-industrial and post-commercial textiles wastes, data collection and verification will require more significant adaptations from the current system used for reporting under the Waste Statistics regulation to a system that ensures textile specific data collection from the economic operators as well as data on waste management operations across the end-of-life chain and ensure traceability from the point of waste generation to its final treatment to attribute waste performance to specific Member States and enable monitoring to underpin possible future waste management target setting. The data collection processes should build on the existing ones applied for compliance with the Waste Statistics Regulation and in that process also improve the quality of data reported under that instrument.

The obligation entails data collection and verification by member States and reporting to the European Commission. Waste management operators will be required to generate and report data to competent authorities, as a minimum on the following: waste generated in tonnes, separate collection in tonnes, sorted in tonnes, prepared for reuse in tonnes, recycled in tonnes, energy recovery in tonnes, other recovery in tonnes, disposal in tonnes.

It is expected that in relation to existing waste management operators at the commercial level, the additional data to be reported would already be collected by:

-commercial collectors of waste for which volumes of waste generated and separately collected will already be recorded for contractual purposes between the producer and collector.

-commercial recyclers, where they differ from waste collectors, once again for contractual purposes between those who deliver waste for recycling and those who recycle it.

-the amounts sent for energy recovery and disposal will be collected at the point of recovery or disposal.

The elements missing are in relation to the volumes sorted and the volumes prepared for reuse. It is expected that for a large proportion of these wastes recycling rather than reuse will be the waste management operation of choice as these wastes are more suitable for recycling than reuse. Consequently, the biggest data gap will be in relation to volumes that are sorted for which additional data would be required to be gathered by those performing sorting prior to further treatment or re-use. This information should be readily available or generated by sorters based on the amounts entering a facility, sorted materials in bales for re-use and preparation for re-use and other fractions that are sorted for recycling, energy recovery or disposal.

In 2020, the last year of reported data, there were around 20 000 enterprises involved in waste collection in the EU and 7 700 involved in waste treatment and disposal 111 . However, only a proportion of those enterprises are likely to serve those producers involved in pre-consumer, post-industrial and post-commercial textiles wastes, particularly as such wastes represent just under 1 million tonnes of waste generated in comparison to 171 million tonnes of waste generated in the manufacturing sector overall 112 . A conservative estimate of 5% of all such enterprises handling textiles has been applied to assume that 1 385 waste management operators would be required to generate data each year.

Assuming the time taken for reporting of three days per year the total administrative burden would stand at just under €750 000 per year or approximately €540 per operator.

Finally, an additional 0.5 FTE would be required within the European Commission to adopt the necessary implementing acts setting out reporting formats and issuing guidance to the Member States (ESTAT) in support of those. Additional resources will also be required for the data flow management for all waste textiles (ESTAT).

Impact on SMEs and social enterprises

Given the majority of those involved as producers are SMEs they would tend to be impacted by the provisions to a larger extent than non-SMEs. However, the reporting obligations have been targeted to build on already existing obligations to minimise the additional administrative burden impacts that would result. Compliance costs for social enterprises linked to reporting obligations on waste collected and further treated would partially be new, since waste related reporting would already be a national obligation linked to waste permits that they generally have, but it is expected that the generation of the required data already takes place and would be offset by the reduction of costs in the management of residual waste in accordance with measure 2.9.

Stakeholder evidence

In both stakeholder workshops, industry, NGO and Member State stakeholders recognised that improved knowledge base across the end-of-life value chain is a significant barrier to improved waste management of used textiles and textile waste. Improvements in the reported data nationally and at EU level would address the need for more transparent data to allow for measurement of the environmental impact of the textile industry. This would need to be cross-boundary, with shared definitions, standardised indicators and reporting procedures, as well as accountability requirements 113 114 . If measured and tracked properly and consistently across the EU, the data would allow monitoring of the performance on waste prevention and residual waste and available feedstocks for developing preparation for re-use and recycling infrastructure 115 . Concerns were also raised over the cost implications and the added value of the more granular data on textiles in terms of environmental benefits.

Table 25 : Summary of impacts for measure 2.14

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this measure.

Table 26 - impacts on competitiveness of measure 2.14

Option 3: Prescribing performance targets

One of the advantages of using a target-based approach is that it is a top-down approach that aims to reach the same goal for all Member States thereby ensuring a level playing field whilst providing flexibility to Member States as to how the targets are achieved in practice thereby respecting the subsidiarity principle. This means that the measures implemented can be tailored to the specific challenges of each Member State. Different types of targets can be set to encourage improvement in different aspects of waste management. These include targets for waste generation separate collection for reuse preparation for reuse and recycling as well as a combined reuse and recycling one. These have been considered in this assessment.

The biggest challenge in relation to setting targets is to make sure that the targets themselves remain realistic. The problem definition explains the data challenges that exist and measure 2.14 describes how they could be resolved. However, even with the most ambitious of timetables, consistent data to enable the setting of targets would realistically only be available in 2031 after 2 to 3 sets of annual data are available based on improved reporting framework under measure 2.14. Waste management targets are generally set with waste generation data as the denominator and with a baseline figure at a given starting year against which progress could be prescribed and subsequently assessed. However, the current data on textile waste generation is not robust partly because of the fragmented understanding of whether what is collected is waste or not. There is currently no sound method of estimating textile waste (collected and discarded in mixed municipal waste).

Key missing data/information to set sound targets and other uncertainties

·Assessment of the robustness of the data on re-use of textiles to be reported to the Commission for the first time in mid-2023 under the WFD.

·Estimated apparent consumption and textile waste generated need to be fine-tuned to better assess the amounts of unsold and returned goods as well as those that are stored by consumers in their households (difference between apparent textile consumption and post-consumer waste) even though these numbers are likely to be relatively small (around 5%).

·Updated assessment of the implementation of separate collection systems in the Member States.

·Improved projections of future capacities for recycling plants based on realistic capacity growth rates.

·Assessment to better understand the economic feasibility for recycling plants.

·Stakeholder feedback.

As explained in Annex 10, the JRC is working on a feasibility assessment for setting future recycling targets and their work is planned for conclusion by the end of 2023.

Setting targets based on non-robust data is risky because the levels set could be unrealistic and threaten the Member States’ commitment to achieve them. Indeed, the commitment from Member States is an additional challenge as such. There are several examples when targets set under EU law have proven to be challenging to achieve, for example, those related to the objectives of the Water Framework Directive, 116 the recycling targets in the WFD itself and the Air Quality Directives 117 . The assessments of the status quo have demonstrated the challenges in achieving targets sometimes due to a series of problem drivers.

Therefore, the sections below for measures 3.1, 3.4, 3.5, and 3.8 examine the feasibility of the mechanism by which a target could be set in the future and the impacts of that process and not the actual levels of targets. In relation to setting a target for collection, a more detailed assessment based on an interim low ambition target is presented. The setting of targets is likely to have a number of common impacts as outlined below.

Economic impacts

Setting targets would involve additional costs in those Member States that are below the targets set and where relevant measures are not already foreseen to achieve them. Such impacts would include investments that would have to come from public or private funding to address several elements:

1.Collection infrastructure.

2.Sorting infrastructure

3.Repair infrastructure to enable reuse

4.R&D to develop recycling technologies at industrial scale

5.Recycling infrastructure to enable greater levels of recycling

As noted under Measure 2.9, the maximum likely additional cost per item would be an increase in product costs of 0.6%. In countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then costs may be met via the likes of disposal fees applied at the point of disposal or general taxation. The spread of costs between producers and consumers would be defined at the Member State level.

At the same time, however, increased collection of textiles and the potential resulting increased reuse and recycling would result in positive economic impacts in relation to the materials reused and recycled driving investment in the waste management sector and the second-hand textiles market.

Environmental impacts

The setting of targets would result in reductions in the environmental impact of textiles that would otherwise be predicted to remain in residual waste and subsequently be disposed. This would reduce the environmental impacts that currently result from the disposal of textiles including GHG emissions and air pollution water pollution and soil and groundwater impacts including in relation to microplastics.

Social impacts

Additional collection would be expected to lead to additional employment in the collection and downstream sorting and further treatment of materials that would otherwise be disposed of. Furthermore, in relation to the social impacts of waste textiles in receiving environments targets would effectively lower these effects that is particularly important given the large proportion of EU used textiles exported to third countries where environmental controls are generally lower than those employed within the EU.

Impacts on competitiveness

The following impacts on competitiveness have been assessed under this group of measures qualitatively. It should be noted that actually quantifying these impacts is not possible except in relation to measure 3.6. This is as a result of the fact that no specific targets are proposed for the other target measures and the extent of the targets and the distance away from those targets would determine the majority of competitiveness impacts.

Table 27 - impacts on competitivenss of measure 3.1, 3.4, 3.5 and 3.8

Measure 3.1 – Setting an EU textile waste reduction target

The objective of this measure would be to drive Member States to reduce textile waste generated in the first place. In terms of implementation this could be achieved through measures addressing reduction of textile consumption for example through information campaigns for consumers or through specific support to the textile repair and reuse sectors. It would also look to improve the way Member States collect textiles for reuse as a way of reducing textile waste by diverting reusable that are currently disposed of.

Impact on SMEs and social enterprises

Most producers of textiles within the EU are SMEs as are most actors involved in collecting textiles that are mainly social enterprises. The separate collection obligation for textiles would at least in part be expected to be implemented by these enterprises in collaboration with Member States. As noted above with increasing collection the revenue from reuse and recycling is also likely to increase to partly offset the additional costs that will be required to implement the sorting requirements. The intention of the measure is to avoid disrupting the business model of social enterprises and with this in mind Member States should work alongside social enterprises to limit any such disruption in meeting this target. Therefore, a waste reduction target would be likely to fall mainly on SMEs to a certain extent on social enterprises. The precise impacts would be dependent upon the approaches employed by Member States to meet the targets concerned.

