As was mentioned earlier the ideal approach would be to structure the platform based on the CPA model but specialized by strategic couples. This would involve different subjects and working groups dedicated to key areas, with a particular focus on polyester and polyester/cotton (polycotton) recycling which are the most significant and rapidly growing materials in the textile industry.

In the CPA (Circular Plastics Alliance), the PET packaging sector successfully addressed key issues such as standardization—something that was difficult to tackle amongst ourselves within our broader value chain. The monitoring efforts were also highly effective, even though DG ENV ultimately chose a different approach. Nevertheless, the work accomplished was outstanding and remains in operation today.

Now, concerning the Textile Ecosystem Platform and the challenges the industry will encounter as the EU Commission regulates the textile sector without fully accounting for the complexities of scaling up the polyester textile value chain, effective compliance will require seamless coordination across collection, sorting, preparation for recycling, and the recycling processes themselves. As a result, the responsibility for implementation will fall on individual member states and their respective EPR systems which is , even though necessary,  not in our opinion an ideal way.

In effect, simply replicating the EPR-based packaging directive cannot not be totally effective, as its limitations have already been observed in that sector. This is precisely why, for example, PETCORE EUROPE, brand owners, and NGOs have successfully advocated for the Deposit Return System (DRS): it is an harmonized route where each container is individually accounted for, unlike curbside collection, where tonnage, quality of the sorting and yield calculations vary across countries, resulting to minimum 90% PET bottles collection rate.  

A similar approach cannot be adapted  as such for polyester textiles but if some regulations are not let to member states and EPR’s only and can be harmonized for a BETTER coordination of the polyester value chain the success.

In other terms to avoid repeating the mistakes made in the early stages of PET packaging regulations, we must harmonize both regulated and non-regulated actions as much as possible. Some key priorities include:

  • Reducing administrative burdens related to End-of-Waste and/or other regulations.
  • Developing a Brussels based polyester and polycotton recyclability evaluation platform, similar to the EPBP initiative for PET packaging.
  • Establishing a hazardous waste platform to manage risks effectively.
  • Defining harmonized sorting criteria for:
    • Reuse
    • Repair
    • Recycling where sorting guidelines have already been initiated by Petcore Europe, big sorting centers could help considerably competitiveness by  hundreds of € per ton, same for preparation centers and a wide scale recycling plants.
  • Transitioning from an informal and cash-based industry to a fully documented and optimized system through adapted automatic and non-automatic sorting centers that align with the EU market size. It is a priority but how is it possible?

Additionally, it is crucial to recognize that Europe's textile sector struggles to compete with China and the USA due to its fragmentation. In China, 80% of PET production is controlled by just four companies, while in the USA, three firms dominate the market. In contrast, Europe’s industry is divided among five or six smaller producers, making it less competitive, energy costs being just one factor among many. Do we  not want challenge them as we start textiles recycling? Can Europe not be more ambitious?

In Summary, Establishing an EU Platform for Polyester would be highly beneficial in helping the EU Commission navigate the complexities and challenges—both technical and financial—associated with polyester. It would also contribute to the development of more effective, harmonized regulations.

At last,  the platform could play a crucial role in coordinating the scaling up of an EU-based  harmonized system for polyester collection (the most challenging aspect), sorting (the most straightforward), preparation for recycling, and recycling itself.