EU takes first swing at ultra-fast fashion, but can textile EPR survive Shein?
- Thomas Lundkvist
- Dec 18, 2025
- 4 min read
The EU is preparing a historic shift by introducing mandatory producer responsibility for textiles, a reform intended to reshape how textile waste is financed and managed across Europe. The goal is clear, brands placing textiles on the European market must also pay for the cost of managing them as waste. But even before the system comes into force, a structural risk has emerged. The explosive volume of ultra-cheap garments shipped into Europe by platforms such as Shein threatens to undermine the framework before it is fully operational.
A key reason is how these platforms enter the market. Unlike traditional retailers, much of Shein’s clothing is shipped directly from China to individual European consumers in millions of small parcels. This direct-to-consumer model makes it difficult to identify a producer or importer established in the EU, which is normally required to register, report volumes and pay Extended Producer Responsibility fees. As a result, large textile volumes can reach European wardrobes while remaining only partially captured by EPR systems designed for domestic or EU-based actors.
As the EU now moves to counter ultra-fast-fashion imports with new customs fees on small parcels, the central question is becoming harder to avoid. Can Europe’s most ambitious circularity reform withstand the world’s fastest-growing fashion platform?
Direct-to-consumer imports expose gaps in producer responsibility
As Europe begins implementing its new Extended Producer Responsibility framework for textiles in 2025 and 2026, the intention is to internalise environmental costs. EPR fees are meant to finance sorting, reuse, recycling and improved waste management infrastructure across the continent.
At the same time, ultra-fast fashion import volumes are accelerating. Platforms such as Shein operate with extremely low price points, data-driven design and near-instant production cycles. The result is a scale of textile inflow that few existing systems were designed to handle.
The core logic of EPR is simple, whoever places products on the market must also pay for managing them when they become waste. But when products are sold through cross-border platforms with no clear producer entity established in the EU, that logic becomes difficult to enforce. The risk is that compliant European brands, retailers and importers end up carrying a disproportionate share of the financial burden, while overall textile volumes placed on the market – and eventually entering waste streams – continue to rise.
Parcel fee signals political recognition of the problem
This imbalance has now prompted a concrete EU response. On 12 December 2025, EU finance ministers agreed to introduce a temporary flat fee of €3 on low-value parcels entering the Union from outside its borders. The measure, which will apply from 1 July 2026, is widely understood as targeting platforms whose business models rely on shipping millions of individual parcels directly to consumers, particularly from China.
The fee is intended as an interim solution ahead of a broader customs reform, including the abolition of the duty-free threshold for small consignments and the rollout of more advanced digital customs systems. It represents a political acknowledgement that ultra-fast-fashion imports are placing pressure on existing regulatory and economic structures.
However, the new fee is not part of the textile EPR legislation itself. While it may reduce some cost advantages and slow the growth of micro-parcel imports, it does not resolve the underlying question of how EPR fees are calculated, reported and enforced for cross-border platforms.
Why ultra-fast fashion challenges the logic of EU textile EPR
The structural mismatch remains. Textile EPR systems assume identifiable producers, local representation, consolidated reporting and long-term accountability. Ultra-fast fashion platforms operate on almost the opposite logic, fragmented shipments, minimal physical presence, limited traceability and algorithm-driven production responding directly to consumer demand.
A flat parcel fee may slightly rebalance competition, but it does not ensure that the textiles entering Europe are fully accounted for within EPR systems. Nor does it guarantee that fees collected correspond to the actual volumes placed on the market.
When a single platform can ship more garments into Europe than many national retail chains combined, while remaining only loosely integrated into producer responsibility frameworks, the risk is not merely financial. It becomes a question of systemic credibility for Europe’s circular economy policy framework.
From parcel fees to system design: a growing policy mismatch
According to Reuse News’ review of EU policy documents and customs reform proposals, the scale and structure of ultra-fast fashion imports were not central assumptions when textile EPR systems were designed.
The EU has begun to recognise that ultra-fast-fashion imports are challenging the foundations of its circular economy policies. But unless the largest volume actors are fully integrated into EPR systems, with transparent reporting and proportional financial contributions, the framework risks being undermined from the outset.
For reuse organisations, waste operators and European retailers, this is no longer only about competition. It is a systemic risk to the infrastructure meant to support reuse, recycling and waste reduction.
The question facing policymakers is therefore no longer hypothetical. Can textile EPR function when one of Europe’s largest textile importers operates through a market model that does not align with the system’s basic design?
The new parcel fee is a step toward addressing that gap. Whether it is followed by deeper integration of ultra-fast-fashion platforms into Europe’s responsibility frameworks will determine whether textile EPR becomes a cornerstone of circularity, or a system strained by forces it was never designed to absorb.
Sources
• European Commission communications on textile strategy and consumer protection
• EU reports on customs and import framework changes coming in 2026
• Policy analyses on Extended Producer Responsibility and textile flows
Written by Thomas Lundkvist
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