Stakeholder evidence

All stakeholders in both of the textile workshops agreed that there was a need to reduce the fraction of textiles in mixed household waste. However, it was suggested that, where an EPR is established, in its early stages targetsare not a priority and could be implemented later and – where applied – should focus on waste prevention and resource efficiency 118   119 . Some actors notably Member States classified the measure as not useful. The feedback outlined that the measures need to go beyond solely targets 120 to avoid the potential for divergent approaches taking place across Member States which could cause uncertainty and complexity and unnecessary costs to the economic operators 121 . There was sentiment that unless measures are mandatory they will not be implemented. The question was also raised of how the targets would be enforced in view of data uncertainty and the design of the EPR114.

In designing the targets there were questions in the second stakeholder workshop over whether this would be directed towards preventing the generation of textile waste through circular business models or by reducing what is placed on the market. There was also uncertainty over whether the targets are set at the national member state level or would require further reporting or independent initiatives and who would need to report as well as the processes for doing so. Comments from the workshop were that targets should be used to measure the overall flow of resources consumed and waste produced in the market while reducing the environmental footprint of textiles. There were questions on how this would be defined and agreement that this would need to be designed carefully to ensure it was clearly defined including whether it would be per kg per capita etc and would need to be supplemented by a reuse and recycling and consumption reduction targets and material consumption reduction targets 122 . This could be further incentivised through eco-modulation under EPR schemes and financial penalties for not meeting targets.

Waste reduction targets are difficult to operationalise. Some actors – such as commercial or C2C platforms – could be incentivised through regulation to monitor and report textile waste prevention. Overall, the targets were considered not strong enough to create the change required with participants suggesting investment in infrastructure that can allow for separate collection and adoption of circular business models (i.e. product use extension) is more critical.

Table 28 : Summary of impacts for measure 3.1

Measure 3.4 – Setting a preparation for reuse target for textiles

The objective of this measure would be to drive Member States to improve their reuse of textiles by setting a realistic preparation for reuse target in comparison to solely relying on the application of the separate collection of textiles under Article 11(1) of the WFD. Preparing for reuse in the context of textiles means checking, cleaning or repairing recovery operations by which textile products that have become waste are prepared so that they can be reused without any other pre-processing. Presently the costs of preparation for reuse within the EU generally mean that such preparation is limited as the economic costs of such preparation are higher than the value added to the repaired product. However, one of the expected impacts of the EU strategy for sustainable and circular textiles is to facilitate the reuse and repair sector such that repair within the EU becomes more profitable and a preparation for reuse target would be set with this expected outcome in mind.

Table 29 : Summary of impacts for measure 3.4

Measure 3.5 – Setting a reuse target

The objective of this measure would be to drive Member States to improve their reuse of textiles by setting an overall reuse target that they should achieve in comparison to a baseline. Reuse poses an additional challenge in terms of how to measure it. The World Economic Forum (WEF) recently examined the need for a robust and standardised framework for reuse measurement 123 . The WEF Consumers Beyond Waste initiative focussed most of its effort on primary plastic packaging. The two reuse metrics to be piloted in 2023 are less relevant for textiles as they focus on the total number of loops a packaging unit achieves over the course of its lifetime as well as the share of volume of products designed or developed to be reused. Specifically in relation to textiles Finland through the Finnish Environmental Institute collected data on C2C and B2C reuse volumes of textiles. The data is collected through a survey sent to online and physical second-hand shops. Finland also uses a consumer barometer to provide insights into consumer behaviour concerning reuse. Further approaches are also developed in Flanders and Ireland. 124

In accordance with Commission Implementing Decision (EU (European Union)) 2021/19 on reuse, the EEA is piloting a strategy for reporting on reuse by developing an online reporting tool, that will be available in April 2023. By combining quantitative and qualitative data the reported data on reuse will improve the understanding of the reuse sector and the impacts of the measures that the Member States have taken on waste prevention. Member States have developed different methods to collect the quantitative data on reuse flows. It is therefore necessary to await the analysis of the data submitted by Member States in accordance with this reporting obligation to determine the scope for further improvement of data on re-use of textiles and the feasibility of setting re-use targets at EU level.

Stakeholder evidence

During the discussions concerning Commission Implementing Decision (EU (European Union)) 2021/19 on reuse and development of the decision a main concern from the Member states were the administrative work that it may take to collect and report data on reuse. It was decided that in order to monitor reuse and to gain a better understanding of the reuse sector the reporting should include a combination of qualitative and quantitative data. The quantitative data should be reported every third year and the qualitative data annually.

Participants to the second textile stakeholder workshop agreed that there is not enough data to be able to set a definitive baseline and robust targets at the moment. Therefore, setting a reuse target cannot be considered at this point 125 . Additionally, stakeholders were concerned that as there is not yet the capacity for reuse systems to deliver at volume the market isn’t ready to respond to reuse targets. Feedback from the workshop outlined that the development of reuse targets should be done in consultation with industry experts and progressively increased over time as the infrastructure and data permits. This would allow for Member States and market demand (boosted by ESPR measures) / capacity to expand symbiotically in keeping with the aims of the EU strategy for sustainable and circular textiles in relation to profitable reuse and repair services. Collaboration with industry and Member States would also ensure that targets are reasonable, and stakeholders advocated for targets not to be set below what is already being achieved in some states. Importantly as with most measures harmonisation of monitoring and reporting is vital. However, stakeholders noted that this could be challenging as reused textiles are not considered waste therefore language and terminology would need to be reflected accurately in these. It was suggested that reuse targets should be developed in line with prepare-to-reuse targets but only focusing on waste and donations (excluding C2C platforms). Some feedback states that reuse targets are not practical or feasible and targets should be focused on prevention because even with better reuse and recycling issues like fast fashion are not being addressed and we should always be aiming for moving up the waste hierarchy.

Preparation for reuse targets were seen as an option which could form part of the EPR with a recycling target on the fraction that would not be prepared for reuse (remaining fraction 126 .) An example of this in action is the Netherlands that uses a combination of targets relating to preparation for reuse and recycling and allow producers to choose 127 .. Separate reuse and recycling targets would be required to ensure everything doesn’t end up being recycled for instance design for recycling. Reuse should only be considered if it takes place within Europe due to lack of end-of-life information for exports out with the area. Additional measures would also need to be in place to ensure preparation leads to reuse. This would also drive the reuse market within the EU boundaries 128 . Another option when developing the target could be to consider the textiles that currently end up in municipal waste to increase the amount of material entering preparation for reuse and decreasing household waste 129 . Where respondents agreed with the targets there was still caution against setting a target straight away. Due to other legislative changes – namely the 2025 textiles collection obligation – there will be a significant increase in collection of non-reusable fractions of textile which will make it non-feasible to significantly increase prepare-for-reuse in the first few years. There is also a lack of harmonised data for collection rates which would be necessary to provide a reporting framework and baseline 130 .

Like other target-based measures stakeholder mentioned potential challenges in measurement and enforcement. There were questions raised around who would measure the data and how it could be collected. It was felt that prevention was an easier metric to measure as this can be monitored by amounts POM 131 . There were some interviewees who felt the measure was relevant and useful 132   133 . It was suggested the preparation-for-reuse would be better suited as a KPI which would take into account social aspects of the production process 134 . It was felt that if measured and tracked properly the measure could support the reduction of textiles ending up in landfills or incineration and increase those used as feedstocks; however, this would depend on them being collected and sorted efficiently which could improve the recycling infrastructure.

An interviewee expressed that they did not see the purpose of a target as the market is self-regulating. As reuse operators and sorters will seek to make the maximum value from materials the commercial process will automatically drive the preparation for reuse element 135 . Currently, collection and sorting are financed by reuse and only around 10% of what is collected can be resold in the EU as the market requires a higher quality than elsewhere. As the process of sorting is labour intensive the costs for this increase every year but the quality decreases. There is therefore a significant cost implication for this which – if not supported through a wider EPR or national system – will fall to the businesses. This will further drive down the volume of textiles able to be reused. Stakeholders highlighted that to ensure textile reuse there must be a high-level of reusable items or demand for recycling which is economically feasible 136 .

Table 30 : Summary of impacts for measure 3.5

Measure 3.6 – Setting a separate collection target for textile waste

The apparent lack of sufficient collection infrastructure to manage the expected volumes of textile waste generated hampers the ability further down the textile management process to ensure that textiles that could be reused or recycled are diverted from residual waste. On the other hand, the uncertainty of the available reuse possibilities and the immaturity of several recycling technologies tend to dis-incentives Member States from speeding up the setting up of efficient separate collection systems.

Economic impacts

Setting a 50% separate collection target would involve additional costs only for those Member States and producer responsibility organisations (PROs) that are unlikely to meet a 50% collection target by 2035. The list of Member States concerned and the likely shortfall in tonnes is presented below.

Table 31 - Additional tonnes to be collected to achieve a 50% collection target

The costs of collection are dependent on the type of additional infrastructure that would be required. In keeping with most collection being achieved by separate bins, it is considered that shortfalls in separate collection would be met by adding additional separate collection bins for the Member States concerned.

This measure would also have a benefit in reducing disposal of textiles in the household mixed waste. Treatment of mixed waste is more expensive that treatment of separately collected waste. This benefit would be apparent to those responsible for municipal waste collection, typically municipalities. In cases where the polluter pays principle is applicable, i.e., where households pay (or may more) for their mixed waste than for separately collected waste, this saving would be directly apparent to households. It was not possible to quantify this benefit as the applications of the polluter pays principle is not applied by all municipalities and where it is, it is implemented in a variety of ways, by weight, by volume, by collection, by bag etc.

