The Growing Threat to Extended Producer Responsibility in Europe

The recent push for Extended Producer Responsibility (EPR) regulations as a solution for textile waste in Europe is being undermined by a major loophole: e-commerce sales. Online clothing sales account for 42% of all clothing sales in Europe (Statista), yet many e-commerce giants like Shein, Temu, and AliExpress are evading EPR obligations. This threatens to make EPR regulations ineffective in tackling the textile waste crisis.

The EPR and E-Commerce Loophole

EPR has been enacted in France and the Netherlands, requiring all retailers, including e-commerce sellers, to pay fees for textile recycling and waste management. However, many Chinese online retailers ignore these laws, creating a regulatory gap. In the Netherlands, for example:

• Shein, Temu, and AliExpress have not established a local legal entity, as required by law.
• They do not pay EPR fees, which fund textile recycling programs.
• They do not take legal responsibility for end-of-life reuse or recycling of their clothing.

As a result, a massive loophole in the EPR framework is undermining the system’s effectiveness. While some online retailers comply, others evade regulations, resulting in severe environmental and economic consequences.

The Financial & Environmental Impact

The total value of online fashion sales in Europe reached €213 billion in 2023 (ecommercenews.eu), and Chinese e-commerce platforms now control 10-15% of this market. This translates into €21-25 billion worth of clothing sales evading EPR regulations annually.

Shein’s Rising Dominance

• Shein reported sales of €7.7 billion in Europe in 2023, a 68% increase over 2022 (Reuters).
• With total European clothing sales at €483 billion in 2023, Shein alone controls 1.6% of the market(GlobalData).
• Combined with Temu and AliExpress, non-EU online retailers dominate nearly 10% of the European clothing market.

The Missing EPR Fees

• The average EPR fee is €0.24 per kg (Dutch EPR rate, 2025).
• With an estimated 1.1 million tons of textiles imported annually by fast fashion e-commerce, Europe is losing €264 million per year in unpaid EPR fees.
• These fees are meant to fund recycling infrastructure, textile reuse programs, and waste management.

Unchecked Textile Waste Growth

• Over 5,000 tons of shipments, mostly clothing, enter Europe daily from non-compliant e-commerce retailers (Cargo Forwarder EU).
• Without enforcement, this waste burden falls on European taxpayers and local recycling facilities.

How EPR Non-Compliance Undermines Sustainability Goals

EPR has three key objectives:

1. Make producers responsible for textile waste and recycling.
2. Set collection and recycling targets for textiles.
3. Generate funds to achieve these targets through retailer fees.

However, due to e-commerce evasion:

• €25 billion in clothing sales annually escape EPR rules, with no accountability for their environmental impact.
• EPR programs miss out on €264 million in annual fees, meaning less funding for textile recycling.
• There is no reliable tracking of how many garments are being sold, recycled, or ending up as waste from online retailers.

Why Is E-Commerce Allowed to Evade EPR?

E-commerce retailers exploit regulatory gaps by shipping directly from China and other Asia locations to EU consumers, bypassing local business registration requirements. Around 4 billion parcels will be delivered to European customers in 2024, with 80% originating from China (Cargo Forwarder EU).

Key Problems That Allow Fast Fashion to Evade EPR

1. No Customs Enforcement – There are no EPR compliance checks at EU borders.
2. Lack of Market Oversight – Online marketplaces like Shein and AliExpress do not pay EPR fees on their clothing shipments
3. Exploitation of the €150 De Minimis Rule – Small parcel imports under €150 avoid import duties and EPR obligations.

What Can Be Done?

The EU needs urgent reforms to close the loopholes in textile EPR and hold all e-commerce retailers accountable.

1. Enforce EPR Fees at Customs

• No EPR registration = No entry into the EU market.
• Require proof of EPR compliance before any textile shipment clears customs.

2. Make Online Marketplaces Liable

• Shein, Temu, and AliExpress should be forced to pay EPR fees
• Platforms that fail to comply should face hefty fines and potential bans.

3. Remove the €150 De Minimis Loophole

• E-commerce retailers are avoiding VAT and EPR fees by shipping individual small parcels.
• The EU should eliminate duty exemptions for ultra-fast fashion retailers.

Conclusion: Fast Fashion Must Pay Its Fair Share

The unchecked rise of e-commerce is undermining Europe’s textile waste policies. If the EU fails to close loopholes, fast fashion giants will continue evading responsibility, leaving European taxpayers to clean up their waste.

🔹 Immediate action is needed to enforce EPR at customs, make platforms responsible, and remove import loopholes.

🔹 If e-commerce retailers refuse to comply, they should face penalties or be banned from the European market.

Fast fashion brands must be held accountable for their environmental footprint—it’s time for the EU to enforce real Extended Producer Responsibility.

Toomas Allikas
www.linkedin.com/in/allikas