Textile Waste Rules: India’s Quiet Move Toward an EPR for Apparel

Updated: September 24, 2026 · 16 min read

India generates an estimated 7.8 million tonnes of textile waste annually — pre-consumer cutting waste from mills and post-consumer garment discard combined — yet as of September 2026, no standalone EPR framework exists for the sector. That gap is closing faster than the industry’s preparedness curve. MoEFCC’s 2024-25 stakeholder consultations, parallel pressure from European buyers, and the blunt force of SEBI’s BRSR Core disclosures mean that textile waste rules in India are no longer a policy hypothetical: they are an approaching deadline. Brands and mills that treat this as someone else’s problem will find themselves restructuring supply chains under regulatory duress rather than commercial advantage.

India’s 2026 Textile Waste Policy Gap — and Why It Will Not Last

The absence of a dedicated textile waste rule in India is not an oversight — it reflects the sector’s historical political weight. Textiles employ roughly 45 million people directly and anchor export earnings of around $35 billion per year. Any EPR obligation that raises production costs has faced fierce resistance from mill associations in Gujarat’s Surat cluster, Tamil Nadu’s Tiruppur garment belt, and Maharashtra’s Bhiwandi processing units. The result has been delay, not exemption.

What has changed in 2026 is the convergence of pressures. The Ministry of Environment, Forest and Climate Change (MoEFCC) has already demonstrated it can move quickly when political will aligns: the Battery Waste Management Rules, 2022 were notified, enforced, and saw EPR targets revised within a 24-month window. The E-Waste (Management) Rules, 2022 replaced their 2016 predecessor with expanded producer scope and a live CPCB portal for EPR credit trading. Textiles are next in the queue, and the machinery to notify them exists under Section 6 and Section 25 of the Environment Protection Act, 1986 — no new Act of Parliament required.

The Central Pollution Control Board (CPCB), which administers EPR registrations across categories, has been quietly building classification capacity for fibre types — cotton, polyester, blended, technical textiles — that mirrors the groundwork done for plastics before the Plastic Waste Management Rules, 2016 were operationalised. The signal is unmistakable to anyone watching CPCB’s extended producer responsibility portal.

What MoEFCC and the Ministry of Textiles Have Actually Said

In the second half of 2024, MoEFCC circulated an internal concept note on Extended Producer Responsibility for textiles and apparel — a document that has not been formally published but was referenced in the minutes of a multi-stakeholder consultation convened by the Ministry of Textiles in February 2025. That consultation brought together representatives from the Confederation of Indian Textile Industry (CITI), the Clothing Manufacturers Association of India (CMAI), and officials from the NITI Aayog circular economy task force.

The broad contours that emerged from those discussions are consistent with India’s approach to other EPR categories. Producers — defined to include brands that place garments on the Indian market, whether manufactured domestically or imported — would be required to register on a CPCB portal, declare annual volumes, and either establish their own take-back infrastructure or purchase EPR credits from CPCB-registered recyclers. The Ministry of Textiles pushed for a phased rollout beginning with large enterprises (annual turnover above ₹250 crore) before extending to SMEs, mirroring the staged approach used in the Battery Waste Management Rules, 2022.

No gazette notification had been issued as of the date of this article (September 2026). However, the FY 2026-27 Union Budget’s allocation of ₹500 crore to the Amended Technology Upgradation Fund Scheme (ATUF) for textile machinery included, for the first time, explicit eligibility for fibre-sorting and recycling equipment — a fiscal signal that the policy superstructure is expected to follow. Brands would be unwise to interpret the absence of a formal rule as permission to defer investment.

The EU EPR for Textiles: A De Facto Compliance Mandate for Indian Exporters

Whatever the pace of domestic rulemaking, Indian apparel exporters supplying European brands are already operating under an external EPR regime. The European Union’s revised Waste Framework Directive introduced mandatory separate collection of textiles across all member states from 1 January 2025. Several member states — France being the most advanced, having operated the REP TLC scheme since 2007 — have already built producer fee structures and eco-contribution models that brands must absorb.

For Indian exporters, the commercial consequence is direct. European buyers — Inditex (Zara), H&M, and the major German mid-market retailers among them — are now requiring their supply-chain partners to provide evidence of post-production waste recycling rates, fibre-to-fibre recycling certifications (GRS — Global Recycled Standard, or RCS — Recycled Content Standard), and waste manifests from Indian factories. An Indian garment manufacturer in Tiruppur that cannot produce a certificate of recycling for its cutting waste is increasingly being graded down in supplier scorecards, regardless of price competitiveness.