Data from the CESME project that considered the Humanita textile recycling programme in BG 137 indicates that addressing approximately 3 400 tonnes of textile per year came with combined container transport and storing costs of 367 000 euro per year leading to an average cost of 108 euro per tonne collected. This figure appears low in comparison to data from the ECAP study on used textile collection in European Cities 138 that indicates costs of collection in the NL of 165 euro per tonne. In applying these costs to the Member States above would lead to the following additional annual collection and onward sorting and treating costs:

Table 32 - Additional costs to achieve a 50% collection target

The additional collection and sorting costs remain relatively low at 39.2 million euro. This reflects both the predicted distance to 50% collection by 2035 where most Member States would be close to that target already as well as the scale of textile waste generation where the countries listed are generally smaller generators of textile waste in comparison to DE or FR that would already be collecting over the 50% target by 2035 (and in the case of DE is already collecting beyond that target). In countries where EPR applies or is planned to apply then the costs would fall on the producer. Producers would either have to absorb those costs that would lower their profitability or increase the costs to consumers of the products themselves. Where EPR is not applied then the costs of additional collection and sorting may be met via the likes of disposal fees applied at the point of disposal or general taxation. The extent of these additional costs is difficult to determine. As noted in Annex 4, the total costs for all wastes account for an approximate increase per product of around 0.6%. However, as the additional volumes listed above that fall above the baseline are lower (in some cases up to 7.5% more at a Member State level in comparison to the baseline) then maximum increase would be 7.5% of the 0.6% maximum i.e. 0.045%. Consequently, were the additional costs of collection, sorting and treatment to be applied for the additional volumes only and the cost spread over all relevant textile products sold in total then a very conservative estimate would place those costs at an additional cost of 0.1% in the countries concerned by requiring additional action to meet the target. The extent to which these costs may be absorbed by producers or consumers is not possible to be separated and will rely on decisions at the Member State level.

At the same time there would be benefits from the materials recovered. The baseline assumes that 42% of what is separately collected would either be close-loop or open loop recycled representing 18 250 tonnes additionally going to closed loop recycling and 7 150 tonnes going to open loop recycling. Using values from Fashion for Good 139 an additional ~30 200 tonnes of reusable textiles collected would have a value of 23 million euro per year and the additional recyclable material a value of 5 million euro per year. Only 8% of separately collected waste would be disposed 140 .

Additional costs would be expected for competent authorities to enforce compliance with a collection target. However, the activities that are required to contribute to the target are already required to be managed by competent authorities under existing waste permitting requirements for collection, sorting and treatment facilities; therefore, allowing for synergies with the existing enforcement processes. Furthermore, given the relatively modest increases in tonnes to be collected by the Member States concerned as a maximum such costs would incur a 15% increase in total in comparison to the baseline for those Member States furthest from the 50% target i.e. LV, SI and SK, with lower total cost increases expected for the other Member States that are predicted to be closer to the 50% target. The additional reporting costs under this measure are addressed under Measure 2.14. In case the reporting would be through PROs, the administrative burden would be even lower given that PROs would need to report the required data to assess the separate collection target anyway. There would also be no additional administrative burden on Member States.

However, as shown in Annex 10, the heterogeneity of predicted separate collection rates across different studies may make it challenging to set a specific target at this stage and should therefore be carefully considered.

Environmental impacts

The additional collection rate that would be applied to the Member States concerned to hit a 50% separate collection target is likely to reduce the environmental impact of textiles that would otherwise remain in residual waste and subsequently be disposed. This would reduce the environmental impacts that currently result from the disposal of textiles including GHG emissions and air pollution, water pollution and soil and groundwater impacts including in relation to microplastics.

Social impacts

Additional collection would be expected to lead to additional employment in the collection and downstream sorting and further treatment of materials that would otherwise be disposed of.

Impact on SMEs and social enterprises

Given the majority of those currently involved in collecting textiles are SMEs, mainly social enterprises, the obligation to collect textiles is expected to fall at least on these enterprises in collaboration with Member States. As noted above, with increasing collection the revenue from reuse and recycling is also likely to increase to offset the additional costs that will be required to implement the sorting requirements. The intention of the measure is to avoid disrupting the business model of social enterprises and with this in mind Member States should work alongside social enterprises to limit any such disruption in meeting this target.

An additional 0.2 FTE would be required within the European Commission to adopt the necessary implementing act setting out harmonised methodology for the measurement of the collection performance by the Member States.

Administrative burden assessment

In order to inform the target and compliance with the target data would be required to be complied and reported at the Member State level in relation to those wastes or products forming both the numerator and denominator. These requirements would fall on all Member States and not just those for which additional collection would be required to be implemented above the baseline. The full costs of this burden are addressed in Measure 2.14.

Impacts on competitiveness

The following impacts on competitiveness have been identified under this measure:

Stakeholder evidence

The consensus was that increasing collection is only useful to the extent that there is available infrastructure to manage those quantities. Typically, as this will lead to an increase in material flows and end of life considerations, there must be sufficient collection and sorting in place to manage this and where targets are implemented, these need to be carefully designed and possibly phased in 141 . It was suggested at the second stakeholder workshop that separate targets for household and commercial waste should be outlined in the WFD and there was general agreement that targets should be aligned with the waste hierarchy.

Table 33 : Summary of impacts for measure 3.6

Measure 3.8 – Setting a recycling target for textiles

The objective of this measure would be to drive Member States to improve their recycling of textiles and thereby increase recycling capacity by setting a realistic recycling target that takes into account likely changes in recycling capacity and technologies – see for example the ReHubs initiative that looks to achieve 2.5 million tonnes of fibre-to-fibre recycling by 2030. This target would be in comparison to solely relying on the application of the separate collection of textiles under Article 11(1) of the WFD to provide more textiles available for recycling.

Taking inspiration from the way FR and NL have set combined targets for reuse and recycling the objective of this measure would be to drive Member States to improve both their reuse of textiles and their recycling of textiles by setting a realistic combined target. This would avoid the undesired effect of a recycling target where textiles that could be treated further up the waste hierarchy would be sent to recycling to achieve the target. This would also offer some flexibility to Member States to achieve the combined target in the way that is more appropriate based on the size and prospects of the reuse market as well as the availability of recycling facilities.

Stakeholder evidence

The apparel and footwear industry 142 considers that any recycling target should be set in consultation with the industry experts and that the targets should be progressively increased over time in line with the development of relevant infrastructure in the Member States and the market demand for secondary raw materials. National and regional public waste organisations echoed the need to align the targets to relevant infrastructure. 143

Social enterprises active in reuse, repair and recycling as well as MWE and the Swedish environmental agency 144 emphasised the need to prioritise reuse over recycling in keeping with the waste hierarchy and that this needs to be considered in the setting of recycling targets that may otherwise result in reusable materials being sent for recycling. A recycler supports mandatory targets on recycling and recycled content at the EU level to both boost demand and supply for recycling. 145

In addition, during the second textiles workshop, stakeholders called for recycling targets being established which – supported by clarity and consistency – would help create a market for secondary material and facilitate collection and prioritised use 146 .

Table 34 : Summary of impacts for measure 3.8

Overall impacts of the measures

For textiles, the table below summarises the net impacts of the measures that are included in each option. For each measure, the direction of impact is indicated as positive, negative or neutral using + - and +/- to indicate these impacts. Additionally, where indirect impacts are identified these are shown between brackets, e.g. (+) would demonstrate an indirect positive impact. The table below sets out the economic, environmental and social impacts by measure covering all relevant stakeholders: public authorities, industry (including SMEs), citizens and workers and third countries. For those measures that contained alternatives, the table presents the ratings for the selected alternatives within each measure.

Table 35 : Overview of the economic environmental and social impacts of the measures

Table 36 : Overview of the costs and benefits and overall balance of the measures

2.Food waste 147

This Annex presents results of the MAGNET model and other analysis for the options setting legally binding food waste reduction targets (Option 1 to Option 3). As regards Option 4, it is not possible to assign specific reduction level (but only a range of reduction), therefore the MAGNET model was not run for this option and therefore not included in this Annex. As the impacts for Option 4 are expected to be in the range between the Baseline (2030) and Option 1, its impacts are described (in the main document) by reference to impacts from these options.

2.1.Impact of reduction scenarios on food waste quantities

The reduction of food waste increases with a broader coverage of the food supply chain and increased target levels. Figure 1  depicts the baseline food waste numbers in 2020 and 2030 and compares it with the three main scenarios: Option 1, Option 2 and Option 3. Option 1 leads to an estimated reduction of food waste of around 7 000 ktons, while the expected food waste reductions are around 13 000 ktons for Option 2 and around 23 500 ktons for Option 3.  

Figure 1 – Total EU27 food waste quantities in the baselines and the three options

Source: MAGNET simulation results (2020 baseline based on ESTAT 2022)

The ambitious food waste reduction in Option 3 can be traced back to the high reduction target rates (50%) at the household level as most food waste occurs at this stage. On the other hand, an increased reduction of food waste in the other main segments of the food supply chain under all three options, has more limited impact compared to the consumption segment ( Figure 2 ). This is due to the smaller share of total food waste attributed to upstream stages of the food supply chain. For instance, Option 3 leads to an estimated food waste reduction of nearly 17 000 ktons at the household level, while the expected decrease at the retail and distribution level only amounts to 2 400 ktons of food waste.

Figure 2 – Deviations in EU27 food waste quantities at the industry and consumption stage, Options vs baseline 2030

Source: MAGNET simulation results

Per food commodity group, the largest food waste reductions are expected to happen in sectors where food waste generation is the highest. Vegetables and fruits constitute over 40% of food waste by households with the result that household waste reductions fall commensurately in these sectors. Hence, Option 3 results in food waste reduction by more than 3 000 ktons for vegetables and more than 2 500 ktons for fruits ( Figure 3 ). Households’ out-of-home consumption of food waste is depicted by the food service sector as a whole, and the food waste reductions at this level is also significant (over 3 500 ktons in Option 3). Other food sector comprises mostly packaged and prepared food, where noteworthy reductions are also expected.

