Besluit UPV Textiel: What Fashion Brands Selling in the Netherlands Need to Know
Besluit UPV Textiel, the Dutch decree on extended producer responsibility for textiles, was published in Staatsblad 2023 No. 132 on 21 April 2023 and entered into force on 1 July 2023. It applies to every party placing textile products on the Netherlands market professionally, with no revenue or unit threshold. Foreign producers selling directly to Dutch consumers must appoint a Dutch authorised representative unless they join a producer responsibility organisation, which then registers and reports for them. Producers have filed a report on every calendar year since 2023. The report on 2025 calendar-year data, the first against the targets, fell due to Rijkswaterstaat before 1 August 2026, and annual reports follow on the same calendar-year-plus-eight-months pattern, so the report on 2026 data is due before 1 August 2027. Rijkswaterstaat administers the national register and receives the report. The Inspectie Leefomgeving en Transport (ILT) inspects and enforces. Three producer responsibility organisations (PROs) operate alongside direct registration. From early 2028 the scheme is due to widen, footwear included, as the Netherlands applies the revised Waste Framework Directive.
What Besluit UPV Textiel requires
Besluit UPV Textiel is an Algemene Maatregel van Bestuur under the Wet milieubeheer. Staatsblad 2023 No. 132 published the text on 21 April 2023 and brought the decree into force on 1 July 2023. The decree requires producers placing textile products on the Dutch market to register with Rijkswaterstaat, report annually on volumes placed on market and their disposition outcomes, and meet binding reuse and recycling targets that escalate year on year.
Producer scope is broad. Every party placing textile products on the Netherlands market professionally is in scope. There is no revenue or unit threshold. A small foreign brand selling apparel directly to Dutch consumers via owned e-commerce sits inside the same obligation as a multi-billion-euro fashion group with retail estate across the Randstad. Foreign producers selling directly to Dutch consumers must appoint a Dutch authorised representative unless they join a producer responsibility organisation.
Product scope is set by Combined Nomenclature code. Consumer clothing and workwear sit under CN codes 61 and 62. Household textiles sit under CN 6302. Items outside these codes, including leather goods and footwear, are outside the current scope of Besluit UPV Textiel. The operational portal for registration sits at business.gov.nl, with the Rijkswaterstaat national register maintained through afvalcirculair.nl.
When the reporting deadlines fall
The annual report to Rijkswaterstaat is due before 1 August each year on the prior calendar year. The decree let producers limit the reports on 2023 and 2024 to the quantities placed on the market. The report on 2025, due before 1 August 2026, was the first to report against the targets, and the decree asks for verification documents, not a mandatory audit. From 2026 onwards every annual cycle runs on the same calendar-year-plus-eight-months pattern. The report on 2026 data is due before 1 August 2027, the report on 2027 data is due before 1 August 2028, and so on.
Five-year record retention applies to the underlying evidence, in alignment with the five-year retention periods set by Delegated Regulation (EU) 2026/296 under ESPR Article 25 and by Implementing Regulation (EU) 2026/2 under Article 24. A brand that filed on 2025 data before 1 August 2026 retains the underlying garment-level and category-level records through to 2031 at minimum.
The 1 August deadline is the load-bearing date each year for any compliance lead at a brand placing apparel on the Dutch market. In 2026 it came just after the ESPR Article 25 destruction ban began to apply to large enterprises on 19 July 2026. The ESPR Article 24 public disclosure runs alongside it, with no fixed publication date until the twelve-month window in Implementing Regulation (EU) 2026/2 takes effect.
Who Besluit UPV Textiel applies to
Producer scope under Besluit UPV Textiel is materially broader than the producer scope under ESPR Article 24. There is no revenue or unit threshold. There is no large-enterprise filter of the kind the ESPR takes from Commission Recommendation 2003/361/EC. Every party placing textile products on the Netherlands market professionally is in scope, irrespective of size.
Territorial reach extends to foreign producers. A brand based in the United Kingdom, the United States, or any non-EU jurisdiction that sells apparel into the Netherlands through owned e-commerce, direct wholesale to Dutch retailers, or direct retail presence is in scope. Foreign producers selling directly to Dutch consumers must appoint a Dutch authorised representative who registers with Rijkswaterstaat on the producer’s behalf, unless they join a producer responsibility organisation, which then files for them. The operational reference for the authorised representative requirement sits on business.gov.nl.
Product scope is set by CN code. Consumer clothing and workwear sit under CN 61 and CN 62. Household textiles sit under CN 6302. The scope does not currently extend to footwear or leather goods. A brand whose Dutch market range includes leather handbags, leather jackets falling outside CN 61 and 62, or footwear lines should treat those items as outside Besluit UPV Textiel reporting while remaining inside any applicable ESPR disclosure.
Brand-level scope reconciliation matters here. A brand at the large-enterprise threshold under Commission Recommendation 2003/361/EC placing both apparel and leather goods on the Dutch market files the Article 24 disclosure on the union of EU-wide scope categories, while filing the Rijkswaterstaat report only on the CN 61, CN 62 and CN 6302 portion. The two reporting obligations cover overlapping but non-identical product sets.
