New registration obligation for packaging in Spain

The Spanish packaging law obliges producers to register their packaging. Distributors from abroad must also register through an authorised representative if they sell packaged products in Spain.

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General Product Safety Regulation (EU) 2023/988 obliges
GPSR Risk Analysis Required

Mandatory for almost every product: According to the GPSR, producers must draw up technical documentation for the products they place on the market. The technical documentation must be based on an internal risk analysis.

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General Product Safety Regulation requires Responsible Person
EU Responsible Person Service for the GPSR and more

Since 16 July 2021, it is against the law to sell products with CE marking without a Responsible Person in the EU. In addition, a Responsible Person must also be specified in accordance with the General Product Safety Regulation (EU) 2023/988.

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Personal EU Batteries Regulation Training
Ready for the new Batteries Regulation (EU) 2023/1542

Find out which obligations the EU Batteries Regulation places on you and how to deal with them in your specific case. Receive comprehensive information on how to implement your obligations with regard to labelling, battery passport, EPR and due diligence obligations in the supply chain.

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Is cotton recyclable?

The EU Commission has denied a de jure cotton ban until 2030. However, existing and future EU legislation to improve the circular economy and sustainability may affect cotton like all other textile products. The question is: is cotton recyclable?

At the turn of the year, numerous reports about a possible cotton ban attracted public attention (trade-e-bility reported: Cotton ban by 2030?). The EU Commission has since responded in a report: “EU ban on cotton is not in sight“. ‘Fact checkers’, who have reconstructed the course of events of the information spread, see, among other things, a report by Fashion United as the crux of the debate. However, the fact check also comes to the conclusion: Nowhere in the article is it definitively stated that a ban on cotton is actually planned, says DPA Factchecking.

While the debate revolves around the term “cotton ban” and various pieces of legislation that have little or nothing to do with textile recycling requirements, a remarkable statement in the Commission's statement is overlooked: Existing and future EU legislation to improve the circular economy and sustainability may therefore affect cotton in the same way as all other textile products placed on the EU market.

It is worth taking a look at an article by Fashion Power from August 2024, which is also considered to be one of the key sources on the topic. The article “Cotton: A Material Without a Future?“ states in part on the recyclability of cotton:

“Even if all that were to work, the biggest problem remains unsolved; cotton is not circular. It is not now, and it will not be for the foreseeable future. This is because cotton is a weak fiber, contributing significantly to the microfiber problem.”

The text also sheds light on the origin of the recycling rates attributed to numerous EU reports:

“By 2025, 50% of the clothing we bring to market must be recyclable, and half of that must be circular, from clothing to clothing. This specifically applies to the Netherlands, as Europe expects this by 2030.”

When researching these figures, the following is found:

By the year 2030, all textile products sold on the Dutch market should contain at least 50 percent sustainable material, of which at least 15 percent should be fibre-to-fibre recyclate from the post-consumer sector. (Source: Euwid). Further details on this topic can be found in the Beleidsprogramma circulair textiel 2025–2030 (Circular Textile Policy Programme 2025-2030) of December 2024 and in the Decree of 14 April 2023 regulating extended producer responsibility for textile products (Decree on Extended Producer Responsibility for Textiles) from the Staatsblad van het Koninkrijk der Nederlanden.

The European Parliament resolution of 1 June 2023 on an EU Strategy for Sustainable and Circular Textiles (2022/2171(INI)) “Acknowledges the urgency of ensuring that textile products placed on the EU market are long-lived, reusable, repairable, recyclable, made to a great extent of recycled fibres, and free of hazardous substances; underlines that textile products should be produced in a way that respects human and social rights, the environment and animal welfare”.

The Union strategy “Expresses its concern that the measures identified in the EU Strategy might not be sufficient to fulfil the 2030 objective and calls on the Commission to ensure all necessary measures, including additional legislative and non-legislative measures to those identified in the strategy, are taken to achieve the 2030 vision expressed in the Textiles Strategy; underlines that the adopted measures should prioritise waste prevention in line with the waste hierarchy”.

trade-e-bility textile expert Anika May advises caution with the term ‘cotton ban’, as there are already methods and further efforts to make cotton recyclable. And work is also being done to make cotton fibres longer so that they can be recycled for longer.

In view of the divergent expert opinions, the crucial question for assessing a possible “de facto ban on natural cotton” is: Is cotton recyclable?

trade-e-bility will be happy to answer any questions you may have about cotton or the recyclability of textiles: +49/40/750687-300 or sales@trade-e-bility.de.

Sebastian Siebert
Contact

Sebastian Siebert
Head of Advisory services

Phone: +49 40 750687-0

beratung@take-e-way.de

Christoph Brellinger
Contact

Christoph Brellinger
Head of Marketing & Public Relations

Phone: +49 40 750687-0

presse@take-e-way.de

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