.avif)
The European Commission is preparing product-specific ecodesign requirements for textile apparel under the Ecodesign for Sustainable Products Regulation.
As the technical work progresses, organisations representing textile manufacturers, apparel brands, sporting goods companies and environmental interests are publishing recommendations on how these requirements should be designed.
These documents do not represent the Commission’s final position or binding requirements. They show where stakeholders agree, where their priorities differ and which implementation questions remain open.
The technical baseline comes from the European Commission’s Joint Research Centre, orJRC. The JRC is the Commission’s science and knowledge service. It conducts research and develops the evidence and policy options that the Commission can consider when preparing legislation.
For textile apparel, the JRC is conducting thePreparatory Study on Textile Products. Its work examines potential ecodesign requirements and possible Digital Product Passport content. The JRC documents are technical inputs, not the final Textile Delegated Act.
The stakeholder positions considered in this article come from the following organisations:
FESI, the Federation of the European Sporting Goods Industry, represents companies across sportswear, technical apparel, footwear, outdoor products and sporting goods. ItsOctober 2026 position paper specifically addresses the future ESPR Textile Delegated Act. It provides recommendations particularly relevant to technical and performance apparel.
EURATEX, the European Apparel and Textile Confederation, represents European textile and clothing manufacturers. ItsMarch 2026 position paper on the Digital Product Passport for apparel focuses on mandatory information, data access, confidentiality, interoperability, implementation costs and enforcement.
The Policy Hub – Circularity for Apparel & Footwear is an industry policy initiative launched by Cascale, Global Fashion Agenda and FESI. It brings together companies and organisations across the apparel and footwear value chain. ItsMarch 2026 analysis examines the feasibility of the textile ecodesign options under discussion, while itsposition on lifecycle assessment calls for a harmonised methodology across the EU Single Market. This article considers only the recommendations relevant to textile and apparel products.
A joint textile value-chain statement on substances of concern brings together organisations representing textile manufacturers, chemical suppliers, apparel brands, sporting goods companies, retailers and textile services. Its signatories includeEURATEX,FESI,AFIRM,ETAD,EBCA,IAF,ETSA and EuroCommerce.
ECOS, the Environmental Coalition on Standards, is an environmental NGO working on technical standards, product policy and legislation. Its recent publications addressmicroplastic release from apparel and therevision of the EU Textile Labelling Regulation, providing an environmental counterpoint to industry positions.
Both FESI andEURATEX support the introduction of Digital Product Passports for apparel. Their positions focus on ensuring that mandatory datasets remain proportionate and operationally manageable.
EURATEX argues that the mandatory DPP should be limited to information required by legislation. Companies could add sustainability labels or other voluntary information, but these elements should remain clearly separated from the mandatory dataset.
The organisation also calls for differentiated access rights. Consumers, authorities, recyclers and other actors would access different information according to their roles. Commercially sensitive data, including supplier networks and production methods, should remain protected.
FESI similarly proposes beginning with a defined core dataset that can evolve as systems, methodologies and supply-chain data mature. Its recommendations also cover interoperability, technological neutrality, data ownership, business continuity and flexibility in data-carrier placement.
The common industry position is not opposition to the DPP. It is a request for clearly defined mandatory information, controlled access and an implementation model that can operate across complex supply chains.
A central question is how textile products should be categorised and assessed.
FESI argues that technical sportswear, performance apparel and lifestyle garments cannot always be evaluated through identical criteria. The Federation notes, for example, thatsocks and T-shirts should not be assessed through identical durability frameworks because their typical failure modes and end-of-life drivers differ.
Its position therefore calls for sufficiently detailed product categories and testing methods that reflect intended use and product construction.
This distinction matters because the Delegated Act may introduce requirements or scoring systems based on attributes such as robustness, repairability and recyclability. If categories are too broad, the results may not accurately reflect the function or expected lifetime of different apparel products.
Durability is widely recognised as a priority, but stakeholders differ on how it should be regulated.
The JRC’s preparatory work examines options for assessing textile robustness and communicating the results. FESI recommends initially treating robustness primarily as an information requirement while testing methods and product classifications are further refined.
ECOS argues that the future framework should include mandatory minimum ecodesign requirements rather than relying only on consumer-facing information. This position is presented in itsJune 2026 webinar materials on the future ecodesign rules for apparel.
The distinction is significant:
The final Delegated Act may combine both mechanisms.
Recycled content is another area in which stakeholders broadly support the objective but question how compliance should be calculated and verified.