The data Rijkswaterstaat requires
The annual report to Rijkswaterstaat covers volumes placed on the Dutch market by category, volumes collected from the Dutch market, volumes prepared for reuse, volumes reused in the Netherlands, volumes recycled (separating fibre-to-fibre recycling from other recycling routes), and target-attainment evidence against the binding 2025 figures. Documentary support sits behind every figure in the report.
The 2025 binding targets, measured against the weight placed on the Dutch market in the previous year, are: 50 percent prepared for reuse or recycling, of which 20 percent prepared for reuse, of which 10 percent reused in the Netherlands, with 25 percent of what is recycled going to fibre-to-fibre recycling. The targets escalate year on year through 2030, reaching 75 percent prepared for reuse or recycling, 25 percent prepared for reuse, 15 percent reused in the Netherlands, and 33 percent of recycling going fibre-to-fibre on 2030 data.
| Function | Body | Role |
|---|---|---|
| Registration | Rijkswaterstaat | Administers the national register of textile producers and authorised representatives |
| Reporting | Rijkswaterstaat | Receives the annual report before 1 August each year on prior calendar year |
| Enforcement and inspection | ILT (Inspectie Leefomgeving en Transport) | Inspects compliance, acts on reports of unregistered businesses, enforces under the Wet milieubeheer |
| Underlying authority | Wet milieubeheer; Algemene Maatregel van Bestuur (Staatsblad 2023 No. 132) | Statutory basis |
Eco-modulation and the PRO route
A producer registers either directly with Rijkswaterstaat or through one of three PROs. The largest is Stichting UPV Textiel, initiated by Modint and INretail and founded in 2022. The second is European Recycling Platform Netherlands (ERP NL). The third is Collectief Circulair Textiel (CCT), whose board was appointed at the end of 2024 with operational scale-up running through 2025. The three operate at different stages of operational maturity; CCT is the newest entrant and has not yet reached the scale of Stichting UPV Textiel or ERP NL.
Eco-modulation applies through PRO fee structures. A producer placing more durable, more recyclable, or more reuse-ready product faces a different fee scale to a producer placing fast-moving low-recyclability stock. The detail of the fee scale sits under each PRO. The underlying framework is the Besluit UPV Textiel target system, with PROs setting fees in line with their members’ aggregate performance against the binding targets.
The Beleidsprogramma circulair textiel 2025-2030, published by the Ministerie van Infrastructuur en Waterstaat in December 2024, signals intent to amend Besluit UPV Textiel as the revised Waste Framework Directive (Directive (EU) 2025/1892) transposes. Footwear scope is expected to be added under the revised framework, with Dutch transposition due by 17 June 2027 and a national EPR scheme operational by 17 April 2028.
How UPV Textiel interacts with EU ESPR
Besluit UPV Textiel and ESPR are different regimes running in parallel. UPV Textiel is national, single-market, with annual reporting to Rijkswaterstaat before 1 August on prior calendar year. ESPR Article 24 is EU-wide public disclosure under Regulation (EU) 2024/1781, with the format set by Implementing Regulation (EU) 2026/2 and the ten derogations set by Delegated Regulation (EU) 2026/296. ESPR Article 25 is the EU-wide destruction ban, applying from 19 July 2026 to large enterprises and from 19 July 2030 to medium enterprises.
A brand placing apparel on the Dutch market that meets the large-enterprise threshold under Commission Recommendation 2003/361/EC therefore runs three obligations on substantially the same operational data. It files the Rijkswaterstaat report before 1 August each year on the prior calendar year. It has operated under the Article 25 destruction ban since 19 July 2026. It publishes an annual Article 24 disclosure, the first covering FY 2025 for calendar-year reporters. Each obligation reports a different cut of the same underlying garment flow.
National regimes elsewhere in Europe run on their own timelines. The Loi AGEC brought the French national destruction ban into force on 1 January 2022, with Refashion as the producer responsibility organisation. The revised Waste Framework Directive carries a transposition deadline of 17 June 2027 across the EU. A brand operating in four or five EU jurisdictions runs four or five national regimes alongside the EU-wide Article 24 disclosure.
Enforcement risk
ILT runs an inspection-led enforcement model under Besluit UPV Textiel. The simplest exposure is non-registration. ILT accepts citizen and competitor reports of unregistered businesses placing textiles on the Dutch market, and the national register at Rijkswaterstaat is a public-facing record. A brand selling apparel into the Netherlands but not appearing on the register is publicly visible as a likely unregistered producer, regardless of whether ILT has opened a file.
Penalties sit under the Wet milieubeheer enforcement regime. There is no published Tier 1 penalty schedule specific to Besluit UPV Textiel itself. Penalties for non-registration, non-reporting, or under-reporting are set under national law and applied by ILT in line with its broader environmental enforcement framework. A brand operating without registration or without filing the annual report is exposed both to formal enforcement and to the reputational read across the public register.