Figure 3 – Change deviations in household food waste quantities per commodity group for EU27 options vs baseline 2030

Source: MAGNET simulation results

2.2.Environmental impacts 

2.2.1.MAGNET model 

2.2.1.1.Emissions

The results show that savings in amounts of food waste at any stage of food supply chain have a significant positive environmental impact on emissions both within the EU and globally. As explained in the methodological chapters, it is assumed that reduced household food expenditures result in rising non-food expenditures (savings rates are assumed fixed across all options) such that there is an increase in emissions from other economic activities ( Figure 4 ). 

Figure 4 – Absolute deviation of direct emissions in the EU27 (mt CO2 equivalent) options vs baseline 2030

Source: MAGNET simulation results

Figure 5 depicts absolute deviations of direct emissions associated with agri-food for the EU and non-EU. In connection with food waste reduction in the EU, a decrease in direct emissions in the rest of the world is also expected, resulting from the EU’s reduced agri-food import demand in particular.

Figure 5–Absolute deviation of direct emissions associated with agri-food (mt CO2 equivalent) options vs baseline 2030

Source: MAGNET simulation results

It should be noted that the modelling does not take into account other policy constraints, such as the national greenhouse gas emissions reduction targets established in the EU. In reality the rebound effect may actually translate in the need to take less measures in other sectors to achieve the agreed GHG reduction targets, reducing overall mitigation costs in the economy with the same environmental effect

2.2.1.2.Land use

Food waste reduction options in general lead to slight decreases in land use driven by changes in demand and production. The highest decrease (by hectare) is expected to occur in pastureland, with a decrease of 500 000 hectares in Option 3 ( Figure 6 ). However, this e only corresponds a decrease of up to 0.77% ( Figure 7 ). Although limited, the highest percentage change in land demand is expected in the vegetables sector as a result of decreasing demand and production in this sector.

Figure 6: Absolute deviation in land use in the EU (thousand hectares) options vs baseline 2030

Source: MAGNET simulation results

Figure 7: Deviation in land use in the EU (% change) options vs baseline 2030 (baseline in 2020 =100)

Source: MAGNET simulation results

2.2.1.3.Footprints (consumption, households)

This section shows the environmental impacts of different food waste reduction targets using household food demand-driven footprints of land, emissions and energy, which measure the intensity of land use (i.e., emission and energy use associated with food consumption).

Figure 8 , Figure 10 and Figure 12  show the development of the land (m²), emission (kg CO2 equivalents) and energy footprints (mega joules, MJ) per capita per year in the baseline for the years 2020 and 2030. Whereas,  Figure 9 5, Figure 11 and Figure 13 show the land, emission and energy savings due to the reduction of waste by comparing the footprints of the scenarios with the footprints in the baseline in 2030.

While the land footprint of the EU27 is already lower than world average in 2020, Figure 8 shows that the land footprint across Member States significantly differs but decreases for all Member States from 2020 to 2030.

Figure 8: Land footprint associated with household food consumption (m² per capita per year) – baseline 2020 and 2030

Source: MAGNET simulation results

Food waste reduction in the EU leads to a reduction of the land footprint associated with household food consumptions of the EU and of all Member States, while it leads to an increase of the land footprint in non-EU regions. As the impact on the non-EU region is very small, the world land footprint tends to decrease in 2030 compared to the baseline. The magnitude of these land use savings increases with an increase in the food waste reduction targets, thus scenario Option 1 leads to the smallest savings, while scenario Option 3 leads to the highest savings. The extent of these savings largely differs across Member States- between 2% and 5% in Option 3.

Figure 9: Land footprint associated with household food consumption (m² per capita per year) – savings, options vs baseline 2030

Source: MAGNET simulation results

By contrast to the land footprint, the emission footprint of the EU is higher than the world average in the baseline in 2020. Figure 10 also shows significant differences across Member States. While the emission footprint of the EU decreases from 2020 to 2030, the development of the Member States’ footprints is mixed. The emission footprint tends to decrease less in the EU-13 Member States 148 and even increases in Member States that showed the highest footprints in 2020.

Figure 10: Emission footprint associated with household food consumption (kg CO2 equivalent per capita per year) –baseline 2020 and 2030

Source: MAGNET simulation results

In line with the findings related to the land footprint, the emission footprint of the EU and of all Member States also decreases when reducing food waste, with the highest effects observed in the scenario “Option 3”. However, the extent largely differs across Member States and varies between around 3% to 5% in emission savings.

Figure 11: Emission footprint associated with household food consumption (kg CO2 equivalent per capita per year) – savings per options vs baseline 2030

Source: MAGNET simulation results

Also, the energy footprint of the EU is higher than the world average in the baseline in 2020 and Figure 12 shows significant differences across Member States. While the energy footprint of the EU decreases only minimally from 2020 to 2030, the development of the Member States’ footprints is mixed. The energy footprint tends to increase or remain unchanged in many EU Member States; only very few Member States show a decrease in their footprint.

Figure 12: Energy footprint associated with household food consumption (MJ per capita per year) – baseline 2020 and 2030

Source: MAGNET simulation results

Figure 13 shows that food waste reduction leads to savings with regard to energy use in household food consumption, with the highest reduction of the energy footprint observed in “Option 3”. Member States save around 3-5% of energy related to household food consumption in the most ambitious scenario.

Figure 13: Energy footprint associated with household food consumption (MJ per capita per year) – savings per options vs baseline 2030

Source: MAGNET simulation results

2.2.1.4.Virtual trade – systemic view 

The footprints presented in the previous section consider emissions and land use associated with household food consumption in the EU, hence accounting for the quantity of the virtual (i.e., non-tradable) commodity embedded within imported and domestic EU final food consumption. The underlying virtual flows and their concomitant cross-boundary trade impacts are presented in the figures below.

Figure 14 shows that the EU is a net-emission importing region that is represented by the negative trade balances for both livestock and food. In other words, EU consumers generate emissions ‘leakage’ through their food consumption patterns. However, the negative trade balance for food is much larger than for livestock. Virtual emission trade related to food is in general larger than for crops and livestock, particularly as livestock is not traded much and all meat and dairy trade is included in food. In addition, virtual emission trade related to food is unbalanced as virtual exports only account for around two thirds of virtual imports, while virtual emission trade related to crops is rather balanced.

Figure 14: EU virtual emission trade flows (mt CO2 equivalents) in the baseline 2030

Source: MAGNET simulation results

Reductions in food waste lead to reductions in virtual emissions imports and exports associated with livestock and food trade. The extent to which virtual emissions imports are reduced significantly outweighs the impact on virtual emissions exports, so that the virtual emissions trade balance improves. Virtual emission exports associated with trade in crops tend to increase while virtual imports decrease, hence also improving the virtual emission trade balance. However, the impact of the reduction in food waste on virtual emissions trade is rather small so that the net position as a net emissions import region tends to improve only slightly. The more ambitious the food waste reduction target, the larger the effect is on the trade balance ( Figure 15 ).

Figure 15: Absolute deviation of EU virtual emission trade flows (mt CO2 equivalents) options vs baseline 2030

Source: MAGNET simulation results

Figure 16 shows that the EU is a net-importing region with regard to the virtual trade of land, with the largest negative trade balance associated with the trade of food and food services.

Figure 16: EU virtual land trade flows (million hectares) in the baseline 2030

Source: MAGNET simulation results

The virtual land trade balance also improves with the reduction of food waste, revealing the smallest changes with regard to crops followed by livestock and food. By contrast to virtual emission trade, virtual exports of land tend to increase for all commodity groups, while virtual land imports tend to decrease. As the effect on virtual land imports clearly outweighs the effect on virtual land imports, the virtual land trade balance improves for all three commodity aggregates. Figure 17 also supports the previous statement that the more ambitious the food waste reduction target, the larger are the effects on virtual land trade.

Figure 17: Absolute deviation of EU virtual land trade flows (thousand hectares) options vs baseline 2030

Source: MAGNET simulation results

2.2.2.Bottom-up analysis

This chapter presents the results of a complementary modelling approach that was applied to the analysis of food waste prevention targets in order to support the policy impact assessment. The approach relies on the application of the Life Cycle Assessment (LCA) method, which allows assessing the environmental impacts of food and food waste by modelling individual food products in their entire life cycle (from agriculture production to food waste management). In this way the environmental benefits deriving from the application of food waste reduction targets are estimated, based on the quantities of food waste avoided in the different policy options and on the environmental impacts of representative food products of the modelled food groups assessed in the Consumption Footprint, (EC - European Commission, 2022; Sala and Sanye Mengual, 2022). Details of the methodology are provided in Annex 4.

Table 37  shows the environmental impacts caused by food waste generation in the baseline, while the avoided environmental impacts (and relative monetised values) for the EU27 obtained as a consequence of food waste reduction targets set in the three policy options are displayed in Table 38  and Figure 18  for four selected environmental impact categories.

Table 37- Environmental impacts of food waste in the baseline used for the impact assessment

Table 38 - Overview of results on environmental savings associated to the policy options and their equivalent estimated monetary values

Figure 18  shows the relative reductions for the impact on climate change achieved with the three policy options. Similar results can be observed for the other impact categories.

Figure 18: Relative differences in climate change impact between the three policy options.

Considering the various steps of the supply chain,  Figure 19  shows the contribution of primary production, processing and manufacturing, retail and distribution and consumption phases in the reduction of climate change impact under the three policy options. The consumption phase has a major role in the overall avoided impact, due to the fact that the largest share of food waste is generated at this stage, and that, in a life cycle perspective, the products reaching the consumer have higher impacts than earlier in the supply chain as the impacts cumulate along the supply chain.

Figure 19: Avoided climate change impact obtained with the three policy options considering the various steps of the supply chain.

Figure 20 and Figure 21  show the contribution of avoided waste treatment and avoided food production in the total environmental savings that can be achieved applying the various policy options. Avoided food production plays a bigger role for all the impact categories but, in the case of climate change, the contribution of waste treatment is slightly higher than for the other impact categories.