FESI supports recycled-content requirements but proposes allowing regulatory compliance to be calculated at an aggregated operator level in certain circumstances. Product-specific environmental claims would still need to reflect the characteristics of the individual product.
This approach could provide companies with more flexibility where recycled fibres are not consistently available for every production run. It would also raise questions about how aggregated compliance should be documented, verified and connected with product-level Digital Product Passports.
The Policy Hub’sMarch 2026 analysis also highlights the importance of fibre availability, recycling infrastructure, verification systems and calculation methodologies. It argues that the environmental ambition of the rules must be supported by methods that can operate across global apparel supply chains.
The open question is therefore not only how much recycled content should be required, but also at which level it should be calculated and which evidence companies will need to maintain.
The Policy Hub calls for a harmonised lifecycle assessment methodology across the EU Single Market.
Without a common approach, companies could face different methods for calculating or substantiating environmental performance under different EU initiatives. The organisation calls for clarity on system boundaries, lifecycle stages, primary data and the relationship between product rules and environmental claims.
This debate affects both compliance and communication. If environmental-footprint information is included in a Digital Product Passport, the underlying calculation method must be sufficiently consistent to make the information meaningful and comparable.
The future Delegated Act is expected to specify how the ESPR information requirements for substances of concern will apply to textile apparel.
The joint statement signed by EURATEX,FESI,AFIRM,EuroCommerce and other value-chain organisations asks the Commission to clarify the relationship between the ESPR and existing EU chemicals legislation, particularly REACH.
The signatories call for:
The objective is to avoid duplicate or conflicting reporting obligations while enabling relevant chemical information to follow the product and support its end-of-life management.
ECOS argues that the future rules should address microplastic release from apparel.
Its recommendations refer to existing testing methodologies and propose measures targeting the design and manufacturing factors that can influence fibre shedding.
This position goes beyond requiring companies to disclose information. ECOS calls for concrete policy options capable of reducing microplastic pollution from clothing, including potential performance requirements.
The FESI paper also addresses the need for reliable testing and product categorisation. The debate therefore concerns both the environmental objective and whether available methodologies are sufficiently robust for use in mandatory product requirements.
The Textile ESPR Delegated Act and the revision of the Textile Labelling Regulation are separate initiatives, but their information requirements will nevertheless need to work together.
Industry organisations generally support a more digital-first approach. FESI argues that physical labels should remain limited and that more detailed information should be made available digitally, reducing label size, translations and duplicated information.
ECOS also supports digital access to extended information, but argues that essential information should remain directly available on the physical label. Its recommendations address areas such as size, origin and care, with further detail made available digitally.
The discussion is therefore not simply about choosing between physical and digital labels. It concerns which information must remain immediately visible on the product and which information can be maintained, translated and accessed through the Digital Product Passport.
Under the ESPR, the application date of a product-specific delegated act should generally be no earlier than 18 months after its entry into force, except in duly justified cases. Industry organisations are requesting longer timelines for textile apparel.
EURATEX recommends a transition period of 24 to 36 months.FESI requests 48 months for robustness, recycled-content and environmental-footprint provisions. For substances-of-concern requirements, it requests at least 36 months, with up to 48 months for SMEs.
The final timing will be determined by the adopted Delegated Act. The positions nevertheless show that implementation is expected to involve more than publishing a consumer-facing passport. Companies may need to adapt product development, testing, procurement, compliance and data-management processes across multiple collections.
Stakeholder positions are not a preview of the final legal text. They are useful because they identify the requirements most likely to create operational complexity and the points on which the final approach is still contested.
For apparel companies, the documents provide early indications of where implementation effort may concentrate:
This distinction helps companies avoid two opposite risks: waiting for every technical detail before beginning, or building fixed systems around requirements that remain under discussion.
Companies can already map product and supplier data, clarify internal ownership, assess existing evidence and ensure that their systems can support different datasets and access levels, while decisions that depend on final product categories, calculation methods or mandatory thresholds should remain adaptable until the Delegated Act is adopted.
Following stakeholder positions therefore helps companies identify no-regret preparation, anticipate the functions and suppliers that may be affected, and recognise which implementation choices should not yet be treated as definitive.
Renoon supports fashion companies in translating regulatory developments into data models, internal responsibilities and implementation plans that can evolve with the final Textile ESPR requirements.
Speak with our team about preparing for the Textile ESPR requirements.
.png)
.avif)
.png)
.png)