This is the classic pattern that preceded India’s domestic EPR rules for plastics and e-waste: export-buyer pressure creates de facto compliance long before the domestic gazette notification arrives. The difference with textiles is that the domestic rule, when it comes, will apply to the far larger domestically consumed apparel market — estimated at ₹7.5 lakh crore by FY 2025-26 — where there is currently no external buyer imposing discipline.

The Regulatory Toolkit Already in Play

While a dedicated textile EPR rule is pending, the compliance environment for Indian textile businesses is far from empty. Three existing frameworks carry direct relevance — and real enforcement teeth.

The Environment Protection Act, 1986

Section 7 of the Environment Protection Act, 1986 prohibits the discharge or emission of any environmental pollutant in excess of prescribed standards. Textile dyeing effluent and wet-processing waste from mills in Surat, Ludhiana, and Erode have been the subject of CPCB enforcement notices and court-directed closures. The Act also grants MoEFCC the authority — used repeatedly — to notify sector-specific waste management rules without fresh legislation.

The Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016

Textile processing units that use azo dyes, heavy-metal-based colourants, or finishing chemicals classified as hazardous under Schedule I or Schedule II of the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 are already subject to authorisation, manifest tracking, and record-retention obligations. Rule 4 requires every occupier generating hazardous waste to obtain authorisation from the State Pollution Control Board. Many textile units treat this obligation lightly — a posture that State PCBs in Tamil Nadu, Maharashtra, and Gujarat have been correcting through inspection drives in FY 2025-26.

SEBI’s BRSR Core (Circular dated 12 July 2023)

For listed companies in the apparel and textile sector, the Business Responsibility and Sustainability Reporting (BRSR) Core framework — mandated under SEBI’s circular dated 12 July 2023 — requires Key Performance Indicators on waste generation, recycling rates, and water intensity. From FY 2024-25 onwards, the top 150 listed companies by market capitalisation must provide assured (third-party verified) BRSR Core data. The top 250 follow in FY 2025-26 and 1,000 by FY 2026-27. A listed garment brand that cannot quantify its textile waste flows is not just non-compliant — it faces adverse analyst commentary and proxy-advisor red flags.

EPR Target Scenarios: What Numbers India Is Likely to Adopt

India’s EPR frameworks for other categories provide a useful benchmark for projecting what textile targets might look like. The Plastic Waste Management Rules, 2016 (as amended) set collection and recycling targets on a phased trajectory reaching 100% EPR obligation by FY 2024-25 for rigid plastics. The Battery Waste Management Rules, 2022 set collection efficiency targets of 70% for FY 2025-26, rising to 90% by FY 2027-28. The E-Waste (Management) Rules, 2022 require producers to meet collection targets starting at 60% of the previous year’s sales weight.

Given the complexity of textile fibre streams — mixed-fibre blends are notoriously difficult to sort and recycle — MoEFCC is likely to adopt a lower initial target, possibly 20-30% collection-and-recycling obligation in Year 1 of the notified rule, stepping up to 50-60% over a five-year trajectory. The fee structure, if it mirrors France’s REP TLC model, could translate to contributions in the range of ₹2 to ₹8 per garment placed on the market, depending on recyclability scoring. These are projections based on policy analogues, not a notified figure — but brands building financial models should stress-test against this range.

EPR Category	Governing Rule	Year 1 Target	Year 5 Target	Penalty / Consequence
Plastic packaging	Plastic Waste Management Rules, 2016 (as amended)	25% (FY 2022-23)	100% (FY 2024-25)	EPF levy; CPCB enforcement notice
Batteries	Battery Waste Management Rules, 2022	70% (FY 2025-26)	90% (FY 2027-28)	Environmental Compensation Fund deposit
E-waste	E-Waste (Management) Rules, 2022	60% of prior-year sales weight	Escalating annual targets	EPR certificate shortfall; CPCB notice
Textiles (projected)	Textile EPR Rule (draft — not yet notified)	20-30% (projected Year 1)	50-60% (projected Year 5)	TBD — likely EPF levy + portal block

The 7-Step Readiness Checklist for Apparel Brands and Mills

Compliance frameworks for other EPR categories — plastics and e-waste most instructively — show a consistent pattern: brands that begin infrastructure preparation 12-18 months before a rule is notified secure recycler partnerships at reasonable rates; brands that scramble after notification pay a premium and face EPR credit shortfalls in Year 1. The following checklist is calibrated for action in FY 2026-27, ahead of an anticipated draft notification.

