REUP Technologies Holding BV
REUP
REUP Technologies is a recycling company with capabilities of recycling post and pre-consumer textile waste into Next-Gen recycled cotton fibers and recycled polyester chips.
ID: 644416194757-17
Lobbying Activity
Response to Circular Economy Act
31 Oct 2025
RE&UP Technologies, a textile-to-textile recycling company based in the Netherlands, welcomes the European Commissions initiative for the Circular Economy Act (CEA) and strongly supports a harmonised, market-enabling legislative framework to accelerate the transition towards a circular and resource-efficient economy in Europe. The CEA represents a crucial opportunity to strengthen the internal market for secondary raw materials, remove existing regulatory barriers, and support industrial competitiveness in the circular economy. 1. Harmonised regulation across the EU RE&UP supports converting the Waste Framework Directive (WFD) into a Regulation to ensure uniform implementation across all Member States. A harmonised approach to Extended Producer Responsibility (EPR), separate collection, sorting, and recycling targets for textiles is essential to prevent market fragmentation and achieve circularity at scale. An EU-level product and waste registry, linked to mapped recycling facilities, should facilitate cross-border shipment of sorted textile waste, support regional circularity hubs, and promote transparency. Binding EU-wide targets for collection, sorting, and recycling would ensure effective implementation. In parallel, the End-of-Waste (EoW) criteria and by-product definition should be harmonised and include a fast-track mechanism to recognise innovative textile recycling technologies. 2. Lack of targeted trade codes for waste shipments and recycled materials The absence of specific EU and international trade codes for textile waste destined for recycling and for recycled textile materials continues to hinder circular trade. The List of Waste should be updated to include clear codes for textile waste for recycling. At the international level, dedicated HS sub-codes (e.g. for recycled cotton and recycled polyester) should be established to distinguish recycled from virgin materials. This would improve traceability, enable data-driven policymaking, and facilitate legitimate circular trade flows while maintaining environmental safeguards. 3. Economic incentives and funding A stable and predictable economic framework is essential to attract investment in circular technologies. The EU should establish a Circular Economy Fund to de-risk innovation and scale circular solutions, complemented by long-term fiscal incentives, such as tax reductions or VAT exemptions for products containing recycled materials. Support for labour-intensive waste management activities should be introduced to strengthen local economies and social sustainability. Concurrently, disincentives for landfilling and incinerating recyclable textiles should redirect materials towards reuse and recycling. Transparent tracking of EPR financial flows, with due regard to commercial confidentiality, would ensure accountability and fair distribution of resources. 4. Public procurement as a market driver Public procurement should be leveraged to create demand certainty for recycled materials. The EU should establish minimum recycled content requirements for textiles in procurement processes, supported by robust and harmonised verification mechanisms. Procurement criteria should focus on repairability, recyclability, and recycled content, rather than durability alone. Textiles should be prioritised within CEA-related procurement measures, given their significant environmental footprint and circular potential. 5. Market development and certification A harmonised EU certification framework for verifying recycled contentincluding mass-balance-based approachesis critical to ensure credibility and comparability across Member States. Such a system should serve as the verification mechanism under the Ecodesign for Sustainable Products Regulation (ESPR), clarifying the current fragmented certification landscape. A unified approach would increase transparency, reinforce consumer and industry trust, and prevent misleading environmental claims.
