Confindustria Toscana Nord
CTN
Confindustria Toscana Nord (CTN) è una associazione di imprese industriali autonoma, apartitica, senza fini di lucro; ha sede operativa nelle province di Lucca Pistoia e Prato (Toscana), orienta ed ispira i propri comportamenti organizzativi e le proprie modalità di funzionamento al Codice Etico e dei Valori Associativi di Confindustria.
ID: 009832643638-02
Lobbying Activity
Response to Derogations to the prohibition of the destruction of unsold Apparel and Footwear
1 Aug 2025
The draft regulation states that "the reuse of these products is always the best environmental solution compared to recycling or other forms of destruction". While the priority of reuse is correct, grouping 'recycling' and 'destruction' together is a conceptual error that contradicts the European Union's own waste hierarchy (Directive 2008/98/EC), which places recycling on a higher level than energy recovery and disposal (destruction). Unsold products, especially those made of noble fibres like wool and cashmere, are not "waste to be destroyed" but valuable raw materials for the industry. Accessing this raw material only through the complex and burdensome derogation procedures intended for damaged or non-compliant products would nullify circular industrial models. The Delegated Act must unequivocally clarify that, for unsold products unsuitable for reuse, recycling is the mandatory preferred pathway over destruction. The hierarchy should be: 1st Reuse, 2nd Recycling, 3rd Destruction (as a last resort). We also propose introducing a new derogation, separate from those related to defects or hazards, that can actively support the recycling value chain. This derogation could be justified as follows: "Sending unsold products for recycling shall be permitted where the economic operator can demonstrate that they will be transformed into secondary raw material intended to substitute virgin raw material in the production of new goods. This option is particularly encouraged for textile fibres whose recycling allows for a significant environmental benefit, reducing the impact associated with the production and import of virgin fibres from non-EU regions." This derogation would not only resolve the current paradox but would also create a positive incentive. In conclusion, we ask that the Delegated Act recognise the strategic value of textile recycling. Treating it as an exception rather than a priority would be an own goal for the European circular economy. Also, the derogation allowing the destruction of damaged goods when repair is not "cost-effective" creates a systemic disadvantage for producers of high-quality, durable products. This criterion disproportionately burdens companies that invest in quality, as their products are more likely to be deemed worth repairing, thus increasing their operational costs for handling and mending. In contrast, it offers a simpler path for the destruction of low-value, less durable items, for which repair is rarely economical. This approach disincentivises the production of durable and repairable goods, directly contradicting the ESPR's goals of creating a more sustainable market.
Read full responseResponse to Sustainable Products Initiative
22 Jun 2022
Confindustria Toscana Nord, follows with particular attention the roadmap on the 'Sustainable Product Initiative' published by the European Commission. In fact, the Prato area is home to the largest textile cluster in Italy and Europe, which has been based on a circular business model for centuries. This is why it is important that the considerable change in the business model of the textile industry is designed taking into account the existing virtuous circular business models, favouring their development in the EU. We wish that the European Commission takes into account Prato's production system, which is rich in expertise and technical knowledge, as a pilot example at the European level to verify the technical feasibility of requirements that will be included in the new legislation.
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