Primark
Primark is an international clothing retailer, providing sustainable fashion affordable for everyone, with a focus on creating great retail experiences in-store.
ID: 513563750943-13
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
Primark welcomes the Circular Economy Act (CEA) as an important opportunity to strengthen Europes transition to a more circular and resource efficient economy. We believe the CEA can help create a coherent and harmonised EU legislative framework, which if, supported by investment and incentives, can help companies adapt supply chains, invest in circular innovation, and improve competitiveness. Legislation should be proportionate with realistic implementation timelines, supporting the Commissions simplification agenda by reducing administrative burdens, streamlining processes, and avoiding a patchwork of national rules. Harmonisation will help make compliance simpler and consistent across Member States, supporting circularity and business growth while maintaining affordability for consumers. Given that most textiles sold in Europe are sourced and manufactured outside the EU, circularity measures must consider global supply chains. We advocate for a holistic, end-to-end approach linking material recovery, recycling, product design, sourcing, and production. Packaging should also be integrated alongside textiles, as it is often the first material to become waste and plays a critical role in circularity. Key challenges the CEA should address include: inconsistent EPR schemes, the structure and governance of Producer Responsibility Organisations (PROs), divergence in end-of-waste (EoW) criteria, inconsistent waste ownership rules, and varying recycling infrastructures. Harmonised EU rules are critical to ensuring a level playing field, enabling realistic compliance, and delivering measurable circular impact. Primark recommendations: Fully harmonise PRO structures and governance, and transparency across Member States, including packaging, and promote Member State coordination to reduce fragmentation. Develop a digital EU one-stop-shop for producer registration, reporting, and fee payment to simplify compliance and ensure compatibility with national systems. Align eco-modulated fee criteria between the ESPR delegated act for textiles, WFD implementing act, and PPWR. Define EU-wide EoW criteria, establish a single-market approach to waste classification, clarify ownership/responsibility for waste, and ensure consistency between textile and packaging EoW rules. Set fibre-specific, progressive recycled content targets under ESPR with realistic timelines, recognise both post-consumer and post-industrial recycled inputs, and align requirements for textiles and packaging. Promote investment in textile-to-textile recycling and advanced sorting, ensure EPR revenues strengthen circular supply chains, encourage public-private partnerships, and incentivise fibre-to-fibre innovation. Ensure coherence across EU legislation (WFD, ESPR, PPWR, WSR, TLR), advance digitalisation via interoperable tools like the Digital Product Passport, and provide realistic transition timelines for technical and financial feasibility. In conclusion, the CEA presents an opportunity to move from fragmented national measures to a unified, and coherent framework that supports both sustainability and competitiveness across the EU. A proportionate approach will be key to achieving this balance and ensuring an effective Single Market. Success depends on well-functioning, harmonised EPR systems and PROs, clear end of waste criteria sufficient recycling capacity, and coherence between textiles and packaging It is important that this transition remains inclusive and affordable. Ensuring that circularity can be achieved without increasing costs for consumers will help maintain access to affordable, more sustainable fashion for all. A position paper outlining Primarks detailed recommendations is attached.
Read full responseMeeting with Peter Agius (Member of the European Parliament)
1 Apr 2025 · Introduction
Meeting with Anna-Maja Henriksson (Member of the European Parliament)
1 Apr 2025 · Retail
Meeting with Christel Schaldemose (Member of the European Parliament)
1 Apr 2025 · sustainability strategy
Meeting with Seán Kelly (Member of the European Parliament)
28 Jan 2025 · Priorities for the Waste Framework Directive's revision
Meeting with Cynthia Ní Mhurchú (Member of the European Parliament)
28 Jan 2025 · Irish business
Meeting with Billy Kelleher (Member of the European Parliament)
12 Nov 2024 · Sustainability
Response to Revision of EU rules on textile labelling
30 Sept 2023
Primark is an international fashion retailer with over 420 stores across 14 EU member states plus the UK and US and employing more than 70,000 colleagues. Founded in Ireland in 1969 under the Penneys brand, we aim to provide affordable choices for everyone, from great quality everyday essentials to stand-out style for women, men and kids, as well as beauty, homeware and accessories. Primark is working to make more sustainable fashion affordable for everyone and we are committed to the transition towards more circular production and use of clothing and textile products. Our ambition is to give clothing a longer life, protect life on the planet and support the livelihoods of people who make Primark products. As part of this, we have unveiled a series of commitments we are working to achieve by 2030. We welcome the opportunity to comment on the proposal to revise the EU rules on textile labelling as part of the EU strategy for sustainable and circular textiles. Textile labelling requirements need to be harmonised to give consumers clear information. In recent years, labels on clothing have got ever bigger as manufacturers and retailers have tried to provide more information, but some of this is inconsistent and is not necessarily recognised in all territories, which can be confusing. Frequently, the consumer simply cuts the labels off, as they are too big and can become uncomfortable, and then loses all the information. We are also pleased that the review will not be done in isolation and that it will be explored in the context of other recently proposed legislation, particularly the Ecodesign Regulation and the Digital Product Passport (DPP), but also the Waste Framework Directive as it relates to textile waste, the Empowering Consumers Directive, the Directive on Corporate Sustainability Due Diligence (CSDDD) and others. We cannot emphasise enough the importance of a cohesive and consistent approach to policies covered by more than one legislative file to reduce the potential for duplication and/or fragmentation of requirements. We believe that the DPP should be used to fulfil many of the requirements of the Textiles Labelling Regulation (TLR) to keep to a minimum the information required on physical labels. This will make physical labels easier to read and make it less likely that consumers will remove them. It also supports international businesses that have to incorporate other territories labelling requirements. That said, businesses will need time to invest in the systems changes necessary to enable digital labelling, as the platforms used by many websites are not currently flexible enough. The TLR should address the need for better classification of new and novel fibres, many of which are not covered by existing fibre classifications and have to be classified as other, eg man-made cellulosic fibres (MMCF). Many of these include fibres produced through more environmentally friendly and sustainable manufacturing processes. It would be helpful if Annex I could also show HS or CN codes to assist with the classification for customs and other purposes of products made from these fibres. Ideally this should be agreed at the World Customs Organisation as part of its ongoing work on HS codes. However, the EU could use TARIC codes to identify products made of such fibres and, longer term, incentivise their use by reducing the applied duty rate. Exemptions for labelling requirements should be maintained but the list should be less prescriptive to enable product information to be supplied on the packaging where it is not practicable to add a label or print the information, eg socks. We support the concept of digital labelling of product information and the contribution this could make to the green transition. However, as noted above, it is important that the requirements of TLR are aligned with those of DPP to create a coherent policy. We recognise that some consumers prefer physical labels but we do not see any need to
Read full responseMeeting with Barry Andrews (Member of the European Parliament, Rapporteur for opinion)
15 Sept 2023 · CSDDD