What audit-trail readiness looks like for UPV Textiel
A defensible UPV Textiel report rests on per-garment records inside the Dutch recovery flow, not on category-level aggregates extracted from third-party logistics invoices or general-ledger write-off entries. The record set required to evidence the 2025 binding targets is unit-level: garment identifier at SKU and unit level, inspection record at arrival, treatment performed (cleaning and conditioning, then any repair where applicable), disposition decision (preparation for reuse, reuse in the Netherlands, fibre-to-fibre recycling, other recovery, or disposal), and recipient correspondence where the garment leaves the brand’s ownership.
The 2025 target lines themselves are per-garment disposition fractions. 50 percent prepared for reuse or recycling, 20 percent prepared for reuse, 10 percent reused in the Netherlands, and 25 percent of recycling going fibre-to-fibre. Without per-unit evidence behind each disposition decision, the targets cannot be evidenced and the Rijkswaterstaat filing cannot be verified. A 3PL monthly volume report by category, a general-ledger write-off, or a jobber invoice tagged “miscellaneous unsold stock” each fail the verification test on the same point.
The 10 percent reuse-in-the-Netherlands target line is structurally in-market. A garment reused in Germany or Belgium does not count toward it. A return generated in Amsterdam and recovered inside Opera Garment Solutions’ Dutch operations sits at unit level in the record set Rijkswaterstaat will read. Inspection, treatment and disposition decisions are captured at the garment, in the market where the garment was sold, against the 10 percent reuse-in-the-Netherlands target line under the 2025 binding figures. For the deeper view on this operational pattern, see in-market recovery.
Frequently asked questions
What is Besluit UPV Textiel?
Besluit UPV Textiel is the Dutch decree on extended producer responsibility for textiles, published in Staatsblad 2023 No. 132 on 21 April 2023 as an Algemene Maatregel van Bestuur under the Wet milieubeheer. It entered into force on 1 July 2023.
When did Besluit UPV Textiel enter into force, and when are reports due?
The decree entered into force on 1 July 2023. Producers have filed a report on every calendar year since 2023. The report on 2025, due before 1 August 2026, was the first to report against the targets. Annual reports follow on the same calendar-year-plus-eight-months pattern.
Who does UPV Textiel apply to?
Every party placing textile products on the Netherlands market professionally is in scope, with no revenue or unit threshold. Product scope covers consumer clothing and workwear (CN 61 and CN 62) and household textiles (CN 6302). Foreign producers must appoint a Dutch authorised representative unless they join a producer responsibility organisation.
Does UPV Textiel apply to UK or US fashion brands selling into the Netherlands?
Yes. A UK or US brand selling apparel into the Netherlands via owned e-commerce or direct wholesale is in scope. The brand must appoint a Dutch authorised representative who registers with Rijkswaterstaat on its behalf, unless it joins a producer responsibility organisation, which then files for it.
What data does Rijkswaterstaat require for UPV Textiel?
The annual report covers volumes placed on the Dutch market by category, volumes collected, volumes prepared for reuse, volumes reused in the Netherlands, volumes recycled (fibre-to-fibre and other), and target-attainment evidence against the binding 2025 figures. Documentary support sits behind each figure.
What is the difference between Rijkswaterstaat and ILT?
Rijkswaterstaat, under the Ministry of Infrastructure and Water Management, administers the national register and receives the annual report. ILT (Inspectie Leefomgeving en Transport) is the inspection and enforcement regulator, acting under the Wet milieubeheer enforcement regime.
What are the UPV Textiel 2025 binding targets?
Producers must achieve 50 percent prepared for reuse or recycling, of which 20 percent prepared for reuse, of which 10 percent reused in the Netherlands, with 25 percent of recycled textiles going to fibre-to-fibre recycling, measured against the weight placed on the market in 2024 and reported to Rijkswaterstaat before 1 August 2026.
What is Stichting UPV Textiel?
Stichting UPV Textiel is the largest of three PROs operating under Besluit UPV Textiel, initiated by Modint and INretail and founded in 2022. The other two are European Recycling Platform Netherlands (ERP NL) and Collectief Circulair Textiel (CCT).
How does Besluit UPV Textiel interact with ESPR?
Besluit UPV Textiel is national and ESPR is EU-wide. They run in parallel. A large enterprise placing apparel on the Dutch market files the Rijkswaterstaat report before 1 August each year, has operated under the Article 25 destruction ban since 19 July 2026, and publishes an annual Article 24 disclosure, the first covering FY 2025.
Close
The Rijkswaterstaat report is due before 1 August each year, and the report on 2026 data falls due before 1 August 2027. ESPR Article 25, the EU-wide destruction ban for large enterprises, has applied since 19 July 2026. ESPR Article 24, the EU-wide public disclosure, covers FY 2025 onwards for calendar-year large enterprises. Three regulatory obligations on substantially the same operational data. Opera Garment Solutions runs garment returns recovery as a single point of access to a network of professional garment care experts, with per-garment records held in the market where the garment was sold.
( 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.