American Circular Textiles: A National Blueprint for Effective EPR
American Circular Textiles (ACT) presents a national blueprint for effective Extended Producer Responsibility (EPR) for textiles, aimed at strengthening U.S. manufacturing, building recycling infrastructure, and preventing the pitfalls seen in fragmented state-level approaches. The paper outlines how EPR can drive circularity and economic growth if designed with strategic incentives, infrastructure investment, and a unified federal framework.
American Circular Textiles (ACT) presents a national blueprint for effective Extended Producer Responsibility (EPR) for textiles, aimed at strengthening U.S. manufacturing, building recycling infrastructure, and preventing the pitfalls seen in fragmented state-level approaches. The paper outlines how EPR can drive circularity and economic growth if designed with strategic incentives, infrastructure investment, and a unified federal framework.
American Circular Textiles (ACT) presents a national blueprint for effective Extended Producer Responsibility (EPR) for textiles, aimed at strengthening U.S. manufacturing, building recycling infrastructure, and preventing the pitfalls seen in fragmented state-level approaches. The paper outlines how EPR can drive circularity and economic growth if designed with strategic incentives, infrastructure investment, and a unified federal framework.
Executive Summary
Extended Producer Responsibility (EPR) presents an opportunity to align sustainability with economic growth. A well-structured EPR system can complement state and federal tax incentives to drive investment in domestic textile recycling, infrastructure, and job creation, strengthening the U.S. supply chain while reducing waste. A 2025 economic analysis by the National Association of Manufacturers (NAM) and Ernst & Young (EY)[1] underscores the risks associated with expiring federal tax provisions that have historically supported U.S. manufacturing. The report indicates that the phase-out of key incentives, such as immediate R&D expensing and full capital investment expense, threatens nearly 6 million jobs and $1.1 trillion in GDP, highlighting the urgent need for additional policies that reinforce domestic industry, of which well-implemented EPR programs can play a role.
Effective EPR will enable the future of U.S. manufacturing by converting existing materials and products for reuse and recycling, and in doing so, enabling new material markets, jobs, and resource efficiency. However, if not implemented correctly, it risks becoming another ineffective and burdensome mandate that increases costs on businesses without delivering results.
Several state-level packaging EPR bills have already encountered significant obstacles. California’s Senate Bill 54, the Plastic Pollution Prevention and Packaging Producer Responsibility Act of 2022 (SB 54), despite its ambitious targets, has been criticized for a lack of sufficient enforcement mechanisms and potentially failing to support necessary recycling technologies or create scalable infrastructure, which risks continued reliance on landfills.[2] France’s EPR for Textiles, one of the most established textile EPR systems, has struggled with massive textile stockpiles due to a lack of viable processing solutions, primarily because of insufficient investment in recycling infrastructure. Meanwhile, Oregon’s recent recycling overhaul, aimed at packaging and recycling reforms, has resulted in higher compliance costs for businesses, while collection and processing infrastructure remains underdeveloped.[3] Lessons from these other EPR frameworks suggest that domestic textiles regulations could face similar hurdles if policies are not aligned with infrastructure capacity and market realities.
ACT made significant contributions to the final version of California’s SB 707 – Responsible Textile Recovery Act of 2024. Its passagemarks a pivotal moment in regulatory momentum for circular textiles. However, without a harmonized national strategy, the industry risks navigating a fragmented patchwork of state regulations, leading to increased compliance costs and inefficiencies while failing to achieve true circularity at scale. While key state-level EPR principles that drive investment, align market incentives, and ensure fair industry participation will be a step in the right direction, the most effective system will ultimately be a unified federal waste framework.
[1] National Association of Manufacturers & Ernst & Young LLP. Economic Impacts of the Expiration of Tax Policies https://nam.org/wp-content/uploads/securepdfs/2025/01/NAM_EY_TCJA_Mfg_Provisions_Analysis.pdf
[2] Resource Recycling. How SB 54 Went from Twice-Failed Bill to Landmark EPR. October 17, 2022. https://resource-recycling.com/recycling/2022/10/17/how-sb-54-went-from-twice-failed-bill-to-landmark-epr/
[3] Resource Recycling. Oregon Finalizes EPR Rulemaking, PRO Submits Plan. December 11, 2024 https://resource-recycling.com/plastics/2024/12/11/oregon-finalizes-epr-rulemaking-pro-submits-plan/