Amendment to the Waste Framework Directive: measures to restrict fast fashion and to combat food waste.

In a blog in 2023, about the Dutch Extended Producer Responsibility Textiles Decree (hereinafter: EPR Textiles Decree), we mentioned the European Commission's proposal of 7 July 2023 to amend the European Waste Framework Directive (hereinafter: WFD). Directive (EU) 2025/1892 amending the WFD was adopted on 9 September 2025 and entered into force on 16 October 2025. Below, we describe the amended WFD and compare it with the EPR Textiles Decree.

The amendment to the WFD concerns two topics: textiles and food. For both topics, the European legislature emphasises that the European Green Deal and the Circular Economy Action Plan call for strengthened and accelerated action by the EU and Member States to ascertain the ecological and social sustainability of the textile and food sectors.  Both are among the sectors that consume the most resources and cause significant negative environmental externalities, according to the recitals to the amendment. The amended WFD contains rules designed to restrict the fast fashion industry and to combat food waste. 

Textiles

According to the amended WFD, Member States must set up EPR schemes for producers of textile, textile-related and footwear products. Under these schemes, producers bear the costs and responsibility for collecting, sorting and preparing these products for reuse or recycling. Producers must make a financial contribution to a producer responsibility organisation, which, among other things, sets up a system for the collection of textile waste and selects waste managers to process the textile waste.

The EPR applies to clothing, blankets, table, bed and household linen, curtains, hats, clothing and accessories made of leather or imitation leather, and various types of footwear. The complete overview can be found in Annex IV quater of the amended WFD. There is considerable overlap with the application of the EPR Textiles Decree, but there are also differences. For example, the European EPR applies to blankets, while the Dutch EPR does not, as stated in the explanatory notes to the EPR Textiles Decree. 

Unlike the EPR Textiles Decree, the amended WFD does not set targets for a specific weight percentage of textile waste that must be prepared for reuse or recycled. However, producer responsibility organisations (see below) must report how much is actually recycled or reused in practice. The preamble to Directive (EU) 2025/1892 states that the Ecodesign Regulation will set design requirements for textiles that should increase the recyclability and reusability of textiles. These requirements are still being drawn up. See also our previous blog about the Ecodesign Regulation.

The preamble states that producer organisations must ensure that textiles are reused as much as possible. To this end, the Commission will develop end-of-waste criteria which should determine that collected textile waste that has been assessed by a professional as suitable for reuse should not be considered waste.

Mandatory implementation by producer responsibility organisations

According to the amended EPR, Member States must acsertain that textile producers appoint a producer responsibility organisation to fulfil the EPR obligations on their behalf. According to the amended WFD, this is necessary to reduce administrative burdens. 

This deviates from the main rule of the WFD, which assumes that the producer may choose to transfer responsibilities to a producer organisation. The preamble to the amendment to the WFD shows that the European legislature deliberately opted for more detailed and harmonised rules for EPR for textiles. The amended WFD thus deviates from the EPR Textiles Decree, in which textile producers can choose to fulfil their responsibilities themselves. The EPR Textiles Decree is therefore at odds with the amended WFD.

The concept of a 'producer responsibility organisation' is new in the WFD and is defined as a legal entity that arranges the fulfilment of EPR obligations on behalf of producers, either financially or organisationally. This definition does not explicitly state that when a producer organisation fulfils obligations on behalf of a producer, the producer itself is no longer responsible for fulfilling these obligations. Dutch law does explicitly arrange this, in the Decree on Extended Producer Responsibility Regulations. Although it is not explicitly stated in the amended WFD, this seems to us to be the most obvious interpretation of the WFD. 

The producers make a financial contribution to the producer organisation. This financial contribution is based on the weight of the textile waste and, where possible, also on requirements based on the Ecodesign Regulation which are relevant to the prevention of textile waste and that guarantee the ecological sustainability and circularity of the products.

Food 

The amended WFD requires Member States to take measures to prevent food waste throughout the food supply chain. The entire chain extends from primary production and the manufacturing and processing industry to retail, distribution, restaurants, catering and ultimately households. 'Food' refers to all substances and products, processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans (see the definition in Regulation (EC) 178/2002).

The amended WFD states both the minimum measures that must be taken and the objectives that should be achieved. The measures and objectives are aimed at reducing food waste and thereby achieving positive environmental effects. 

Objective

Member States must take appropriate measures to achieve two specific objectives by 31 December 2030:

1. Food waste production in the processing and manufacturing industry must be reduced by 10% compared to the average amount of food waste produced per year between 2021 and 2023;
2. Per capita food waste generation in retail, other food distribution, restaurants, catering services and households must be reduced by 30% compared to the average annual food waste generated between 2021 and 2023. 

For the second target, a target expressed as a percentage change in per capita waste levels has been deliberately chosen to take account of demographic changes. In addition, the amended WFD includes a correction mechanism for tourism: the European Commission will establish a correction factor to take account of the increase or decrease in tourism compared to the reference year.

In order to achieve these targets and verify compliance, it is of course important to use a uniform measurement method to determine how much food waste Member States produce each year. This method is set out in Delegated Decision (EU) 2019/1597 on a common methodology and minimum quality requirements for the uniform measurement of levels of food waste. On the basis of this Delegated Decision, Member States have been measuring the quantities of food they produce since 2020. 

Measures

The WFD states the minimum elements that measures to reduce food waste must contain. These elements are as follows:

• behavioural change interventions to reduce food waste and information campaigns to raise awareness about food waste prevention;
• identifying and addressing inefficiencies in the functioning of the food supply chain, and supporting cooperation amongst all actors, ensuring a fair distribution of the costs and benefits of prevention measures;
• encouraging food donations and other redistribution for human consumption;
• supporting training and skills development and facilitating access to funding opportunities, in particular for small and medium-sized enterprises and social economy entities;
• encouraging and promoting innovation and technological solutions which contribute to the prevention of food waste;

The amended WFD leaves much room for Member States to shape the measures themselves. The preamble to Directive (EU) 2025/1892 does note that Member States' measures to prevent food waste have so far focused mainly on awareness and not yet on promoting behavioural change. The amended WFD encourages measures that go further and actually lead to behavioural change and a reduction in food waste. The specific objectives should help to achieve this. Some suggestions for measures mentioned in the preamble include solutions for improving packaging so that food is not unnecessarily discarded, or solutions for stating use-by dates more accurately and clearly on packaging. 

Conclusion

Member States have 20 months – until 17 June 2027 – to comply with the directive. The amended WFD harmonises the rules for EPR for textiles. This gives Member States less discretion to design their EPR schemes for textiles. In Dutch law, amendments to the EPR Textiles Decree will probably be necessary to align with the amended WFD. In practice, it is therefore highly desirable for the Dutch government to announce soon which amendments to the EPR Textiles Decree are envisaged. Textile producers in the Netherlands would be advised at this stage to compare the amended WFD with the EPR Textiles Decree and to take into account possible changes in Dutch legislation. The preamble to Directive (EU) 2025/1892 further states that eco-design rules and end-of-waste criteria are still being developed at European level to promote the reuse and recycling of textiles.

Unlike the rules for textiles, the amended WFD does not specifically prescribe which measures Member States must take to reduce food waste. The WFD prescribes elements that the measures must contain, but leaves much room for Member States to shape the measures themselves. At first glance, these elements appear to be mainly policy-related. However, the concrete targets ensure that Member States actually take effective measures that lead to behavioural change.