FDSE AB
The Sustainable Fashion Academy
The mission of The Sustainable Fashion Academy (SFA) is to accelerate progress to science-based sustainability targets and global sustainability goals by leveraging the power and influence of the fashion and apparel industry.
ID: 030017691884-31
Lobbying Activity
Response to Circular Economy Act
5 Nov 2025
The upcoming Circular Economy Act presents a pivotal opportunity to accelerate the transition toward circular business models by creating a compelling business case for companies to invest in circularity. By offering targeted incentives and removing structural barriers, the Act can drive meaningful change across industries, particularly in textiles and footwear. To ensure the Act delivers on its potential, SFA recommends the following key measures to be included: 1. Introduce Targeted Financial Incentives Rewarding Circular Products and Services: Lower or remove VAT rates for second-hand goods, recycled materials, and circular services such as repair and resale. Simultaneously, introduce a tax on virgin fibres to discourage resource-intensive production. Exemptions could apply for virgin fibres with demonstrably low environmental impact, such as sustainably sourced bio-based materials. Extended Producer Responsibility (EPR) schemes should also be leveraged to support reuse and repair. Companies offering resale and repair services could benefit from reduced EPR fees or targeted bonuses. Additionally, a portion of EPR revenues could be allocated to dedicated consumer-facing initiatives, such as garment repair funds, that directly extend product lifespans. 2. Mandate Green Public Procurement Criteria for Textiles: Establish clear, enforceable, and measurable sustainability criteria for public procurement of textile products to stimulate demand for circular goods and services. 3. Strengthen Extended Producer Responsibility (EPR) Schemes: Ensure that EPR fees fully cover the end-of-life costs of textile and footwear products and introduce eco-modulation criteria that reward circular practices, such as repair services, reuse, and resale. 4. Harmonize EPR Compliance Across Member States: Reduce administrative burdens by aligning EPR rules and reporting requirements across the EU, enabling smoother compliance for businesses operating in multiple countries. 5. Set EU-Wide Material Footprint Targets to Curb Resource Overconsumption: Establish binding targets to reduce material consumption . Complement these with EPR-linked goals for improving collection, sorting, reuse and recycling rates. For a detailed explanation of the points above, please read the attached document. Feel free to contact us at michael@sustainablefashionacademy.org.
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