Green-listing of B3030 mixtures with footwear and accessories
15 Sep 2026 | Expertise and positionning
The European Commission has launched a consultation on a draft delegated act aimed at simplifying cross-border shipments of mixed textile waste that also contain footwear, hats, belts, and accessories; a legal grey area well known to the reuse sector.
TESS GEIE supports the Commission’s objective of resolving the current legal uncertainty around mixtures of textiles, footwear and clothing accessories. However, we cannot support the draft as currently proposed.
As drafted, the new entry green-lists these mixtures only when they are destined for recycling. It therefore facilitates the lowest applicable step of the waste hierarchy and leaves the highest one burdened. Simplification should follow the waste hierarchy, not work against it.
We ask the Commission to set it out as a single narrowly defined entry - in Annex IIIB under Article 79(4), or in Annex IIIA if the Commission is satisfied that it can carry it - covering mixtures that result from a sorting operation and are destined for preparation-for-reuse or material recycling. Mixtures shipped before sorting should continue to be covered by prior written notification and consent, as they are today.
In short, we ask the Commission to:
1. cover shipments for both preparation-for-reuse and material recycling;
2. green-list only mixtures that have undergone a sorting operation;
3. leave unsorted collected mixtures under prior written notification and consent;
4. make the existing simplified notification mechanisms more accessible to small and social economy operators, and ensure that EPR schemes cover the related administrative costs;
5. add a review clause assessing the effects of the new provisions on local sorting and preparation-for-reuse.
This would close the legal gap the Commission has identified while preserving the incentives for local sorting, preparation-for-reuse, local employment and social-economy activity.
Click here to read our full position
TESS GEIE supports the Commission’s objective of resolving the current legal uncertainty around mixtures of textiles, footwear and clothing accessories. However, we cannot support the draft as currently proposed.
As drafted, the new entry green-lists these mixtures only when they are destined for recycling. It therefore facilitates the lowest applicable step of the waste hierarchy and leaves the highest one burdened. Simplification should follow the waste hierarchy, not work against it.
We ask the Commission to set it out as a single narrowly defined entry - in Annex IIIB under Article 79(4), or in Annex IIIA if the Commission is satisfied that it can carry it - covering mixtures that result from a sorting operation and are destined for preparation-for-reuse or material recycling. Mixtures shipped before sorting should continue to be covered by prior written notification and consent, as they are today.
In short, we ask the Commission to:
1. cover shipments for both preparation-for-reuse and material recycling;
2. green-list only mixtures that have undergone a sorting operation;
3. leave unsorted collected mixtures under prior written notification and consent;
4. make the existing simplified notification mechanisms more accessible to small and social economy operators, and ensure that EPR schemes cover the related administrative costs;
5. add a review clause assessing the effects of the new provisions on local sorting and preparation-for-reuse.
This would close the legal gap the Commission has identified while preserving the incentives for local sorting, preparation-for-reuse, local employment and social-economy activity.
Click here to read our full position