Figure 20: Avoided climate change impact due to food production and waste treatment in the three policy options

Figure 21: Avoided impact on water use due to food production and waste treatment in the various policy option

The climate change impacts avoided in each Member State under the third policy option are shown in  Figure 22 . The highest impacts are in Germany, France and Italy, which are also the countries with the biggest amounts of food waste and biggest population.

Figure 22: Avoided climate change impact in the Member States with option 3

2.2.3.Comparison of the two approaches

Environmental impacts presented in this section are calculated with two different approaches: the MAGNET model (section 4), providing impacts in terms of emissions and land use, and the bottom-up analysis (Section 5), which uses the metrics proposed by the Environmental Footprint method (EC - European Commission, 2021). The common metric used by both approaches are greenhouse gas emissions (expressed as kgCO2eq) and therefore a comparison between the two approaches could be performed for this impact category. 

Differences between the two approaches are significant and reflect the different methodological basis. In the case of the bottom-up approach, the avoided environmental impacts are calculated considering that a reduction of food waste brings benefits linked to: (i) the avoided impact of producing and distributing the food items saved up to the point of the FSC where the food waste is avoided and (ii) the avoided impact of the food waste disposal following the approach presented in (De Laurentiis et al., 2020). The assessment is entirely based on biophysical flows and assumes a linear relation between the amount of reduced food waste and reduced environmental impacts.

Figure 23  shows the potential climate change reductions due to food waste reduction targets assessed with the bottom-up approach in the context of the overall climate change impact due to the EU-27 economy (3298 Mt CO2 eq.), as reported by EEA (2020). The contribution of the EU food system is estimated as one third of the total when considering a production-based emissions (territorial approach) (Crippa et al., 2021). This share is higher when considering the emissions embodied in the imported goods with the Consumption Footprint (CF) approach (around a half of the total), which estimates the impact of food consumption as 1577 Mt CO2 eq. Climate change impact of food waste in 2020 (based on reported food waste quantities, ESTAT (2022) is quantified as 246 Mt CO2 eq. (16% of the impact of food systems) and 244 Mt CO2 eq. in 2030 (based on projections of food waste derived applying the production changes used in MAGNET).  The emissions reductions obtained with the three policy options range between 33 and 108 Mt CO2 eq. These values do not include possible rebound effects, which are instead captured in MAGNET and that seem to contribute substantially to offsetting the environmental benefits of these policy measures.

Figure 23:

Reductions in climate change impact due to the application of food waste targets, in the context of the global impact of the EU 27 system and the impact due to food systems. All amounts are million tonnes of CO2 eq.

151 152  Notes. (*) excluding Land Use, Land Use Change and Forestry (LULUCF) and international aviation and international maritime transport (EEA, 2022); (**) EDGAR is the Emissions Database for Global Atmospheric Research developed by the JRC (Crippa et al., 2021); (***) The Consumption Footprint (CF) approach is based on the calculation of impact at product level and considering the full life cycle of products (Sanyé-Mengual and Sala, 2023).

Source: Author’s own elaboration based on data from (EEA (2022), Crippa et al., (2021), Sanyé-Mengual and Sala (2023), ESTAT (2022), bottom-up approach

In the case of the MAGNET model, the emissions reductions are calculated within an (economic) general equilibrium model approach which takes into account market dynamics and interrelations between different economic sectors., Similar to the results of the bottom-up analysis, though based on different assumptions, food waste reductions at all stages of the food supply chain have a significant positive environmental impact on emission savings, both within the EU and globally.

The so-called rebound effect arises when reduced household food expenditures result in rising non-food expenditures (savings rates are assumed fixed across all scenarios) such that there is an increase in emissions from other non-food economic activities. As shown, the larger is the final demand redistribution effect resulting from higher household waste reductions, then the larger is the rise in emissions in non-food and waste management/treatment activities. 

Therefore, depending on the spatial and sectorial coverage as well as calculation method, results are diverging (see sections 4.3.4.1 and 4.3.4.3).

Figure 80 shows the range of emission reductions in the scenarios (from Option 1 to Option 3). On the left-hand side, the reductions of the aggregated emission footprint associated with household food consumption for the EU are depicted (in Mio CO2eq Option 1: -7.4, Option 2: -14.6, Option 3: -24.1). Looking at the right-hand side, the emissions are presented as reductions in the EU food chain including the waste treatment (-4.9, -9.8, -16.7), including the global food chain (-8.3, -16.7, -28.0) and, finally, the EU whole economy including rebound effects (-2.0, -3.9, -6.5). It should be noted that there is a high uncertainty related to the assumptions regarding the waste treatment (e.g. share of food waste in landfill etc.).

 Figure 24: Overview of different emission calculations within MAGNET range of reduction in Mio CO2eq from Option 1 to Option 3

Source: MAGNET simulation results

Figure 25  presents a comparison of the bottom-up analysis and the general equilibrium model with regard to the resulting emission savings. Apart from different assumptions on the estimated emissions per ton of food commodity, the choice of a linear (maximum benefit through full substitution of market commodity) or non-linear (considering rebound effects) approach as well as the spatial and sectorial coverage explain the differences.

Figure 25: Overview of different emission calculations by Consumption Footprint (life cycle assessment based) and within MAGNET range of reduction in Mio CO2eq from Option 1 to Option 3

Source: MAGNET simulation and bottom-up approach results

2.3.Economic impacts

This section assesses the impact of the selected policy options on economic variables such as changes in consumer demand, agricultural production and market prices and the impact on international trade. The aim is to show how the reduction of food waste affects different markets along the supply chain and to highlight the impact of possible direct and indirect rebound effects through the interlinkages of different markets. This section concludes with an economic cost-benefit analysis focusing on the costs associated food waste reduction and the resulting impact on GDP and welfare.

This study simulates the targeted consumer food waste reductions by increasing the cost of generating waste and accounting for both price and quantity effects associated with a reduction in food waste as outlined in earlier. In doing so 50%, 30% and 15% respectively of the initial food waste is recovered as food for human consumption. In addition, food waste reduction at retail, processing, and primary production stages affects output and market prices. Reducing food waste increases cost of waste generation relatively to the price for food commodities. As a result, the waste rate will fall as more food commodities are purchased when looking at relative prices; however, in addition some of the initially demanded food commodities will be recovered for food production. Thus, agricultural and food production could be produced by demanding fewer food commodity inputs. However, by how much this translates into lower market prices for agri-food commodities depends on the cost associated with food waste reduction.

Regarding the latter, on the production side, for each leverage point in the food supply chain, the costs for food waste reduction represent an internalisation of a market failure (which is food waste). The additional cost (represented by a tax) proxies for the adjustment costs (i.e., improvements in harvesting, labelling, storage, distribution) that inevitably result from (partly) removing these supply chain inefficiencies.

On the demand side, the slightly rising cost per unit of food consumption to the consumer is a market signal that reflects the behavioural adjustment required to reduce food waste (increased planning and preparation times, and/or market signals to incentivise food consumption behaviour). It should be noted, however, that market prices still fall because aggregate demands for food fall (quantity effect), which outweighs the rising per unit cost effect noted above

2.3.1.Demand impacts

Figure 26 shows the changes in consumer demand in the three policy options compared to the baseline in 2030 for selected commodities. As expected, consumer demand falls are greater when moving from the scenario “Option 1” to the scenario “Option 3” as more food waste is reduced and can be recovered for human consumption (quantity effects) and also increasing the relative price of generated waste to food commodities (price effect). On average, agri-food demand drops up to 5.5% in Option 3. In general, the reduction in consumer demand is highest for vegetables, cereals and fruits as these are the commodities with the highest waste shares, thus the uniform reduction of waste across commodities affects these commodities the most. Figure 27 shows demand changes of selected food groups at the MS level for Option 3.

Figure 26: Changes of EU27 consumer demand (%) for selected commodities, options vs baseline 2030

Source: MAGNET simulation results

Figure 27: Changes in consumer demand (%) in EU MS for selected commodities, Option 3 vs baseline 2030

Source: MAGNET simulation results

2.3.2.Price impacts

Figure 28 shows the percentage deviations of EU27 market prices compared to the baseline in 2030 and Figure 85 shows the changes at MS level. As consumer food demand decreases, also prices for agricultural and food commodities decrease. The effects are particularly pronounced for vegetables and fruits and marginal for animal protein. The average price of agri-food decreases from 0.3% (Option 1) to 1% (Option 3). 

Figure 28: Changes of EU27 market prices (%) for selected commodities, options vs baseline 2030

Source: MAGNET simulation results

However, the prices changes significantly differ across Member States. These effects are mainly driven by the underlying waste shares that determine how much of food is recovered by achieving a certain target, and thus have a clear influence on price and quantity effects.

Figure 29: Changes of market prices (%) in EU MS for selected commodities, Option 3 vs baseline 2030

Source: MAGNET simulation results

We see higher and mixed movements in consumer prices than that of market prices for particular sectors (see  Figure 30 ). That is because consumer prices also include the cost of reducing food waste to the households. Thus, the consumer price change reflects the net effect. While in some commodities prices increase, in other commodities price decreases occur at the EU level. For instance, price of oilseeds is to increase by more than 4% in the most advanced scenario but for animal protein there are price decreases. We also see mixed impact of scenarios. In most cases, higher food waste reduction targets lead to higher changes – either decreasing or increasing. However, consumer price of vegetables and fruits decrease in Option 1 and Option 2 whereas they increase in Option 3.

Figure 30: Changes in EU27 consumer prices (%) for selected commodities, options vs baseline 2030

Source: MAGNET simulation results

Similar to market prices, deviations in consumer prices change significantly across Member States and across sectors. One of the highest price changes are observed in the vegetables sector – up to 10% increase in the Netherlands. However, in some MSs there are price decreases.