1. Conduct a waste-stream audit by fibre type. Quantify pre-consumer cutting waste (in tonnes/quarter) and post-consumer take-back volumes separately. Segregate cotton, polyester, blended, and technical textiles — each has a different recycling route and projected EPR obligation intensity.
2. Map your BRSR Core data gaps. If your company is within the top 1,000 listed entities, confirm whether your FY 2026-27 sustainability report can produce assured waste data at the intensity level SEBI’s 12 July 2023 circular requires. Engage a third-party assurer now — credible ESG assurers in India are capacity-constrained.
3. Verify Hazardous Waste authorisation status. If your mill uses azo dyes or heavy-metal finishes, confirm your State PCB authorisation under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 is current. Authorisations typically run for five years; many units issued authorisations in FY 2020-21 are now operating on lapsed permissions.
4. Engage an authorised recycler for cutting-waste offtake. Secure a formal agreement — not just a spot arrangement — with a CPCB-registered recycler. Ensure the agreement specifies certificate of recycling issuance, GST-compliant invoicing, and minimum offtake volumes. This documentation will be the evidentiary backbone of any future EPR filing.
5. Register on the EPR portal proactively. The CPCB EPR portal currently handles plastics, e-waste, and batteries. When textiles are added, brands already registered in the system will have a faster onboarding path. Ensure your company’s PAN, GST registration, and authorised signatory details are current on the CPCB system.
6. Develop a consumer take-back mechanism. Retail chains with more than 20 outlets should begin piloting in-store garment collection bins — this doubles as a marketing asset (circular economy messaging) and as physical evidence of producer effort that regulators reward in EPR frameworks elsewhere.
7. Engage export-compliance counsel on EU requirements. If you supply European brands directly, obtain GRS or RCS certification for your recycled-fibre use claims and document your supply-chain waste disposal through auditable manifests. These documents will translate directly into Indian EPR evidence once the domestic rule is notified.

How to Build a Take-Back Loop That Survives an Audit

A take-back loop for textile waste is not a marketing programme — it is a documentation chain. When an EPR rule is notified and CPCB or a State PCB sends an inspection team, the auditor will ask for three things: proof of waste generated (production records), proof of waste transferred (weigh-bridge receipts or dispatch manifests), and proof of recycling (certificates from an authorised recycler). The gap between these three documents is where most companies fail.

The architecture of a functional take-back loop begins at the factory floor. Pre-consumer cutting waste must be weighed, segregated by fibre, and recorded in a register that matches the production batch. This register is the foundation document. At the point of transfer to a recycler, a vehicle-specific manifest — analogous to the manifest system already required under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016 — must accompany each consignment. The recycler’s GST invoice and the certificate of recycling (specifying input weight, fibre type, and output material) complete the chain.

For post-consumer waste collected through retail take-back, the chain is longer but the principle is identical. The retailer’s collection log feeds into a consolidation manifest, which accompanies the bulk transfer to a sorting facility. The sorting facility’s output — sorted fibre bales — then travels under a fresh manifest to a fibre recycler or a downcycler (producing insulation, geotextiles, or automotive stuffing, for instance). Each link in the chain generates a document; the document set is what an audit actually scores.

The National Recycling Corporation supports apparel brands through EPR compliance services and connects factories with authorised downstream recycling facilities across Maharashtra, Tamil Nadu, Gujarat, and Karnataka. Our industrial waste management service includes the complete document set — weigh-bridge receipts, GST invoices, and certificates of recycling — structured for BRSR and future EPR submission.

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• Pharma Manufacturing Waste: The CPCB Audit Failures Driving Plant Shutdowns
• Election-Year Policy Risk: How a Change in Government Could Reshape India’s Recycling Rules

Frequently Asked Questions

Is there a law in India right now that requires textile brands to recycle garment waste?

As of September 2026, India has no standalone EPR rule specific to textiles or apparel. However, textile manufacturing units that use hazardous chemicals fall under the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016, which requires State PCB authorisation and manifest-based waste tracking. Listed apparel companies must also meet BRSR Core waste disclosure obligations under SEBI’s circular of 12 July 2023. A dedicated textile EPR rule is anticipated in FY 2026-27.

Which government body will regulate a textile EPR scheme in India?

