Waste Framework Directive (targeted) review completed

On 5 July 2023, the EU Commission proposed a targeted revision of the Waste Framework Directive (WFD) to reduce waste, namely food and textile waste, and limit the environmental impact of waste management. Following the ordinary legislative procedure, the final text was published in the Official Journal of the EU on 26 September 2025 and is set to enter into force on 16 October 2025, giving Member States until 17 June 2027 to effectively transpose the Directive into national law.

The revised Directive introduces binding food waste reduction targets for Member States to be achieved at the national level by 2030, with a 10% reduction in processing and manufacturing and a 30% per capita reduction at the retail and consumption levels, compared to the amounts of food waste generated between 2021 and 2023. The final text also introduces harmonised rules on Extended Producer Responsibility (EPR) for textile waste.

While the revised Directive introduced some positive advancements, it fell short in its ambition as it failed to address key structural shortcomings of packaging waste management in Europe while introducing a concerning reference to State-run Producer Organisations (PROs) regarding EPR obligations for the textile sector. Nevertheless, all is not set in stone. An opportunity to address the limitations of the revised text might sprout through the new Circular Economy Act.

Addressing the shortcomings: the potential of the Circular Economy Act

The upcoming Circular Economy Act, which the EU Commission will unveil by the end of 2026, presents a crucial opportunity to address structural deficiencies in waste management while supporting the attainment of the Packaging and Packaging Waste Regulation targets and the creation of an EU market for secondary raw materials.

To support these objectives, in our view, the new Act should ensure the proper enforcement of Article 8a of the WFD - strengthening and further harmonising EPR governing principles across the EU -, ban state-run PROs, and enshrine the recognition of the earmarking principle for EPR fees in EU law.

WHAT DID YOU MISS?   

9 September 2025: Approval of the text in plenary
26 September 2025: Publication of the final text in the Official Journal of the EU

WHAT'S NEXT?  

16 October 2025: Entry into force of the Directive
17 June 2027: Deadline for Member States to transpose the Directive into national