Regulations at the District Board 

The Prato Textile District is actively engaged in monitoring and influencing the development of Italian and European regulations to ensure compatibility with local specificities and business needs. Collaboration among institutions, trade associations, and companies is crucial for addressing challenges and leveraging opportunities presented by the transition to a circular and sustainable economy.

 

1. ECODESIGN REGULATION 

What it is: The new Ecodesign Regulation, which came into force on July 18, 2024, will establish specific operational rules for product categories by 2025. It sets minimum sustainability requirements for all products on the European market, promoting durability, reparability, recyclability, and the use of recycled materials. A ban on the destruction of certain unsold textile items will apply from July 19, 2026, with exemptions for micro and small enterprises.

Companies in Prato have raised concerns about the strong emphasis on product durability, advocating for the inclusion of circularity and responsible production criteria. They recommend that delegated acts balance these aspects to avoid favoring one over others.

The "Preparatory study on textiles for product policy instruments – 2nd milestone" by the JRC, preliminary to the textile ecodesign act, introduces further critical issues potentially penalizing typical Prato textile productions:

• Exclusion of Post-Industrial Waste: It envisions excluding waste generated along the textile production chain (Post Industrial) from materials usable for recycled textile product manufacturing, arguing that inclusion would incentivize waste production. However, this would penalize the virtuous reuse and valorization of by-products and waste in the production chain, leading to increased landfill waste.
• Limitation of Industrial Symbiosis: A scenario is outlined that prevents industrial symbiosis and thus recycling textile waste in sectors other than pure textiles. The district argues there is no reason to limit the use of recycled textile fibers only to textile products; considering various sectors for potential use is fundamental to maximizing textile waste reuse.
• Generic Durability Criteria: Durability criteria appear too generic, failing to consider fundamental aspects like fiber composition and garment intended use.
• Recognition of GRS: It is crucial to recognize the GRS (Global Recycled Standard), a widely used international technical standard, among accepted methodologies for calculating recycled content and include it in the European accreditation system under Regulation (EC) No 765/2008. This would encourage the adoption of recycled products and ensure supply chain transparency and sustainability.

Main objectives:

• Greater durability and reparability of products;
• Reduction of hazardous substances;
• Presence of recycled fibers;
• Improved recyclability;
• Ban on destruction of unsold textile products (from 2026 for large companies, 2030 for medium-sized).

Prato district position:

• Promote balance between durability, circularity, and responsible production;
• Avoid excessive emphasis on performance that penalizes recycled materials;
• Adapt performance specifications to the intended use of the fabric and textile material composition;
• Continue and increase recycling of textile waste generated during production phases and avoid penalizing it;
• Find outlets in various sectors (industrial symbiosis) for textile waste that cannot be recycled via upcycling;
• Recognize the GRS (Global Recycled Standard) among the methodologies accepted for recycled content calculation.

Current status: Under discussion.

 

2. EXTENDED PRODUCER RESPONSIBILITY (EPR) 

What it is: The EPR system assigns the "producer" financial and organizational responsibility for a product's end of life. The Italian Ministry of the Environment is developing a decree to implement EPR for textile products. However, in the Prato district, most SMEs produce semi-finished goods (yarns and fabrics) and thus do not fall under the current definition of "producer," understood as the entity placing the finished product on the market.

It is important to emphasize that textile manufacturing companies upstream in the supply chain possess the expertise, technology, and investments essential to determine a textile product's sustainability level. Therefore, it is essential to guarantee:

• The right to actively participate in the governance of waste management consortia;
• Differentiation of eco-contributions between recycled and non-recycled products, with clear consumer communication;
• Transparency on the destination of secondary materials for reuse;
• Adequate funding from the eco-contribution for research and development;
• Rules that recognize and valorize territorial specializations in recycling flow management.

Main objectives:

• Encourage collection, reuse, and recycling of textiles;
• Finance innovation and sustainable infrastructure.

District requests:

• Active role also for companies along the textile supply chain, not only brands;
• Differentiated eco-contributions for recycled and non-recycled materials;
• Greater transparency on the destination of secondary raw materials.

Current status: The national Ministerial Decree has just emerged from a consultation phase with stakeholders. At the European level, the amendment to the Waste Framework Directive introducing textile EPR has already passed the trilogue.

 

3. DIGITAL PRODUCT PASSPORT (DPP) 

What it is: A "digital passport" that accompanies the product and contains information on traceability, sustainability, materials, etc. This tool aims to provide detailed information on product sustainability, such as composition, origin, and environmental impact. However, it is essential that the organizational and financial burden does not fall excessively on SMEs. It is important to include representative information such as the country of manufacture and the amount of environmental contribution under the EPR.

Main objectives:

• Improve transparency and inform consumers;
• Encourage sustainable purchasing choices.

District requests:

• No excessive burdens for SMEs;
• Value traceability information with truly useful data like the country of manufacture and the EPR contribution.

Current status: Under discussion.

 

4. VAT REDUCTION FOR REGENERATED MATERIALS 

What it is: Proposal to reduce VAT to 5% on products made with certified recycled materials. To encourage the purchase of products made with regenerated materials certified through specific labels or collective marks, a reduction of the VAT rate to 5% is proposed. This measure should be accompanied by strengthening Green Public Procurement (GPP) and increasing the adoption of green purchases by public administrations. Additionally, incentives for SMEs that, while not directly subject to the new EFRAG/CSRD regulations, are part of supply chains of companies obliged to comply, would be helpful.

