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Humana submits 57 comments on the draft Royal Decree on textile waste
04-09-2025
Humana has submitted 57 comments on the draft Royal Decree regulating the management of textile waste. Today is the deadline for the sector to submit its arguments on the text drawn up by the Ministry for Ecological Transition and Demographic Challenge (MITECO), which is intended to regulate the collection and management of textile waste in Spain and which, as it currently stands, ‘creates regulatory inconsistencies, is far removed from the operational reality of the sector and increases the legal uncertainty that already exists’.
The arguments presented by Humana are in addition to those of numerous other players in the sector. The pioneering organisation in the sector, with 38 years of experience, affirms that the Royal Decree, which establishes the powers of the extended producer responsibility (EPR) system and determines other key aspects for the sector, ‘represents a great opportunity to manage the textile flow well’. ‘Unlike other flows, this one is being reorganised at a legal level with a sector that has been fully active for several decades, with very active markets and numerous opportunities to explore in terms of circularity in its management,’ it adds.
‘However, the draft Royal Decree does not follow this line and relies almost entirely not only on the financing of the EPR, but also on its possible management, which will give it almost absolute power over everything that happens, which in certain cases cannot follow the current logic based on the waste hierarchy, which would be a serious mistake in the system,’ says the organisation.
‘On the other hand, free competition in the sector, not only at the level of current operators, remains in doubt in the time being,’ he continues, "We hope that the arguments put forward by the various stakeholders will restore the limited competitive margin established by Law 7/2022 of 8 April on Waste and Contaminated Soil for a Circular Economy and pave the way for innovation, efficiency and independence from subsidies. Until proven otherwise, well-managed textile waste is a resource of inestimable environmental, economic and social value. To think otherwise from the outset would mean having an unbalanced model that is much more expensive and even far removed from good environmental practices."
For the non-profit organisation, the legislative text ‘tiptoes around the real problem to be solved, which is waste prevention and reduction’. It denounces that this draft Royal Decree "on the one hand, attempts to sugarcoat and equate all social economy entities, knowing that only some legal entities enjoy privileges in management and financing. On the other hand, it directly attacks non-privileged organisations by adding conditional financing that, in addition to being discriminatory, goes against all sense and legality."
Humana urges MITECO to thoroughly review the draft, reinforcing its legal consistency, its environmental ambition and its commitment to the circular economy, avoiding the creation of a system that favours particular interests over the general interest.
