UPV textile reporting tool
Reporting your volumes is the easy part of the UPV textiles scheme. The difficult part is that the decision sets four targets for what happens to textiles you no longer have in your possession: prepared for re-use or recycling, prepared for re-use, prepared for re-use in the Netherlands, and fibre-to-fibre recycled. For these you need to be able to demonstrate a percentage.
Four targets, all rising
The Decree on Extended Producer Responsibility for Textiles has applied since 1 July 2023 and covers newly manufactured textile products in the categories of clothing and household textiles. Carpets, mattress filling and technical textiles are currently excluded, which for some companies removes half their range. Do plan for that boundary to shift: the revised European framework directive extends the scope to include footwear, home textiles, curtains and leather clothing, among other things, and the Netherlands must transpose this by 17 June 2027. The decree with the current scope is available at wetten.overheid.nl. Anyone who places such products on the Dutch market for the first time must register and submit an annual report covering the previous calendar year before 1 August. Rijkswaterstaat administers this, and the Inspectie Leefomgeving en Transport supervises compliance.
The targets are set out in four articles, and they all increase over time. Article 3 requires that 50 per cent of the weight you sold the previous year is prepared for reuse or recycling in 2025, rising by five percentage points a year to 75 per cent from 2030. Article 4(1) requires 20 per cent to be prepared for reuse in 2025, rising by one percentage point a year to 25 per cent from 2030. Article 4(2) requires that, within that, 10 per cent is prepared for reuse in the Netherlands in 2025, likewise rising by one percentage point a year to 15 per cent from 2030. And Article 5 requires that 25 per cent of the textile that is recycled goes fibre-to-fibre in 2025, rising to 33 per cent from 2030. Four targets, four separate series, and different figures every year.
This is where the problem lies, and it is not your bookkeeping. You know what you sold. You don't know what happens two years later to a jumper that someone drops in a clothing bank, yet the decree holds you accountable for it. Your evidence therefore has to come from the chain: from the collector, the sorter and the recycler. And because the percentages build on one another, a single figure per processor is not enough. You need the breakdown that they rarely provide on their own initiative.
Textiles also come first under the Ecodesign Regulation, where they are the first product group to receive a digital product passport. That requires data per item rather than per category; see software for the product passport.
If you also supply other EU countries, those have their own registration requirements and their own rhythm. For how to keep track of these by country and by waste stream, see EPR software.
How we build your reporting tool
The order is the reverse of what most companies expect. We don't start with the report, but with the question of who at the end of the chain can demonstrate something.
Which collectors, sorters and recyclers you or your producer organisation work with, and in what form they supply their figures. What they don't break down, you cannot report; that is the first hard boundary, and you'd rather learn it now than in July.
Which items are clothing or household textiles and which are not, and what weight belongs to each. Completing this is work that precedes the software, and you carry it out yourself or with your supplier.
Each sprint ends with a piece you can check yourselves, and we start with the target that will cost you the most. Your own people test against a closed period whose outcome they already know.
We have the tool calculate a closed year and set the outcome against what you had determined yourselves. Differences almost always point to a processor counting differently from what you assumed.
What the tool actually does
The emphasis lies on the chain side, not on the reporting obligation. Six components: the first three concern your own figures, and the last three concern what others need to supply to you.
Volumes from your own systems
Sales and returns from your ERP or stock system form the base on which each of the four percentages rests. If that count lives in a separate spreadsheet, your report is almost certain to drift out of line with your annual accounts.
Clothing and household textiles defined
For each item, record whether it falls under the decree, along with the reason. If you also sell carpets, curtain fabric or technical textiles, those should now stay outside the base. Because the scope shifts in 2028, we record that assessment per item with a date rather than fixing it in a static list.
Collecting weights from suppliers
A portal through which your producer submits the weight per item, with a list of what is still missing. If your product data sits in a PIM, the weight belongs there rather than in a second administration.
Processing data broken down
Per processor and per stream: what was prepared for reuse, what went to recycling, what stayed in the Netherlands, and what share of the recycling was fibre-to-fibre. Those are precisely the breakdowns the four targets require, and precisely what you rarely receive unprompted.
Four targets calculated separately
The tool calculates each target against the percentage that applies to that reporting year, and shows which target you are likely to miss while there is still time to act. The targets shift every year, so a hard-coded figure becomes wrong after a single year.
Reporting with traceable evidence
Every percentage can be traced back to the submission it came from, with the calculation method preserved. When questioned, you can show not only the figure but also who supplied it.
Who we build for
The scheme affects four types of business, and the difference lies mainly in how far you are from the waste stage.
Brands and producers
You design and have products manufactured, so weights can be requested from your producer. Your real challenge lies on the other side: you know your end customer, but not what they do with the product. See also software for the textile sector, which concerns your collection, PLM and order flow rather than the waste stage.
Importers and distributors
You buy from an overseas producer and are therefore the first to place the product on the market here. Your most difficult position: you sit furthest from the waste stage and have the least grip on who can account for it.
