Textile EPR
Directive (EU) 2025/1892 requires member states to set up extended producer responsibility schemes for textiles by 17 April 2028, and micro-enterprises follow a year later. Its list is based on customs codes, including clothing, blankets, bed and table linen, curtains and felt hats. Importers and some distance sellers count as producers, even when selling to business users.
On a direct reading of the annex, bags under code 4202 and felt as a material under chapter 56 are not listed. Coasters, placemats and wall hangings need checking by exact code. Ask a customs broker to confirm the classification of your product.
PPWR
Regulation (EU) 2025/40 has applied since 12 August 2026. It also covers business-to-business packaging. A felt pouch sold with a product inside may count as packaging; whether it does depends on the criteria in Annex I, as there is no direct example for felt. Environmental claims about packaging properties are restricted under Article 14 and must be supported by technical documentation.
What to do
- List your products with their customs codes.
- Decide who is the producer or importer in each country.
- Ask whether felt gift items count as packaging in your use.
- Watch for national implementation dates.
This is an overview, not legal advice. National laws vary and are still changing.