Read full responseResponse to European Innovation Act
3 Oct 2025
RE&UP Technologies Holding BV, a next-generation circular technology company, headquartered in the Netherlands and committed to revolutionizing textile waste recycling, advocates for a more supportive legislative and financial environment in the European market. RE&UP welcomes the Commissions recognition of the barriers identified in the earlier consultation on the EU Startup & Scale-up Strategy and appreciates its efforts to address these hurdles. While sharing the ambition of the European Innovation Act, we would like to raise the following identified shortcomings: 1. Access to Finance - Non-refundable support: Limited access to national and EU funds remains a challenge. Equity and loans alone cannot meet the needs of capital-intensive industries such as textile recycling. Dedicated non-refundable public grants must complement private and public financing. - Risk-tolerant disbursement: At least 1520% of support should be provided upfront, especially for projects aligned with the sustainability objectives of the EU including but not limited to the targets of EU Green Deal, Circular Economy Act and ESPR. - Simplified access and pre-checks: A pre-assessment tool and a consolidated EU funding platform aggregating EU, national, and regional opportunities would ensure more efficient use of scarce resources. - Inclusion of developing companies: Funding should support all startups and scale-ups, including large-scale strategic innovative projects, in line with their capital requirements and economic viability. - Targeted calls: Dedicated funding for waste management, sustainable product design, and textile-to-textile recycling would enhance EU competitiveness and reduce third-country dependence. 2. Regulatory Framework - Fast-track permitting: Textile recycling projects face costly and lengthy approvals. Fast-track permitting and priority status for circular projects, with harmonised application across Member States, would very much support textile recycling projects. - Faster funding decisions: Accelerator mechanisms reducing resolution periods to 36 months for strategic projects shall prevent unsustaimable timelines and delays in market entry. 3. Access to Markets - Private procurement. A vicious cycle persists where buyers demand scaled supply before committing, while recyclers cannot scale without guaranteed demand. The implementation of product-level recycled content mandatory performance requirements is essential for textile-to-textile recyclers. Fair access to feedstock will be guaranteed by harmonised EPR schemes. - Public procurement: Tender rules with embedded innovation and circularity criteria with higher minimum recycled content thresholds and procurement contracts providing accelerated payments (e.g. within 15 days) or pre-financing to address start-up liquidity constraints should be key elements for public procurement. 4. Intellectual Property - Harmonised IPR rules: Different IPR conditions across EU funding instruments create uncertainty and hinder financing. Harmonised rules are needed to ensure innovators retain full ownership and autonomy of commercially exploitable IP, while enabling fair collaboration. 5. Access to Infrastructure - Support in accessing necessary infrastructure: Recycling scale-ups require reliable and affordable access to energy, water, and industrial land. EU investment in enabling infrastructure is essential. The measures are essential to support startups and scale-ups like RE&UP in delivering innovative solutions that are critical to Europes competitiveness, resilience, and sustainability goals. We look forward to contributing to shaping this ecosystem and being part of further policy discussions.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
4 Jul 2025
RE&UP Technologies Holding BV welcomes the European Commissions initiative to establish the Industrial Decarbonisation Accelerator Act (IDAA) as part of the Clean Industrial Deal. We support its ambition to accelerate decarbonisation and enhance Europes industrial competitiveness, and emphasize that circularityparticularly the role of recyclersmust be fully integrated into the IDAA to meet these objectives. Textile-to-textile recycling addresses key EU priorities: reducing reliance on virgin material imports, lowering emissions, strengthening supply chain resilience, and creating sustainable jobs. Yet, due to its exclusion from the definition of energy-intensive industries, textile recycling currently falls outside the IDAAs scopeundermining goals set under the Waste Framework Directive, the upcoming Circular Economy Act, and the Ecodesign for Sustainable Products Regulation (ESPR). The textile sector is among the most resource- and carbon-intensive globally. In 2020, EU household consumption of textiles required around 175 million tonnes of raw materials. Meanwhile, recyclers face high capital costs, low demand, and competition from low-cost non-EU importsissues the IDAA aims to solve. Without targeted support, the EUs circularity and recycled content goals risk going unmet. To ensure the IDAA delivers on its ambition, we offer three key recommendations: 1. Recognise textile secondary raw materials as enablers of decarbonisation Textile recycling reduces emissions through virgin material substitution. The IDAA should: Support textile circular value chains as low-carbon feedstock providers; Include recycled fibres in the definition of low-carbon products eligible for procurement incentives and funding; Ensure collection, sorting, and advanced recycling infrastructure qualifies for financial support, priority status, and fast-track permitting. 2. Include circular industries in priority clusters and permitting acceleration To avoid offshoring and unlock investment in critical recycling infrastructure, the IDAA should: Designate advanced textile recyclers as priority projects or clusters; Apply permitting acceleration to essential circular infrastructure; Enable access to non-refundable public support via the IDAA or aligned programmes (e.g. LIFE, Just Transition Mechanism). 3. Enable demand creation for recycled content through lead markets We welcome IDAAs planned sustainability criteria, minimum EU content, and low-carbon labelling. To strengthen this: Extend recycled content requirements in public and strategic procurement to sectors like textiles, aligned with ESPR; Ensure EU-wide certification of recycled materials is used for labelling to guarantee consistency and fairness; Introduce incentives for uptake of recycled content in low-carbon products, alongside clean feedstock measures. Textile-to-textile recycling remains an underutilised solution with major decarbonisation and circularity potential. Integrating it into the IDAA will help reduce emissions, strengthen domestic raw material supply, and foster sustainable jobs. Recognising and supporting recyclers is essential to achieving the EUs climate and industrial policy goals. The full feedback, including detailed recommendations and context, can be found in the attached document.