Retail with an own collection
Only your own-label range counts; what you resell from other brands does not. If you have a collection bin in-store, you are also on the supply chain side yourself and can provide the evidence rather than having to ask for it. That is the most favourable position this scheme offers.
Workwear and textile services
Work clothing falls under clothing; linen under household textiles. Your advantage is that you take products back at the end of their life yourself, and so know precisely where they went. That is the position the rest of the market is trying to reach.
Test your idea first: a working prototype in 1 day
With OneDayBuild, we turn your idea into something tangible in one day for €1,150, so you can see whether further development is worth the investment. Decide to go ahead with the full build? Then we credit the full cost.
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Two things shape the build. The first is that processors deliver their figures in ten different formats. The second is that the percentages shift every year, so they belong in a configuration setting rather than in the code.
Why Appfront
The evidence comes from outside your business
This is not an accounting problem. The targets concern goods you no longer hold, so we build the submission side first and the report afterwards.
Four targets, no single fixed figure
Articles 3, 4(1), 4(2) and 5 each measure something different, and each rises every year. Anyone who treats them as a single percentage or hardcodes them may have to redo the work next year.
One denominator for all four
Your sales figures already exist somewhere. We retrieve them through integrations, so the four percentages rest on the same denominator as your turnover.
Honest about what we cannot do
If your processor does not provide a breakdown, no tool can invent one. We make visible what is missing and from whom; the conversation with that party is one you will need to have yourself.
Security and privacy
This reporting contains hardly any personal data, but it does contain sensitive commercial information: your sold volumes per category are a direct derivative of your turnover and market position. For businesses that work for multiple brands, confidentiality towards those brands is also at stake. We therefore keep access tightly controlled and separate data by entity.
The supply chain side requires something extra. You collect figures from collectors and recyclers, and those submissions also reveal something about their own operations. A processor who sees what its competitor delivers will deliver less next time. Each submitting party therefore receives its own, separately protected access point. And because the ILT may audit the report, we retain submitted figures exactly as they were received: a later correction is visible as a correction and does not overwrite the original. We record the calculation method per reporting year, because it changes over time, while older reports rest on the rules that applied at that moment. Our own approach to security is set out in our information security policy; reports from outside parties go through our responsible disclosure policy.
Frequently asked questions about UPV textiles
Newly manufactured textile products in the clothing and household textiles categories. Carpets, curtain fabric, mattress filling, footwear and technical textiles are in principle excluded. This is the first boundary you need to draw, and for some businesses it removes half the range. If you are unsure about a product group, record the assessment together with the reason, because that is what the ILT will ask for.
Four, and all four increase over time. Article 3: 50 per cent prepared for reuse or recycling in 2025, rising by 5 percentage points a year to 75 per cent from 2030. Article 4(1): 20 per cent prepared for reuse, rising to 25. Article 4(2): within that, 10 per cent prepared for reuse in the Netherlands, rising to 15. Article 5: 25 per cent of the recycled textile goes fibre-to-fibre, rising to 33 per cent. Always check the percentage that applies to your own reporting year.
You cannot do that yourself; the evidence comes from the collector, the sorter and the recycler. What you can do is enforce that submission in the form the four targets require: not a single tonnage, but a breakdown into prepared for reuse, reuse in the Netherlands, recycling, and the fibre-to-fibre share of that. If you belong to a producer organisation, this largely runs through them, and the question is mainly whether their breakdown is detailed enough.
Annually, before 1 August, covering the previous calendar year, to Rijkswaterstaat. In practice, this means you need the chain figures for the previous year complete in the first half of the year, which is why you should collect them continuously. Processors deliver slowly, and by June there is no time left to enforce a breakdown after the fact.
For collections that change each season, this is an ongoing task rather than a one-off catch-up. The weights sit with your producer; the practical route is a portal in which they supply them per item, linked to your purchase order so that a new item without a weight is flagged before it is sold. Estimating is possible, provided you document the method.
The decision concerns what is placed on the Dutch market. What you import and then re-export should in principle not be included in the denominator, and that is more than a detail: an inflated denominator pulls all four of your percentages down at once. Have your lawyer establish the precise treatment or check with Rijkswaterstaat; we will make sure the system tracks both flows separately.
It takes over part of the obligations, usually collection and the reporting on it. What remains with you are your own volumes per category and whether the breakdown you receive back is detailed enough for all four targets. An organisation that only returns a total recycling percentage leaves you exposed under Article 4(2) and Article 5.
Then you are additionally subject to the WEEE rules, with a different register and a different deadline. The administration looks similar, but the difficulty lies elsewhere: there the hard question is which of your articles count, whereas here you usually know that and the difficulty lies in the evidence from the supply chain. See WEEE reporting and collection administration.
Ready to build a UPV reporting tool?
The quickest way to see where you stand: send us the breakdown you received last year from your processor or producer organisation. It shows which of the four targets you can demonstrate at all. We build this as a standalone application and as part of a broader custom software project. The PPWR applies to the requirements for the packaging itself; see PPWR software.