Deutscher Textilreinigungs-Verband
DTV
Der DTV vertritt als Arbeitgeber- und Wirtschaftsverband von der traditionellen Textilreinigung bis hin zum industriellen Textildienstleister Unternehmen unterschiedlichster Größe und Betriebsform.
ID: 316037841276-54
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
The German Textile Cleaning Association welcomes the Circular Economy Act. Our position paper addresses 5 key issues that should be tackled: 1. In our view, it is essential that the legislation does not focus exclusively on new circular economy models. Established and economically successful circular business models already exist today and make a valuable contribution to conserving resources. A prominent example is the textile care industry with its textile leasing model. 2. The Circular Economy Act should explicitly address the B2B sector in addition to the consumer market. Circular economy principles can also be applied successfully and profitably in this area, as demonstrated by the textile service industrys Product-as-a-Service business model. 3. Standardisation is an essential governance tool for embedding sustainability requirements throughout supply chains. Service providers such as leasing companies, craft enterprises and textile service or maintenance businesses must be included in this dialogue, particularly for products offered within Product-as-a-Service models. 4. Public procurement represents a key instrument for promoting the circular economy. In the future, every procurement process should be examined to determine whether the demand can be met through circular procurement, taking all sustainable alternatives into account. When evaluating bids, sustainability criteria should not be optional but mandatory. 5. The current focus of Extended Producer Responsibility (EPR) schemes for textiles is largely on the fashion and consumer market. However, the significant B2B textile sector is often overlooked, including workwear, personal protective equipment, and flat linen used in the hospitality, catering and healthcare industries. These textiles are generally provided through textile service companies that lease them to clients in industry, healthcare and hospitality. The core interest of these service providers lies in the durability, reparability and reusability of textiles. Products are only withdrawn from use once they are no longer fit for purpose. Because these textiles are leased directly to customers, there is no need for separate collection or sorting processes. Service providers know precisely where their textiles are located, when they will be returned and what materials they are made of. The EPR framework therefore addresses issues that have long been effectively managed within the B2B textile sector. B2B textiles already achieve the main objectives of EPR resource conservation and waste prevention to a very high degree. Including these textiles within EPR obligations would create additional administrative burdens without delivering environmental benefits. At the same time, the textile services sector has a strong interest in ensuring that B2B textiles are put to meaningful use after the end of their life cycle, for example through recycling. The Circular Economy Act could therefore allow for alternative, self-organised sectoral solutions. Sectors that establish effective collection and recycling systems and meet defined recovery and recycling targets should be eligible for exemption from EPR obligations. Our full position paper can be found in the attachment.
Read full responseResponse to Evaluation of the Public Procurement Directives
7 Mar 2025
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