Figure 31: Changes in consumer prices (%) in EU MS for selected commodities, Option 3 vs baseline 2030

Source: MAGNET simulation results

Reductions in demand for agri-food in the EU and the price impact that it creates is also reflected in land prices. As shown in  Figure 32 , there is also a decrease in land prices for primary agriculture in the EU, which reaches up to 5% in the highest target scenario Option 3. The decrease for crops and pasture are in similar ranges in all scenarios.

Figure 32: Change in land prices in EU (% change, options vs baseline 2030

Source: MAGNET simulation results

2.3.3.Production impacts

Reducing food waste associated with primary agricultural production (i.e., post-harvest losses) leads to an increased availability of agricultural commodities at each given price so that prices would need to decrease in order to achieve a new market equilibrium at which less agricultural commodities are sold at lower market prices. In our simulations we consider food waste reduction at processing, retail and consumer stages that result in an additional decrease of agricultural and food commodity demand, which in return leads to a fall in market prices and a reduction of agricultural and food supply to achieve a new market equilibrium. Figure 33 shows the percentage changes of agricultural and food supply in the selected policy options compared to the baseline in 2030. On average agri-food production is estimated to decrease from 0.6% (Option 1) to -2% (Option 3), however at the commodity level there are differences. While most of the commodities show a reduction in output, the effect on wheat and oilseeds differs. This can be explained by less waste shares in cereals and oilseeds than mainly that of vegetables and fruits. Also, the small increase in oilseeds production can be traced back to the decreasing demand and production of vegetables and fruits - the land that is freed up from the production of this sector which is now potentially filled by oilseeds over time as a rebound effect.

Figure 33: Change in EU27 agricultural production for selected commodities, options vs baseline in 2030

Source: MAGNET simulation results

The higher the reduction target, the larger is the impact on agricultural and food output. Figure 34 shows the decomposition of the results by stage of the supply chain considering absolute deviation of agricultural and food output expressed in ktons compared to the baseline in 2030, which shows that the results are driven by the reduction of food waste at the consumer level while the other stages contribute much less. This is partially explained by the reduction target to be achieved, which is highest for the consumer level and by the waste share of each stage but also by the cost associated with achieving the reduction of food waste.

Figure 34: Changes in EU27 agricultural production compared to the baseline in 2030

Source: MAGNET simulation results

In addition to that, Figure 35 shows the absolute changes compared to the baseline in 2030 by Member State for the selected options while Figure 36  shows the absolute changes by Member State for selected food commodities for Option 3.

Figure 35: Changes in agricultural production (kton) in EU MS for agri-food commodities, options vs baseline 2030

Source: MAGNET simulation results

Figure 36: Changes in agricultural production (thousand tonnes) in EU MS for selected commodities, Option 3 vs baseline 2030

Source: MAGNET simulation results

Taking vegetables ( Figure 37 ) and fruits ( Figure 38 ) as an example, the graphs show the percentage changes of production and consumption compared to the baseline in 2030. It becomes apparent that food waste reduction results in a larger percentage reduction of consumer demand compared to the decrease or in some cases increase of production. As market prices in the EU fall, producers become more competitive on the world market, and thus could potentially increase their export to the world market in order to buffer the demand shock.

Figure 37: Vegetables: Changes in agricultural production and consumer demand in EU MS (%), Option 3 vs baseline 2030

Source: MAGNET simulation results

Figure 38: Fruits: Changes in agricultural production and consumer demand in EU MS (%),, Option 3 vs baseline 2030

Source: MAGNET simulation results

2.3.4.Trade impacts

Food waste reduction in general could lead to higher extra-EU agri-food exports and lower agri-food extra-EU imports. Figure 39 and Figure 40 show percentage change deviations in EU’s exports to non-EU countries and imports from them for a selected group of agri-food products, calculated for different policy options with respect to the baseline in 2030. Increasing the target rate for food waste reduction results in higher exports and lower imports.

Regarding extra-EU agri-food exports, the highest increase is seen in the vegetables sector (rise by 7% in Option 3). Vegetables is one of the sectors with the highest waste shares, hence reducing food waste in this sector would lead to lower demand by consumers and lower production volumes as explained in Section 2.3.1 and Section 2.3.3. In the end EU producers are expected to export more agri-food products to non-EU countries in the short to medium term.

Figure 39: Percentage change deviation in extra-EU exports, options vs baseline 2030

Source: MAGNET simulation results

Changes observed in extra-EU exports are reflected on extra-EU imports ( Figure 40 ). Option 3 - that leads to a 7% increase of EU’s vegetable exports- leads to a decrease 12% in EU’s imports. For wheat, the pattern is the same, with an increase of over 5% in extra-EU exports with a decrease of imports by 10% in Option 3.

Figure 40: Percentage change deviation in extra-EU imports, options vs baseline 2030

Source: MAGNET simulation results

The impact of food waste reduction scenarios on intra-EU trade is more limited than the impact on extra-EU trade. For instance, intra-EU trade of fruits could decrease by only 0.6% in Option 1 to 1.8% in Option 3. For vegetables, the expected decrease is higher by 1.5% to 4.2%.

The generally decreasing trend in extra-EU imports and increasing in extra-EU exports leads to an increase of EU’s agri-food trade baseline across all options versus the baseline in 2030. In value terms, the highest increase in the agri-food trade balance is seen in the fruits sector, which is negative in the baseline. Food waste reduction leads to an improvement in the fruits trade balance that ranges from nearly EUR 350 million to over EUR one billion depending on the option ( Figure 41 ), hence decreasing the trade deficit in fruits up to 11% in Option 3.

Figure 41: Change in EU’s agri-food trade balance by food groups options vs baseline 2030

Source: MAGNET simulation results

Also driven by lower EU prices and increased competitiveness of EU producers in the world market, impact of food waste reduction is positive for the EU’s agri-food trade balance – at least in the short term to the medium term until markets adapt to the generation of less food waste. With the policy Option 3, the expected increase in the EU’s agri-food trade balance amounts nearly to EUR 7 900 millions, whereas we observe decreases in the agri-food trade balance of non-EU countries. Figure 42 depicts these changes for Option 3. Asia’s trade balance in agri-food is to decrease the most mainly lead by declining trade balance in dairy and livestock. For Latin America, the decrease primarily results from the fruits sector given the highest share of fruit imports of the EU from this region and expected less imports of EU.

Figure 42: Change deviation in agri-food trade balance Option 3 vs baseline 2030

       Source: MAGNET simulation results

It should be noted that this is based on the assumption that while non-EU countries may be engaging in food waste prevention as part of their commitment to the global SDG Target 12.3, they are not implementing similar food waste reduction policies (i.e., legally binding targets) and/or implementing such policies at a slower pace. If they do, the advantage of the EU will decrease proportionally to their progress.

2.3.5.GDP and income

Food waste reduction scenarios have marginal macroeconomic impact on the real GDP of the EU and non-EU countries as a total whereas the impact increases with higher food waste reduction targets ( Figure 43 ). Even with the most advanced reduction targets, there is a decline in EU27 GDP of less than 0.02%. On the other hand, although not depicted in Figure 43 , there is a small increase in GDP per capita (up to 0.05% for the EU27 average in Option 3). For the rest of the world the impact is negligible.

Figure 43: Change deviation in real GDP for EU and non-EU, options vs baseline 2030

Source: MAGNET simulation results

The impact of food waste reduction on the GDP of individual EU27 countries is given in Figure 44 . Although the total impact on GDP is negative and small, we see a more mixed impact at the Member State level. In most cases, impacts are negative and, even with the highest reduction scenario (Option 3), they are very limited, with less than 0.1% decline. On the other hand, some countries (e.g., Bulgaria Lithuania) experience GDP growth with decreasing their food waste. However, this increase is also very limited and reaches 0 05% only in the highest case.

Figure 44: Change deviation in real GDP at MS level, options vs baseline 2030

Source: MAGNET simulation results

The effects on income (value added) in total remain unchanged for the EU aggregate: even a small increase of EUR 800 million to over EUR 2.2 billion can be observed depending on the option ( Figure 45 ).

Figure 45: Changes in total income in EU27, options compared to baseline (2030) for different actors

Note: Rest of the economy includes a broad number of sectors with either positive or negative income changes.

Source: MAGNET simulation results

Figure 46 shows the changes in income per Member State and per sector. The income of the agri-food sector (including food processing but not food services) experiences a slight decrease of -3.6%. Impacts are higher in the food service sector. The losses in the food sector are in general compensated by additional income in non-food sectors.

Figure 46: Changes in income in EU MS, Option 3 vs baseline 2030

Source: MAGNET simulation results

2.3.6.Estimated adjustment costs associated with food waste reduction

This section discusses the cost associated with food waste reduction along the stages of the supply chain to the end users. As introduced in Section Error! Reference source not found. of Annex 4, waste generation in production and consumption are the resulting market externalities arising from rational agent behaviour.

To account for these negative externalities associated with food waste, and thus correct the market failure, an adjustment cost must be imposed on the corresponding agent to internalise (partly) the full (social) cost associated with waste. In the model assessment, these costs are estimated by inserting taxes on those agents that generate food waste from the farmgate to the end user.

The total adjustment costs for food waste reduction (calculated separately per supply chain and then aggregated) are estimated to be around EUR 0.9 bn for Option 1, EUR 2 bn for Option 2, and EUR 3.8 bn for Option 3 ( Figure 47 ). Since the largest share of food waste is generated at the consumption stage, the costs associated with food waste reduction at this stage are the highest (exceeding EUR 3 bn in Option 3). The total adjustment costs for the industry are estimated to be relatively lower.