Read full responseMeeting with Jessika Roswall (Commissioner) and
2 Jun 2025 · Textiles
Response to EU Start-up and Scale-up Strategy
17 Mar 2025
RE&UP, as a next-generation circular technology company headquartered in the Netherlands committed to revolutionizing textile waste recycling, advocates for a more supportive legislative and financial environment in the European market. In this reply, we call for faster decision timelines, flexibility and inclusion in eligibility of funding mechanisms and a risk-tolerant disbursement model to better support circular economy startups. Additionally, we urge regulatory simplifications, fast-tracked permitting and the development of essential tools, to enhance scalability and access to markets and knowledge. RE&UP greatly appreciates the Commissions efforts to address the hurdles faced by EU startups and scaleups. Ensuring their success and growth is crucial for the EUs overall competitiveness, as outlined in this Call for Evidence. We agree that startups encounter major challenges regarding access to financial aid and funding, regulatory and bureaucratic burdens, and access to markets and knowledge, therefore, following the structure provided in the call, as elaborated in the attached file, we would like to contribute based on our experience, as summarized under the following key points: Access to Finance Startups and scaleups struggle with complex application processes, long decision and disbursement timelines, and strict eligibility criteria that limit access to EU funding. A pre-assessment tool and more comprehensive centralized EU funding platform could simplify the process. Accelerated approval mechanisms and upfront funding would support startups. More flexible eligibility rules and targeted funding for circular economy initiatives are needed. Reassessment of funding sizes which do not support large-scale projects, and increased funding opportunities are required to meet EU sustainability goals. Access to Markets Scalability barriers, particularly for cross-border expansion, hinder startup growth within EU. To facilitate cross-border expansion, streamlined administrative procedures are essential and a harmonized approach to permits, taxation, and reporting obligations would improve operational efficiency for startups. Optimizing regulations for the free movement of textile waste within the EU as well as refining waste classification standards with clearer content specifications rather than broad terms like textile waste would also support the growth of recycling businesses, enabling them to scale and achieve more effectively Europes sustainability goals. Regulatory and Bureaucratic Burdens Lengthy permitting and licensing processes delay innovation. Fast-track approvals for circular economy projects and support for national authorities to expedite applications would reduce these burdens. Regulatory harmonization across EU, national, and regional levels is crucial to prevent unnecessary complexity. Access to Knowledge & Services An EU Startup Helpdesk offering tailored guidance for startups and scaleup based on their activity would be quite beneficial. Sector-specific guidelines and legislation would further support circular economy businesses. Conclusion: A tailored EU Startup and Scale-Up Strategy is needed to foster innovation and global competitiveness and we look forward to contributing to shaping this ecosystem and policy discussions.
Read full responseResponse to Digital Product Passport (DPP) service providers
10 Dec 2024
We appreciate the opportunity to contribute our insights on implementing the Digital Product Passport (DPP). As RE&UP Technologies, a Dutch-headquartered textile waste recycler with facilities in Türkiye, we are directly involved in fostering circularity within the textile industry and enabling sustainable material cycles. Specializing in recycling polyester, cotton, and poly-cotton blends, we transform textile waste into high-quality, virgin-substitute raw materials. Our processes prioritize sustainability, closed-loop value generation, and adaptability to diverse waste streams. As a textile recycler, we advocate for: 1. Standardization of Information Requests: Manufacturers interact with numerous economic operators, making standardized data request methods essential to avoid inconsistencies. This will simplify compliance efforts and reduce the risk of errors or miscommunication. 2. Cost and Funding Allocation: The financial burden of DPP implementation should not rest solely on manufacturers and recyclers, especially in non-EU or developing countries. A fair funding mechanism ensures participation from all stakeholders, fostering inclusivity. 3. Transparency and Competitive Concerns: Consolidating supply chain information with one party may reduce transparency and restrict competitiveness. Secure and limited data sharing is crucial to maintaining trust among stakeholders. 4. Ownership of Data: Data ownership must remain with the supply chain actors providing it. Protecting this ownership ensures that no stakeholder exploits or misuses sensitive data. 5. Shared Responsibility: Compliance efforts and sustainability goals should be a shared responsibility across the entire value chain. By equitably distributing obligations, all stakeholders can contribute meaningfully to achieving regulatory goals. A more detailed position is provided in the attached document for further reference.
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