Are you prepared for EPR and the BUPD?
Europe is reshaping the fashion industry through regulation. Extended Producer Responsibility (EPR) for textiles and Europe’s upcoming BUPD are shifting accountability from waste operators to brands. The question is no longer whether brands should prepare. It is whether they are ready. Opera provides a tangible solution and the data you need towards it.
If an auditor asked where every returned or unsold garment ends up, could your brand provide evidence?
Circularity is not a branding choice. It is a legal obligation tied to measurable performance.
Who created these regulations and why they matter
Textile EPR is mandated by the European Union under the Waste Framework Directive (Directive 2008/98/EC, revised by Directive (EU) 2025/1892 in September 2025). The revision makes textile EPR mandatory in every Member State by 17 April 2028. Brands will become financially and operationally responsible for end of life management.
Spain, through the Ministry for Ecological Transition (MITECO), is developing the BUPD, aimed at preventing the destruction of unsold goods, increasing traceability and reducing textile losses. Its draft Royal Decree on textile and footwear products was notified to the European Commission on 27 May 2026 and had not been approved by 15 October 2026.
These laws are not voluntary. They redefine the responsibilities of every fashion brand operating in the EU.
The numbers behind the law
Europe’s textile waste problem is well documented.
- The European Environment Agency puts textile waste in the EU at 6.94 million tonnes in 2022, about 16 kg per person.
- Only 4.6 kg per person of that is collected separately, and an even smaller share is recycled.
- According to the EEA, 11.1 kg of textiles per EU citizen a year end up in mixed household waste, most of which goes to landfill or incineration.
- The European Environment Agency estimates in a 2024 briefing that one in five garments bought online in Europe is returned, and BEUC cites research that 32% of fashion parcels in the EU are returned.
These data points explain why lawmakers are now requiring brands to recover more and waste less, with measurable results.
What brands will be required to demonstrate
Under the revised Waste Framework Directive and Spain’s BUPD structure, brands face three core obligations.
1. Financial contribution
Brands must fund systems for collection, sorting, reuse, preparation for reuse and recycling of textiles.
2. Detailed reporting
Brands must report:
- Units placed on the market
- Units collected for reuse
- Volumes prepared for reuse versus recycled
- Exports of used goods and their destination
- Destruction of unsold goods and justification
The EU has signalled that reporting will move toward item level traceability and Digital Product Passports.
3. Waste reduction and reuse outcomes
France’s AGEC law already bans the destruction of unsold goods. Spain already bans the destruction of unsold non-perishable goods, textiles included, under Article 18(2) of Ley 7/2022.
What proactive brands are already implementing
Across Europe, leading brands preparing for the new textile requirements are turning to specialised partners rather than building complex systems internally. Opera offers a simple, end to end solution that addresses every dimension of the problem: data, compliance, sustainability, circularity and operations.
1. Integrating preparation for reuse into their operations
Brands partner with Opera to process returned and pre owned garments through professional cleaning, refreshing, grading and certification. This allows items to legally qualify as “prepared for reuse”, which reduces waste volumes and lowers their future EPR financial contributions. It also turns previously lost inventory into recoverable value.
2. Adopting a traceability layer built for compliance
Opera captures item level data at every step of the journey. Brands gain transparent evidence of condition assessment, processing route, preparation for reuse, resale eligibility and final outcomes. This supports the coming requirements of the Digital Product Passport and ensures they can demonstrate full traceability during audits.
3. Creating reliable recovery channels instead of destruction
pera enables brands to redirect garments into controlled recovery paths such as resale or reuse. With EU restrictions on destroying unsold textiles, these pathways are becoming essential. Our model gives brands a compliant alternative that preserves value, protects brand integrity and reduces environmental impact.
Compliance is becoming operational.
Circularity is becoming mandatory.
Brands that prepare now will avoid penalties and unlock value from returns and unsold stock rather than absorbing them as losses.
( About the author )
Joanna Lambert
CEO & Co-Founder, Opera Garment Solutions
Joanna Lambert is CEO and co-founder of Opera Garment Solutions, which recovers returned, damaged and unsold clothing for fashion brands across the EU and the UK from hubs in the United Kingdom, the Netherlands and Spain. She writes on the EU destruction ban and on what returned stock is worth when it goes back to sale.