The Ministry of Environment, Forest and Climate Change (MoEFCC) will be the primary notifying authority, as it is for all EPR rules under the Environment Protection Act, 1986. The Central Pollution Control Board (CPCB) will administer producer registration, EPR credit issuance and trading, and compliance enforcement — the same model used for plastic waste, e-waste, and battery waste. State Pollution Control Boards will handle mill-level inspections and authorisations.

What penalties could a textile brand face for non-compliance once a rule is notified?

Under the Environment Protection Act, 1986, penalties for violation of rules notified thereunder can reach imprisonment of up to five years and fines. In practice, the CPCB’s enforcement model for EPR categories uses Environmental Compensation Fund (ECF) deposits — under the Plastic Waste Management framework, ECF rates for shortfalls in EPR obligations have reached ₹10,000 per tonne of uncollected waste. Textile EPR penalties are likely to follow a similar ECF-plus-escalation structure, with CPCB empowered to direct portal access suspension for persistent defaulters.

Does the EU textile EPR rule apply to Indian exporters directly?

The EU’s revised Waste Framework Directive, which mandated separate textile collection from 1 January 2025, applies to producers placing goods on the EU market — primarily EU-based brands. However, Indian exporters are commercially impacted because European buyers now require supply-chain ESG documentation, including evidence of factory waste recycling, as a contract condition. Failure to provide fibre-sorting or recycling certificates (GRS/RCS) is increasingly grounds for supplier downgrading, even where no direct legal liability falls on the Indian factory.

How should an apparel brand document its garment waste for BRSR Core reporting?

SEBI’s BRSR Core framework (circular dated 12 July 2023) requires disclosure of total waste generated (in metric tonnes), waste intensity (per unit of production or revenue), and the proportion recycled, reused, or sent to landfill. Brands must maintain weigh-bridge records at the point of waste dispatch, recycler certificates confirming input and output weights, and GST invoices from registered recyclers. Third-party assurance of these figures is mandatory for the top 150 listed companies from FY 2024-25. Records should be retained for a minimum of five years to satisfy any SEBI inspection.

Work With The National Recycling Corporation

The National Recycling Corporation is a Mumbai-headquartered, pan-India waste management and scrap trading company with established recycling partnerships across Maharashtra, Tamil Nadu, Gujarat, Karnataka, and Telangana. We work with apparel manufacturers, textile mills, retail chains, and garment exporters to establish auditable, document-complete textile waste disposal channels — built to the standard that EPR frameworks and export-buyer ESG audits will require.

Our documentation package for every client engagement includes GST-compliant disposal invoices, weigh-bridge receipts, and certificates of recycling or destruction — the precise document set your BRSR Core report and future EPR filings will need. We price fairly against prevailing fibre and material recovery rates, and we do not operate informal channels that create audit liability for your compliance team.

What we offer textile and apparel clients specifically:

• Scheduled bulk collection of pre-consumer cutting waste from factory floors in Mumbai, Thane, Surat, Tiruppur, and Bengaluru
• Fibre-segregated disposal with separate handling for cotton, polyester, and blended waste
• Certificate of recycling issued per consignment, suitable for BRSR Core and export-buyer ESG submission
• GST-compliant invoicing with correct HSN classification, traceable on the GST portal
• BRSR-grade waste generation and recycling reports on a quarterly basis
• EPR readiness advisory — structuring your take-back loop now so registration is straightforward once the textile EPR rule is notified
• Support for hazardous chemical waste streams (dye sludge, finishing waste) through CPCB-authorised hazardous waste disposal partners

To discuss your factory’s textile waste volumes and set up a collection agreement, contact us through our website. You can also review our full list of materials we buy and process or learn more about our EPR compliance services.

Sources and References

• Ministry of Environment, Forest and Climate Change (MoEFCC) — Environment Protection Act, 1986 and EPR Rule notifications
• Central Pollution Control Board (CPCB) — EPR framework administration and enforcement
• CPCB — Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016
• CPCB EPR Portal — Plastic, Battery, and E-Waste producer registration and credit trading
• NITI Aayog — Circular Economy and Resource Efficiency Policy
• Bureau of Indian Standards (BIS) — Textile and recycled fibre quality standards
• Press reports — Business Standard and Economic Times coverage of MoEFCC-Ministry of Textiles stakeholder consultations, February 2025 (referenced generically)
• European Commission — Revised Waste Framework Directive (Directive 2008/98/EC as amended), mandatory separate textile collection from 1 January 2025