In its second position paper, The T2T Alliance – comprising new feedstock developers Circ, Circulose, Re&Up, Recover, Samsara Eco and Syre – is urging the European Union to speed up legislation that will meaningfully support a transition to a circular textile economy.

It is calling for the textile recycling sector to be explicitly included within the scope of the Circular Economy Act on the grounds that textiles remain largely trapped in a linear model characterised by low recycling rates, weak demand for high quality recycled material, cheap and abundant virgin fibres and underdeveloped waste management infrastructure.

Without decisive intervention, the conditions required for genuine textile circularity will not materialise.

At the heart of the Alliance’s position is the need to establish a stable and functional single market for secondary textile materials. To achieve this, it highlights three interlinked priorities – legislative harmonisation, encouraging stronger market demand for recycled content and targeted financial support across the recycling value chain.

Harmonisation

Firstly, the harmonisation of legislation affecting textile recycling is believed critical in order to improve access to feedstock and enable the free movement of secondary materials.

End-of-Waste (EoW) criteria are poorly aligned with operational reality because they classify feedstock as waste until after recycling has taken place, exposing recyclers to restrictive permitting, storage and transport rules. This creates unnecessary barriers to scaling the sector and discourages the cross-border movement of valuable materials. The Alliance therefore proposes the development of functional, industry-informed EoW criteria supported by a comprehensive impact assessment that clarifies how these rules interact with wider waste and shipment legislation.

In parallel, it highlights the need to reform Extended Producer Responsibility (EPR) funding models.

Current EPR schemes largely prioritise collection and reuse, despite evidence that the European reuse market is oversaturated and that large volumes of exported textiles end up as unmanaged waste in destination countries. The Alliance argues that recyclers and pre-processors receive insufficient financial support, undermining the development of closed-loop systems. It is calling for clearer guidance to ensure EPR funding is redirected towards recycling activities and for a formal definition of ‘preparing for recycling’ so that essential processes such as de-trimming, shredding and specialised sorting are properly recognised and funded.

The Alliance also identifies regulatory fragmentation as a significant obstacle to progress. Inconsistent classification of feedstock between Member States, complex reporting requirements and delays in implementing eco-modulation criteria are all cited as factors that increase costs and are slowing industry growth. Streamlining these frameworks is seen as critical to creating a resilient, self-sustaining textile recycling value chain.

Mandaory content

Secondly, the Alliance stresses that circularity cannot be achieved without a significant increase in demand for secondary materials. It is advocating for the introduction of mandatory recycled content requirements for both public and private sectors, including closed-loop recycled material thresholds in green public procurement and ambitious performance targets under the Ecodesign for Sustainable Products Regulation for textiles.

These measures are viewed as essential to providing predictable demand, encouraging investment and enabling the sector to scale at the pace required to meet European sustainability objectives.

Intervention

Finally, the Alliance is calling for immediate fiscal intervention to prevent further collapse within the textile waste management sector, noting that recent bankruptcies and operational shutdowns signal a system under severe strain. It proposes the creation of a dedicated Circular Economy Fund to provide short-term financial relief and investment stability for recyclers. Alongside this, it advocates targeted fiscal tools to close the persistent cost gap between virgin and secondary materials, such as feed-in tariffs, rebates or reduced VAT rates. Time-bound support of this nature is seen as essential to creating a level playing field as the market matures and demand stabilises.

Overall, the T2T Alliance presents a clear case for coordinated regulatory reform, structured financial support and demand-side incentives as the foundation for a genuinely circular textile economy. It positions these measures not as optional enhancements but as critical mechanisms to safeguard the sector, foster innovation and secure Europe’s long-term competitiveness in sustainable textiles.

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