Main objectives:

• Encourage sustainable purchases;
• Strengthen Green Public Procurement in public administration;
• Support SMEs in the CSRD transition even if not obligated.

Current status: Under discussion.

 

5. END OF WASTE (TEXTILES) 

What it is: Regulation defining when a waste ceases to be waste and becomes secondary raw material. Besides the moment, it should define which processes/operations must be completed and which characteristics the material must have to be considered secondary raw material and no longer waste.

The Prato district, with its long-standing experience in textile material regeneration and considering the dimensional characteristics of (micro and small) highly specialized enterprises in individual work phases, aims to promote reuse, regeneration, and industrial recycling of textiles by clearly defining when waste ceases to be such and becomes secondary material.

It is believed that the recovery phase should be as close as possible to the initial selection of textile waste to avoid excessive administrative burdens for micro-enterprises specialized in the recovery chain. Excessive extension of processes included in waste management could compromise the competitiveness and economic sustainability of the sector. The interpretation promoted by JRC — considering post-consumer textile material waste until mechanically reduced to fiber — is therefore considered critical and harmful.

Globally, hundreds of thousands of tons of selected textile materials — from post-consumer waste, separately collected, free of non-textile components, cut and classified by fiber and color — are traded as raw materials, not waste. These materials are often purchased by textile raw material traders who send them to shredding plants based on customer or market requests. After shredding, they are combined with other fibers, virgin and recycled, to produce customized batches.

If JRC continues to classify clean, selected, and cut textile materials as waste before fiber reduction, many legally operating companies would suddenly become non-compliant. Transitioning to waste management, especially for mostly small European companies, would be economically prohibitive. Consequently, with no tangible environmental benefit, we risk losing companies, jobs, specialized skills, and crucial segments of the European textile manufacturing supply chain. We ask that these concerns be taken into utmost consideration.

Also: We recognize the importance of ensuring recycled materials do not pose health and environmental risks (as well outlined by JRC). However, we consider it essential to adopt a risk-based approach to assess hazardous substances in textile products, particularly for reuse and recycling. It is fundamental that restrictions on hazardous substances be implemented based on risk assessment that considers necessary adaptation times.

Testing every single incoming batch for all possible hazardous substances is technically impossible. Therefore, a risk-based approach is not only preferable but the only viable way to effectively manage the issue. This way, risks can be managed, and the use of recycled materials (as well as reuse of second-hand garments) can be safely allowed.

A regulation not considering this difference, if strictly applied, could compromise sectors such as mechanical textile recycling, especially for post-consumer materials. While safeguarding health and environment remains a priority, not differentiating hazardous substance limits between virgin and recycled material — without considering overall environmental impacts — could sometimes hinder material recovery. This might leave landfill disposal or energy recovery (if calorific value allows) as the only viable options. However, these solutions would undermine sustainability and circularity goals and contradict the waste hierarchy established by Europe, which prioritizes recycling and recovery over energy recovery and landfill, the latter to be limited due to its high environmental impact.

Furthermore, regarding compliance of materials for reuse (and similarly recycling) with REACH and/or POP regulations, it is crucial to recognize the impracticality of chemical analysis on every single item. Random sampling would yield inconclusive results due to material heterogeneity. However, any textile waste showing visible stains or contamination detectable by sight or smell is removed during sorting.

Therefore, we support a balanced approach that ensures safety without excessively penalizing reuse and mechanical recycling, fundamental to promoting circular economy in textiles. We propose that risk assessment, given the technical impossibility of exhaustive testing, be the core of restriction implementation, paying particular attention to necessary industry adaptation times.

Critical issues for the district:

• Waste management (End of Waste) should conclude after selection, sanitization, and cutting, not after shredding;
• Overly restrictive rules would jeopardize thousands of micro and small enterprises;
• A realistic End of Waste definition is needed to protect widespread industrial recycling;
• Hazardous substance management in textiles should follow a differentiated risk evaluation to avoid major penalties on reuse and mechanical recycling of historic textiles.

Current status: Preliminary study is in its final phase at the Joint Research Centre (JRC), the European Commission’s research center.

 

6. REACH AND RECYCLED TEXTILES 

What it is: European regulation for chemical safety and management in Europe. REACH is the reference for chemical safety of products and chemical management in textile products and beyond. It is necessary that textile material restrictions consider the material life cycle in the case of recycled textiles, avoiding that undifferentiated REACH restrictions hinder material recovery. Undifferentiated application of restrictions could limit mechanical textile recycling, especially post-consumer materials, and lead to ineffective waste management.

Challenge for recyclates:

• Undifferentiated application of restrictions (no distinction between virgin and recycled fibers) hinders use of post-consumer recycled materials;
• Too strict REACH enforcement (not based on differentiated risk assessment) would heavily penalize reuse and mechanical recycling of historic textiles;
• Balance between environmental protection and industrial feasibility is needed.

Current status: In force since June 1, 2007. Status: Active.

 

7. MARKET SURVEILLANCE 

With increasing demands from EU regulations, it is necessary to ensure that textile products imported into Europe comply with the new laws. Therefore, we request serious investment in market surveillance. It is important that, with new regulations introduced, enforcement and applicability by Italian and European manufacturing companies are guaranteed, but also that a control system is organized for imported textile products to ensure a level playing field for European companies.

 

IN CONCLUSION 

The critical issues described above risk primarily impacting the upstream links in the supply chain (1,500 companies and 10,000 workers), which may struggle to manage the effects of these measures, facing difficulties and closures. Subsequent production phases would also be heavily affected due to the typical interconnections of industrial districts.