Figure 47: Estimated adjustment costs associated with food waste reduction per stage of food supply chain, EU27 – options vs baseline 2030

Source: MAGNET simulation results

Figure 48 below shows the total costs associated with food waste reduction in the Member States for the three options. The costs are calculated separately per supply chain and then aggregated to represent the total costs per country and per option. Reaching the targets in Option 1 comes at comparably low cost, while costs tend to increase when moving to the higher food waste reduction targets as in Option 2 and Option 3. These costs differ significantly across Member States. As shown in Figure 48 , total food waste reduction costs are small in EU13 153 countries. These countries have relatively lower food waste quantities compared to the EU average in the baseline. According to the size of the countries, highest costs are observed in Germany, reaching up to 1 EUR billion in Option 3, followed by Italy (600 EUR million) and France (500 EUR million). In these Member States, absolute food waste quantities are the highest in the 2030 baseline, leading to higher amounts of food waste to be reduced per option.

Figure 48: Total estimated adjustment costs associated with food waste reduction, EU MSs – options vs baseline 2030

Source: MAGNET simulation results

Regarding adjustment costs per ton of food waste reduced, on average, the costs range from EUR 17 per ton in Option 1 to over EUR 100 per ton in Option 3 ( Figure 49 ). At the individual stage level, highest costs occur for households – reaching up to EUR 160 per ton (Option 3). However, costs for the retail and distribution sector are also estimated to be over EUR 100 per ton (Option 3) due to high targets of food waste reduction (50%). 

Figure 49: Adjustment costs of food waste reduction per ton of food waste reduced, EU27 – options vs baseline 2030

Source: MAGNET simulation results

Primary production

As only Option 3 targets food waste reductions at the primary production level, we report only the results of Option 3 in  Figure 50 . A 10% reduction of food waste in the production stage leads to an average adjustment cost of around 6 EUR per ton of food waste reduced. This cost is mainly driven by the waste reductions in the crop sector, with adjustment costs estimated similarly at around 6 EUR per ton. The costs for livestock production are slightly higher, however they influence the average price less than the crops sector as primary production only considers livestock farming and excludes processing.

Figure 50: Adjustment costs associated with 10% food waste reduction at the primary production stage, EU27, Option 3 vs baseline

Source: MAGNET simulation results

Processing and manufacturing

Adjustment costs of food waste reduction per ton of food waste reduced at the processing and manufacturing stage, start from 19 EUR/ton in Option 1, and reaches up to 29 EUR/ton in Option 3, on average, for food and agriculture commodities, as shown in  Figure 50  in the previous sub-section. 

Figure 51  shows the average adjustment costs associated with food waste reduction at the processing and manufacturing sectors across MSs. While the costs vary significantly across MSs, in the majority of MSs, they are lower than the EU average. Particularly the Netherlands and Spain face the highest costs which are higher than 40 EUR per ton.

Figure 51: Cost associated with food waste reduction at the processing stage across Member States, options vs baseline 2030

Source: MAGNET simulation results

Retail and Distribution

On average, adjustment costs of food waste reduction per ton of food waste reduced for the retail and distribution sector is estimated to start from 25 EUR/ton in Option 1 and increase up to 123 EUR/ton in Option 3.   Figure 52  shows the cost associated with food waste reduction at the retail and distribution stage for the three options that is split into the following retail categories: distribution, food services, and agri-food retail. Costs increase as the ambition with regard to food waste reduction increases; however, they are within the same range across retail categories in all options.

Figure 52: Adjustment costs associated with food waste reduction at the retail stage EUR/ton, EU27, options vs baseline, 2030

Source: MAGNET simulation results

Figure 53 shows the average costs associated with food waste reduction across all policy options at the individual MS level. Most countries face adjustment costs that are over 100 EUR per ton. While the lowest costs are observed for Bulgaria and Romania, the highest cost occurs in Ireland.

Figure 53: Average costs associated with food waste reduction at the retail stage across MSs, options vs baseline, 2030

Source: MAGNET simulation results

Households

Figure 54 shows the cost associated with household food waste reduction in the EU27 for the three options, expressed in EUR per ton for the average of the food and agriculture sector, and at a more granular level for crops, livestock, and food and food services. Reaching the targets in Option 1 comes at a comparably low cost. The cost associated with food waste reduction is estimated to be 20 EUR/ton for agri-food on average, but costs tend to increase more than proportionally when moving to higher reduction targets in Option 2 (60 EUR/ton) and in Option 3 (160 EUR/ton). This more than proportional increase of costs occurs as food waste prevention actions usually first target the areas where savings are easiest to achieve, and after this point, expected costs tend to become higher. At the sector level, the highest costs are noted for food and food services

Figure 54: Adjustment costs associated with household food waste reduction, EU27, options vs baseline 2030

Source: MAGNET simulation results

Costs associated with household food reduction differ significantly across MSs. Figure 58 shows that cost tend to be lowest and below EU average in the EU13 MSs. While highest cost is observed in Ireland, food waste reduction at the household level lead to lowest costs in Bulgaria.

Figure 55: Average adjustment costs associated with household food waste reduction, options vs baseline 2030

Source: MAGNET simulation results

The survey sent to stakeholders as part of the targeted consultation (Annex 2) aimed at gathering quantitative data on food waste prevention actions provided some insights on the cost of preventing FW 154 . It received 50 answers on the cost of running the initiatives. 42 respondents provided quantitative data on the amount of prevented food waste achieved by the initiative.

Based on these data, a total cost per tonne of avoided food waste was calculated. The mean value for the whole set of initiatives was 986 EUR/ton, while when considering the ‘food redistribution’ initiative type, the mean value was lower (475 EUR/ton). These values are higher compared to those derived by the MAGNET model and the few information available in literature (Garcia Herrero et al., 2023). Possible explanations for this difference are few initiatives were reported through the survey; these were were generally small and many were oriented to the achievement of additional objectives (i.e., supporting people in need, helping the professional reinsertion of unemployed people etc.). Moreover, in some cases, initiatives aimed at long term behavioural changes (e.g. school campaigns) while food waste measurements gathered only immediate food waste reductions. For these reasons, and also due to the high variability of the data on costs collected, information from the survey related to costs of food waste prevention were not directly used in the MAGNET model to calculate the macro-economic impacts of targets.

Furthermore, from the analysis of the survey responses, it resulted that, on average, 40% of the costs were linked to setting up the different initiatives with the remaining 60% linked to maintaining them. It is however important to highlight that significant variability was reported in this respect, most likely due to the heterogeneity of the types of initiatives reported but also the duration of the initiatives as the contribution of setting up costs naturally decreases with time.

2.4.Social impacts

There are two main social impacts identified from food waste reduction targets: a potential loss of jobs in food production and processing and improved food affordability. Other social impacts such as “inconvenience” or the so-called ‘labour-leisure’ trade-off (“lost” leisure time linked to more attention to food preparation more trips to the supermarket etc.) are hardly quantifiable but are included in the estimation of the costs linked to the reduction of food waste at consumption level. Similarly, the analysis of social impacts does not include such potential positive impacts as better understanding of impacts of food choices on health and the environment awareness-raising, potentially reducing the possible feelings of guilt and/or frustration associated with discarding food, positive social aspects of sharing food etc.

From the responses to the survey sent as part of the targeted consultation (presented in Annex 2), it emerged that food security and poverty reduction are seen as the main social benefit deriving from food waste prevention initiatives. Moreover, additional benefits related to awareness raising, training provided to employees and volunteers’ education and social cohesion were also reported.

2.4.1.Employment 

In this section we report the estimated impact of food waste reduction on employment with a focus on agriculture and food sectors. The presented employment effects have to be interpreted taking into account the earlier described model specificities regarding the functioning of the employment market.

Looking at the agri-food sector, food waste reduction scenarios generally lead to a decrease in employment as shown in Figure 56 . The magnitude of the decrease depends on the level of the food waste reduction target. The impact of lower consumer demand, hence lower production rates, is also seen as decreasing employment in the food and agriculture sector. However, the overall decrease in the total agri-food sector is limited to 2% even in the most ambitious scenario, Option 3. At the sector level, the employment in vegetables and other food sector is expected to decrease the most amongst other sectors (4% in Option 3). On the other hand, employment rises in non-agri-food sectors.

Figure 56: Change in employment in the EU (% change) options vs baseline 2030

Source: MAGNET simulation results

Figure 57 shows the absolute changes in employment for selected sectors. Job numbers decrease for the agri-food sector by 70 000 in Option 1, 135 000 in Option 2, and 220 000 in Option 3. It should be noted that in other sectors, such as manufacturing, new jobs are created.

Figure 57: Change in employment in the EU in selected sectors (thousand heads) options vs baseline 2030

Source: MAGNET simulation results

Figure 58 depicts the impact of food waste reduction on agri-food employment for three policy options. Expected reduction varies across Member States – ranging from -0.3% in Option 1 to -3% in Option 3 depending on the country. Largest percentage change decreases are observed for Germany, Portugal, and Belgium and Luxembourg.

Figure 58: Change in agri-food employment in EU MSs, options vs baseline 2030

Source: MAGNET simulation results

The reader is informed that the food service sector (and other service sectors) are not presented in the analysis. While the numbers of the primary and secondary sectors are directly linked to specific activities impacted by food waste reduction, the reaction of the food service sector cannot be represented in a fully satisfactory way. Firstly, the exact composition of the food service sector (i.e., restaurant, delivery services etc.) is not available. Secondly, the possible reaction of consumers to less waste in food services is not straightforward. The expectation to food waste reduction at the food service level is that if consumers behave in a more socially responsible manner (i.e. waste less), they might be expected to cut back on restaurant visits per time period as they consume out-of-home ‘leftovers’ at home. It is recognised, however, that the reduction in the number of visits to the restaurant is not proportionate to the reduction in waste as people enjoy the experience of eating out. Indeed, individuals with higher disposable income may cut back food services demand considerably less than those with lower incomes. In addition, food services waste reduction could be achieved (partly) by developing/improving management strategies. Thus, in the absence of any empirical evidence, the modelling approach assumes here that the reduction in household demand for food services is in proportion to the reduction in food services waste, thus likely overstating the effect on food services demand of consumers and the associated impacts on employment. Hence, in this section, results for the food service sector ares not presented. As a conclusion, even without the food service sector, the numbers below should be considered as a worst-case scenario. To the extent known, Member States that have taken steps in reducing food waste have not experienced negative impacts on employment in the food supply chain due to this reduction.

