TESS GEIE
TESS
TESS in an EEIG based in Herstal, Belgium.
ID: 749701947455-78
Lobbying Activity
Response to Mid-Term Review: Social Economy Action Plan
2 Jul 2025
As a network of social economy enterprises active in the collection, sorting and reuse of textiles, TESS GEIE pays close attention to current and upcoming regulations, as our sector is increasingly threatened and exposed to multiple economic, environmental, and legislative challenges. We fully endorse the positions put forward by the RREUSE network, whose members represent the voice of civil society with remarkable accuracy and valuable expertise. Now more than ever, we remain available and committed to further develop and strengthen our positions, both as TESS GEIE and as an active member of RREUSE, to promote a sustainable, solidarity-based model that offers concrete solutions for a truly inclusive circular economy.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
21 Nov 2023
Feedback from TESS GEIE: - Short version below - Attached: detailed version - Attached: Legal analysis. What is the value of the act of handing over used textiles (donation vs. act of discarding)? What is the qualification of these textiles (products vs. waste)? (French and translation in English) NB: both annexes are merged in a same PDF document. -- I) Extended producer responsibility scheme for textiles (Article 22a) (see detailed feedback attached) - TESS GEIE would like to ask clarifications regarding the implementation of this EPR scheme, regarding several points. II) Textiles waste management (Article 22d) (see detailed feedback attached) - TESS GEIE would like to highlight the importance of considering that all textiles should be considered as waste upon collection, without exception. - TESS GEIE would like to underline the importance of ensuring that all actors in the textile recovery chain are subject to the relevant legal framework, which makes possible both developing the circular economy and tackling the problem caused by all the informal activity and players. III) Shipments (part of article 22d) (see detailed feedback attached) - Clarification should be given on the articulation between: - the end-of-waste for textiles to be adopted; - the Waste Shipment Regulation (hereafter the WSR); - the WFD Revision Proposal. IV) The key role of the social enterprises (see detailed feedback attached) - TESS GEIE welcomes the recognition of such a key role in the present and for the times to come. - TESS GEIE agrees with all the measures involving the social enterprises in the Proposal - Still, the question of giving a clear definition of the SEs should be addressed V) Producer responsibility organizations (Article 22c) (see detailed feedback attached) - TESS GEIE agrees that a key role is played by the social enterprises in the whole textile recovery value chain. - To be consistent with such a role, it seems that more guarantees should be requested so that social enterprises can be actively involved in the EPR PROs, especially withing their decision-making bodies and processes. - Clarifications should also be given regarding several points. VI) Ambitious separate targets for reuse and for recycling (see detailed feedback attached) - TESS GEIE would encourage the setting of separate targets for reuse and for recycling, that are both ambitious (high) and respectful of the waste hierarchy principle (reuse should be high); - Imposing such targets in the near future seems essential so that the WFD maximizes its positive impacts.
Read full responseResponse to Developing social economy framework conditions
30 Sept 2022
TESS EEIG wishes to make the following contributions to the development of framework conditions for the deployment of the social economy (SE) in Europe:
1—Taking into account the specificity of the textile sector within the SE and engaging in a sustainable green agenda by supporting it
It can be estimated today that SE actors probably represent at least 50% of the textile recovery market in Europe, mainly through the practice of textile reuse. Such a level of development of activities make possible the well know realizations of the social enterprises (SEs) in terms of social reintegration, employment, training, resource circularity and related environmental impacts.
Today, as the second hand textiles market is becoming object of more and more competition and in the context of the construction of new European policies regarding textiles (waste management to the new CEAP), TESS is now anticipating the possible devolvement of two alternative paths:
-Path 1 (that TESS promotes) based on the priorisation of reuse, with little investment needed and the employment of a large workforce ; or
-Path 2 (which TESS would like to warn about) based on the priorisation of recycling, with high investment and limited workforce.
2—Today, TESS is putting forward a series of proposals which would make it possible to accompany this change with the best impacts possible
o With a view to a likely implementation of EPR schemes for textiles
- require a strong involvement of SEs active in textile recovery in the current processes of establishing the harmonised EPR schemes
- require a governance of the EPR schemes that represents the SE at its true value within the management bodies of EPRs
- require a minimum 50% target of reuse, with the objective of making it bigger (thanks to new eco-design requirements, for example)
- setting an obligation for PROs or producers to guarantee that those collection model and sorting facilities will prioritise re-use over recycling and promote circular design
o Require a strong involvement of SEs active in textile recovery in the processes of establishing end-of-waste criteria for textiles
o Developing concrete actions out of the current Transition Pathway, for stronger links between the EU’s future revised CEAP and the SEAP in the form of specific actions supporting SEs active in the textile ecosystem and in the circular economy
o Investing with an ambitious vision and objectives in order to make progress the current actors of textile recovery, especially from the SE, with a perspective of local development. Establish funding objectives for those enterprises (e.g. learning, technological development, cooperation projects between re-use actors, with local authorities, research, etc.)
o Reserving a specific EU funding for the SEs active in textile recovery, so that those actors can gather and thus reach a critical size allowing them to interact with the large international private actors, and avoid to be outdone by them
o Financial support, through EU programs (COSME, LIFE and/or others) to new projects aiming at
- Meeting, the current major challenges regarding sustainable development in terms of circular economy and textile waste management policies (including EPR systems)
- Finding collective solutions and develop capacities (involving public - mostly local and regional - and private actors) in order to adapt quickly
- Guaranteeing the ethical use of textiles (including the exported textile)
o In case some clusters are to be developed in interaction with the traditional private sector: ensuring conditions that allow the historical actors of textile recovery, notably from the SE, to be represented at their fair value. The idea is to avoid any unfair over-representation of actors who may be perceived as less legitimate than the SE active in textiles as a whole
o Developing separate textile collection systems that prioritise and facilitate reuse which should be made more accessible both financially and technically
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