The Regulatory Framework That Will Reshapethe Textile Industry

A central element of the ESPR framework is the distinction between two types of requirements: performance requirements and information requirements. Performance requirements directly determine whether a product can be placed on the EU market. They define minimum criteria that products must meet. If a product does not comply with these requirements, it may no longer be sold in the European Union. In other words, performance requirements can effectively determine market access. Information requirements, on the other hand, are designed to provide transparency. They inform consumers, authorities and other stakeholders about the environmental performance of a product. These requirements will be implemented primarily through the Digital Product Passport and possibly through product labels. Potential product aspects that may be regulated include durability, reparability, recycled content, recyclability, environmental footprint and waste generation. Which of these aspects will be regulated for textiles is currently being examined in detailed preparatory studies and impact assessments.

The development of textile-specific ecodesign requirements follows a structured and highly technical process. Scientific studies, economic analysis and impact assessments form the basis for future legislation. The European Commission’s Joint Research Centre is currently conducting the preparatory study for textiles, analysing environmental impacts, economic implications and possible regulatory measures. Based on the current analysis, the first regulatory steps for textiles are likely to focus primarily on information requirements, particularly through the Digital Product Passport. Performance requirements may follow later, for example in the form of minimum recycled content requirements or durability criteria. The impact assessment phase is expected to continue until the end of 2026. The delegated act for textiles is currently expected around 2027, followed by an implementation period of at least 18 months. This means that the new rules could realistically start applying around 2029. For companies, this timeline may seem long. But given the complexity of textile supply chains and the technical requirements, the transition period is actually relatively short.

One of the most important tools introduced under the ESPR is the Digital Product Passport (DPP). The DPP will function as a digital identity for products and will contain structured information about a product’s composition, environmental performance, repairability and other relevant characteristics. The DPP is intended to serve multiple purposes at the same time. For consumers, it will provide reliable and structured information about products, increasing transparency and trust. For companies, it can help improve supply chain transparency, simplify compliance and potentially enable new business models. For authorities, it will improve market surveillance and enforcement, particularly with regard to imported products from third countries. The system will be decentralised, meaning that data will not be stored in one central database but will remain with the economic operators, while being accessible through standardized identifiers and data carriers such as QR codes or similar technologies. Access to data will likely be structured in different levels. Consumers, repair services, recyclers and authorities may have different access rights depending on their role and needs. In addition, companies will be required to ensure that a backup copy of the data exists, so that information remains available even if a company ceases to exist. This is particularly important for circularity, repair and recycling.

In addition to the Digital Product Passport, the EU is also considering new product labels under the ESPR framework. One possible model is a label similar to the well-known EU energy label. This label would not focus on energy consumption alone, but could display several environmental performance indicators. Exactly which information will be shown on such labels is still under discussion. It is possible that only selected key indicators will be displayed, or that a single aggregated score could be used. These decisions will be made separately for each product group. The aim is to make sustainability information understandable and comparable for consumers, without overwhelming them with too much technical detail.

Dr. Hrčková emphasized that the legislative process relies heavily on stakeholder input. Industry data, practical experience and technical expertise are essential for designing workable regulations. The Commission is therefore conducting consultations, stakeholder workshops and expert forums throughout the process. This is particularly important for textiles, as the sector has one of the most complex global value chains of any industry. The regulation must consider impacts on small and medium-sized enterprises, global supply chains and international trade partners. The Commission is therefore not only analysing environmental impact, but also economic and social effects, as well as the administrative burden for companies.

One important message from the presentation was that regulation will likely follow a step-by-step approach. It may start with data collection and information requirements before moving towards stricter performance requirements later. This approach allows companies to build data systems, gain experience and adapt gradually before binding performance thresholds are introduced. It also reflects a broader shift in European product policy: from regulating individual materials or processes to regulating entire products and their lifecycle performance.

For the textile and fashion industry, the ESPR and the Digital Product Passport represent more than just another compliance exercise. They will fundamentally change how products are designed, documented and marketed in Europe. In the future, sustainability performance will increasingly become a condition for market access, not just a marketing claim. At the same time, data will become a central business asset. Companies will need to know much more about their products, their materials and their supply chains than many do today. The regulation will also create a more level playing field, particularly with regard to imports. Improved market surveillance and standardised product information should make it easier for authorities to check whether imported products comply with EU rules.

The ESPR framework shows a broader shift in European policy: transparency is no longer an end in itself. It is the starting point for transformation. Once reliable product data exists, it becomes possible to set performance requirements, create circular systems and reward better products. For companies, the key question is therefore no longer whether these changes will come, but how quickly they can prepare for them. The timeline may seem long, but building data systems, redesigning products and restructuring supply chains takes years.. The companies that start early with data management, product transparency and circular product design will be in a much stronger position when the new rules become binding. In that sense, the ESPR is not just an environmental regulation. It is a market transformation framework – and textiles are at the center of it.