These results do also not take into account the potential job creation from food waste reduction initiatives, as this would entail strong assumptions on new job profiles required. Based on data from surveys to stakeholders, JRC estimates the number of new jobs created respectively for options 1, 2 and 3 at: 6 700 heads 12 500 heads and 22 300 heads. The new jobs created included the roles such as: logistics operators in food banks, coaching supermarkets’ staff as part of food redistribution initiatives, and collection/transport of products deriving from the valorisation of surplus food and by-products.

2.4.2.Income distribution

In all three options, the economy in the EU27 is only marginally affected. Calculating a standard measure for macroeconomic impacts, i.e., the value added at basic prices (output minus intermediate consumption), hereafter called “income”, the EU27 shows a slight increase in net income of more than 2 billion EUR (0.022%) in option 3. Also, for the options 1 (0.8 billion EUR, 0.008%) and 2 (1.6 billion EUR, 0.016%), the overall economic impact is positive.

Food waste reduction, however, could lead to farm income losses due to less food wasted and hence lower resulting food demand. Figure 59  shows the change in farm income from primary agriculture for EU27 across policy options. In general income losses from the crops sector are higher than in the livestock sector due to the higher share of fruit, vegetables and cereals in total food waste. Option 1 leads to a decrease of around EUR 2.2 billion in farmers’ income from crops and livestock farming, whereas in Option 3 this decrease is higher with EUR 7 billion, which corresponds to a decrease of 3.5%. The income in the total agri-food sector (including food processing but not including food services) could experience in the EU a limited decrease of about 3.6% in the most ambitious scenario (about 4.7% including food services).

Figure 59: Change deviation in farm income (primary agriculture) EU27, options vs baseline 2030

Source: MAGNET simulation results

Figure 60 depicts the change in the farm income for the maximum target scenario, Option 3, with respect to the baseline at the Member State level. At the Member State level, we see differences where France, Germany and Italy show the highest losses in absolute terms. It should be noted that the losses in the food sector are in general compensated by additional income in non-food sectors.

Figure 60: Change deviation in farm income (primary agriculture), Option 3 vs baseline 2030

Source: MAGNET simulation results

Regarding income changes for processed food and the food service sector, the highest income losses due to food waste reduction come from the food service sector (6% reduction at the EU level in Option 3). Figure 61 shows the change deviations per MS. Similarly to primary agriculture, the highest changes are observed in France, Germany, Italy and Spain.

Figure 61: Change deviation in income (food sector), advanced Option 3 vs baseline 2030

Source: MAGNET simulation results

It should be noted that the model does not take into account possible developments in production systems and consumption habits171 linked to the transition to sustainable food systems, which could trigger needs for new products and/or services (e.g., shift to organic farming which generates higher income). For this reason, the numbers above should be treated rather as a worst-case scenario. 

2.4.3.Food affordability

The average share of food expenditure (agri-food and food services) in total household expenditure in EU27 for 2020 is around 19%, which is projected to decrease by around 1.5 percentage points in 2030 in the baseline as depicted in Figure 62 . This result is because as personal disposal incomes grow, non-food demands in developed societies grow faster than food demands (Engel’s Law). The extent of this share differs across Member States, where typically those countries with lower per capita disposable incomes exhibit higher food budget shares.

Figure 62: Percentage share of food expenditure in total household expenditure, (Baseline 2020 and 2030)

Source: MAGNET simulation results

In all policy options examined, the share of food expenditure is expected to fall further, mostly because of decreased demand for food and linked food price reduction to it ( Figure 63 ). Larger amounts of food waste reduction lead to higher decreases in food expenditure shares of households. Due to an expected decrease in food prices linked to food waste reduction, and the reduced amount of food (and food services) purchased, households could save, on average, from 220 to over 720 EUR per year (depending on target levels) and spend these amounts on higher quality food or other goods and services. Such savings are particularly relevant in the current context of rising food prices.

Figure 63: Food expenditure shares and percentage change deviations in food expenditure share, options vs baseline 2030

Source: MAGNET simulation results

Figure 67 shows the Member State-specific data for percentage change deviations in food expenditure. In nearly all EU27 countries, Option 3 results in a decrease of over 6%. Food expenditure shares decrease the most in Slovenia, Denmark and Bulgaria (around 8%).

Figure 64: Percentage change deviations in food expenditure share in total household expenditure, options vs baseline 2030

Source: MAGNET simulation results

2.5.Other impacts

2.5.1.SDGs

The Better Regulation TOOL #19. SUSTAINABLE DEVELOPMENT GOALS indicates: “The indicators and monitoring arrangements underpinning the SDGs can be used to describe the status quo policy objectives, expected impacts of policy options and the observed changes resulting from new policies. As such, the SDG framework is highly relevant for impact assessments and evaluations.” It further outlines “the relevant SDGs should be identified and the associated indicators should be used (if available) when preparing the following sections of the impact assessment report” (page 151).

Among the proposed “Tools for the analysis of SDGs” the SDGs modelling tool aims to facilitate the use of models for sustainability assessment in the SDGs framework trough the identification of appropriate model(s) for the assessment of specific policy options. The tool provides the list of all the models run or developed by the Commission and included in the Modelling Inventory and Knowledge Management System (MIDAS) and their contribution to the SDGs (at goal target and indicator level). This tool offers a transparent mapping of how model outputs can be directly or indirectly linked to EU/UN SDGs indicators, therefore screening which models could be suitable to quantitatively evaluate the impacts of policy options on SDGs targets and indicators.”

As shown in the related report “ Modelling for Sustainable Development Goals (SDGs): Overview of JRC models ”, the MAGNET model is listed as one of the models with the broadest coverage of SDGs and its related indicators.

Indeed, over the last years, the MAGNET model has been further developed for this purpose and was selected by UN-DESA as one of the 16 outstanding SDG Good Practices across the world. The approach also features in the 2021 OECD/JRC report on “ Spillovers and Transboundary Impacts of Public Policies ”. Several scientific articles witness the methodological developments and applications over a broad range of topics.

The figures Figure 65 (percentage changes in the three options) and Figure 66 (absolute changes) present a selection of direct or indirect SDG indicators as outcome of the MAGNET model.

The results of the bottom-up analysis can complement the assessment of the implications of the policy options on a number of relevant SDGs, as this analysis provides an assessment of the impact of the different policy options on additional environmental impact categories. The assessment allows to further evaluate four environmental impact categories of the Environmental Footprint ( Commission Recommendation C(2021) 9332 final ), which are connected to a number of SDGs (Sanye-Mengual and Sala, 2022). The approach also features in the 2021 OECD/JRC report on “ Spillovers and Transboundary Impacts of Public Policies ”.

For the purpose of this exercise, to reduce the complexity of the assessment, the most relevant SDG was identified for each of the four environmental impact categories considered in this analysis. The outcome is presented in Figure 67 (percentage changes in the three options) and Figure 68 (absolute changes).

Figure 65: Percentage changes of selected direct or indirect SDG indicators

Source: MAGNET simulation results

Figure 66: Absolute changes of selected direct or indirect SDG indicators

Source: MAGNET simulation results

Figure 67: Percentage changes of selected direct or indirect SDG indicators

Source: Bottom-up analysis

Figure 68: Absolute changes of selected direct or indirect SDG indicators

Source: Bottom-up analysis

2.5.2.Territorial impacts

The MAGNET model does not provide results for subnational geographical units. However, a preliminary assessment of the potential territorial impacts of the food waste reduction targets can be performed considering the differences in the production structure at the regional level. Thus, we can assume that those regions whose production structure includes most affected sectors by the food waste reduction objectives, will be also the most exposed to the overall economic impact.

In this section we analyse the potential impacts of food waste reduction in the advanced target scenario over regional employment. For this exercise, we focused on some selected sectors that would be the most affected by the food waste reduction according to the aforementioned scenario: (1) agriculture (2) food manufacturing and (3) waste collection. We also analysed both the manufacturing and service sectors (the latter only for value added) so as to have a holistic perspective of the economy. For each sector, we retrieved data on both regional employment (number of persons employed by NUTS2 regions) and value added (million euros) from Eurostat data sources (Regional Accounts and Structural Business Statistics).

The year 2019 is selected as the reference given that it is the most recent year not affected by the COVID-19 pandemic for which both datasets have data availability. Regional accounts provide information until the year 2021, while Structural Business Statistics recently published the data for 2020. However, some sectors such as the accommodation and food services activities were strongly affected by lockdowns and other measures to mitigate the pandemic. Consequently, the information on these years may be distorted with regard to both recent and projected trends in MAGNET even though the effects of the COVID-19 shock was already considered in the baseline scenario.

Table 39: Selected indicators and data sources

Source: Authors’ own elaboration 

After some processing and consistency checks 155 , the data from Eurostat were used to calculate the share of both regional employment and value added over the total for each sector per country. Then, these shares were used as a criterion to distribute the foreseen deviations by country among the corresponding NUTS2. The results are described below. 

Table 40  and Table 41  show a general overview of the impact of food waste reduction by NUTS2 regions classified according to their level of development. This classification follows the same criteria as the eligibility to receive European Regional Development Funds. Thus, the less developed regions are those whose GDP per capita is below 75% of the EU average, the transition regions show a GDP per capita between 75% and 100% of the EU average, while the most developed regions present a GDP per capita above 100% of the EU average. 

Table 40 - Potential impact on total regional employment by group of regions according to their level of development

 Source: Own elaboration from MAGNET results and Eurostat data. 

Table 41 - Potential impact on total regional value added by group of regions