CRNI responds to consultation on Ireland’s Textiles EPR Delivery Plan

Community Resources Network Ireland (CRNI) has submitted a response to the Department of Climate, Energy and the Environment’s consultation on the Textiles Extended Producer Responsibility (EPR) Delivery Plan.

Almost 45 percent of CRNI’s membership is active in the textiles sector, working across reuse, repair and recycling, and this submission has been prepared with direct input from CRNI’s textiles members.

CRNI welcomes the department’s intention that the scheme should uphold the waste hierarchy, support the social economy and strengthen existing reuse and repair systems, but argues these principles need to be built into the design, governance, financing and operation of the scheme, not treated as secondary measures. The EPR cannot meet its legal waste hierarchy obligations without a strong reuse system, and a highly centralised model driven by tonnage or processing volumes risks diverting reusable material away from existing community organisations towards large-scale waste management routes.

Among other recommendations, CRNI’s submission calls for:

• Community-based reuse and repair organisations and social enterprises to be explicitly recognised as delivery partners within the EPR system, rather than solely as stakeholders or potential beneficiaries of funding;
• Full and transparent coverage of the reasonable and necessary costs of collection, transport, sorting and preparation for reuse where these activities are carried out as part of the EPR system, alongside a dedicated investment allocation for reuse and repair infrastructure and capacity;
• Reuse-first access to textile streams suitable for reuse or preparation for reuse, before materials are allocated to recycling, export or lower-order treatment;
• Mandatory and continuing representation for social enterprise, charitable and non-profit reuse organisations within the governance of the Producer Responsibility Organisation, including its Advisory Committee and relevant working groups;
• Eco-modulation criteria based on durability, repairability, expected product lifetime and reuse potential, so producer fees create a meaningful incentive towards longer-lasting and more circular design.

Read CRNI’s full submission to the consultation on the Textiles EPR Delivery Plan here.

• September 10, 2026