Spain Textile EPR Decree: What the TRIS Notification Means for Producers

Spain’s textile EPR decree was formally notified to the European Commission on 27th May 2026, opening a three-month standstill period that runs until 28th August 2026. The draft Royal Decree introduces extended producer responsibility for textile and footwear products sold in Spain, requiring producers to register, join a compliance scheme, and fund collection, reuse and recycling. 

What is Spain’s textile EPR decree?

Spain’s textile EPR decree is a draft Royal Decree that would introduce extended producer responsibility (known locally as RAP, Responsabilidad Ampliada del Productor) for textile and footwear products placed on the Spanish market. It covers clothing, footwear, and accessories for domestic use, along with similar non-textile products used in comparable ways.

The measure isn’t new. Spain published the original draft in June 2025. What’s new, as of 27th May 2026, is that the decree has been formally notified to the European Commission under the EU’s technical regulations notification procedure, a required step before any new technical regulation of this kind can enter into force. This notification is what starts the clock on the formal EU review process.

Why has the decree been notified to the European Commission?

Any EU member state introducing a new technical regulation, including waste and producer responsibility rules of this kind, must notify the European Commission before it can take effect. This gives the Commission and other member states a window to review the draft and raise concerns, ensuring new national rules don’t create unnecessary barriers to trade within the single market.

Spain’s notification, reference number 2026/0266/ES, was received on 27th May 2026. It sits in the Technical Regulation Information System (TRIS), the Commission’s public database for tracking these notifications.

What does the TRIS standstill period mean for the timeline?

The standstill period is the review window that follows a TRIS notification, during which the notifying country cannot formally adopt the regulation. For Spain’s textile EPR decree, that period is due to expire on 28th August 2026, three months after notification.
What happens next depends on how the Commission and other member states respond:

• No objections raised. If the standstill period passes without formal objections, Spain can proceed to adopt the decree, likely via approval at a Council of Ministers meeting rather than through Parliament.
• Objections or comments raised. If the Commission or another member state raises a formal objection, the standstill period is extended by a further three months, and Spain would need to respond to the concerns or amend the text before proceeding.

It’s worth noting that Spain isn’t necessarily waiting idly during this window. Internal validation across the relevant ministries can continue in parallel while the notification is under review at EU level, which means the practical implementation date depends on both the EU process and Spain’s own internal sign-off.

What does the draft decree require of producers?

The draft Royal Decree sets out a comprehensive framework. The core elements include:

• Separate collection requirements. Conditions for the separate collection of textile waste, building on obligations already in force under Spain’s existing waste law.
• End-of-waste criteria. Rules on when textile waste stops being classified as waste, and the conditions that apply when used textile products are transferred, distinguishing genuine reuse from waste management.
• Extended producer responsibility. A formal EPR regime covering who counts as a “producer,” the obligations placed on producers and on the collective compliance schemes (Sistemas Colectivos de Responsabilidad Ampliada del Productor, or SCRAPs) they join, and the costs those schemes must finance for collection, sorting, reuse and recycling.
• Reporting and transparency. Requirements to register with Spain’s national Producer Registry, submit annual reports to the competent authority, and, for waste managers handling textile and footwear waste, file annual returns.
• Consumer information. An obligation to make information on sustainable consumption available to end users of textile and footwear products.

Producer status is defined broadly, and is expected to include small and medium-sized enterprises, though the draft allows extended timelines for some SME obligations to ease the administrative burden.

Why is Spain acting now?

The decree has two legal roots. The first is domestic: Spain’s Law 7/2022 on waste and contaminated soils for a circular economy already bans destroying or landfilling unsold textile surplus, and has required local authorities to collect textile waste separately since the end of 2024. That law also commits Spain to developing a dedicated textile EPR regime within three years of the law taking effect, a deadline that has now been reached.

The second is EU-level: Directive (EU) 2025/1892, which amends the Waste Framework Directive, requires member states to apply extended producer responsibility to textile and footwear products, covering both the management costs producers must fund and their duty to inform end users.

The scale of the problem is part of the justification too. Research cited in Spain’s own impact assessment estimates textile waste generation at around 1,060,200 tonnes in 2017, roughly 23kg per person. A more recent estimate for 2022 puts the figure at closer to 900,000 tonnes, around 20kg per person per year, with the separate collection rate for textiles still described as very low. Fast fashion’s shorter product lifespans and lower repairability are named directly as drivers of the trend.

How does this fit into the EU’s wider textile waste rules?

Spain isn’t acting in isolation. Textile waste has become one of the EU’s priority waste streams, and member states are at very different stages of introducing their own EPR frameworks. France’s Refashion scheme has been operating for several years, the Netherlands has its own textile EPR rules already in place, and Italy has been working through its own draft decree and public consultation process on a broadly similar timeline to Spain.

For a wider view of how these national frameworks are converging, and where the gaps and inconsistencies still sit, our guide to textile EPR across Europe covers the picture country by country. Our earlier explainer on EU textile waste rules covers the underlying Waste Framework Directive obligations that sit behind all these national decrees, including Spain’s

What should businesses do now?

For businesses that place textile or footwear products on the Spanish market, whether based in Spain or exporting into it, the direction of travel is now clear even though the decree hasn’t been finalised. Sensible next steps include:

• Reviewing which products in your range would fall within scope, based on their nature and intended use.
• Establishing whether your business meets the definition of a “producer” under the draft, including for online and distance sales into Spain.
• Beginning conversations with a compliance partner, like RLG or Valpak, about which collective scheme (SCRAP) route makes sense for your business.
• Reviewing what production and sales data you’d need to report if the decree proceeds broadly as drafted.

Given the compliance scheme approval process and registration timelines that typically follow a decree of this kind, waiting until the standstill period ends before starting this work leaves very little room for manoeuvre.

For a deeper walkthrough of the original draft decree, including timelines, reporting obligations, and eco-modulated fees, our recorded webinar with Reconomy’s Aimee Campanella and Valpak‘s Harry Russell is available to watch on demand.

Putting this into practice with Reconomy

Reconomy’s specialist  brands already support producers navigating textile EPR across multiple European markets, from the established French and Dutch schemes through to Spain and Italy’s developing frameworks. Our teams track notifications like this one as they move through the EU process, so producers aren’t caught out by a standstill period ending sooner or later than expected.

If your business needs support assessing its exposure to Spain’s textile EPR decree, speak to our textiles compliance team.