ESPR explained: what the EU ecodesign regulation means for textiles
The Ecodesign for Sustainable Products Regulation extends EU product design rules to clothing and footwear. What it requires, what is already in force and what is still being drafted.
KEY TAKEAWAYS Summary by the editors
- The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, entered into force on 18 July 2024 and covers almost all physical goods placed on the EU market.
- It is a framework law: product-specific requirements for textiles will come through a delegated act, which the Commission has indicated it plans to adopt around the end of 2027.
- A ban on destroying unsold apparel and footwear applies to large enterprises from 19 July 2026 and to medium-sized enterprises from July 2030, with micro and small enterprises exempt.
- Likely textile requirements include durability, repairability, recyclability, recycled content and information through a Digital Product Passport.
- Design, sourcing and product data decisions made in the next few seasons will determine how easily a brand can comply.
For decades, EU ecodesign rules were about fridges, lamps and washing machines. The Ecodesign for Sustainable Products Regulation, known as ESPR, changes that. It allows the EU to set binding design and information requirements for almost any physical product, and textiles are at the front of the queue. For fashion brands selling in Europe, it is the regulation most likely to change how collections are designed and documented.
What is the ESPR?
The ESPR, Regulation (EU) 2024/1781, entered into force on 18 July 2024 and replaced the earlier Ecodesign Directive, which was limited to energy-related products. The new regulation applies to virtually all physical goods on the EU market, with limited exceptions such as food, feed and medicinal products.
It works in two layers. The regulation itself sets the framework and a few direct obligations. Concrete requirements for a product group are then set by the European Commission in delegated acts, after studies and stakeholder consultation. That means the ESPR on its own does not yet tell a brand how durable a T-shirt must be; the textile delegated act will.
The ESPR also contains horizontal tools that will matter to fashion: rules on green public procurement for some product groups, market surveillance powers for national authorities and the legal basis for the Digital Product Passport. Obligations fall on economic operators such as manufacturers, importers and distributors, so brands that rely on third parties to import or distribute their products will need to agree who is responsible for what.
What kinds of requirements can it set?
The ESPR lists the aspects that product rules can address. Not every aspect will apply to textiles, but the list shows the range of possibilities.
| ESPR aspect | Possible meaning for apparel |
|---|---|
| Durability and reliability | Minimum performance on pilling, colour fastness, seam strength or dimensional stability |
| Reusability, repairability, upgradability | Spare parts, replaceable components, repair information |
| Recyclability and recycled content | Limits on hard-to-recycle fibre blends, minimum recycled fibre share |
| Substances of concern | Tracking or restricting substances that hinder recycling |
| Environmental footprint | Information on footprint or performance classes |
| Information requirements | Data made available through a Digital Product Passport and labels |
The textile measures will be defined after technical work by the Commission and its research services. Brands should treat the right-hand column as indicative, not as a forecast of specific thresholds.
What applies already: the ban on destroying unsold goods
One part of the ESPR applies directly without a product-specific act. The regulation prohibits the destruction of unsold apparel, clothing accessories and footwear. According to the Commission, the ban applies to large enterprises from 19 July 2026 and to medium-sized enterprises from July 2030. Micro and small enterprises are exempt.
There are narrow derogations, set out in secondary legislation, for cases such as safety risks, legal non-compliance, intellectual property concerns, significant damage or where donation efforts have failed. Companies in scope must also disclose information about unsold products they discard, using a harmonised reporting format set out in an implementing regulation.
When will textile requirements arrive?
In April 2025 the Commission adopted its ESPR working plan for 2025 to 2030, which names textiles, with an emphasis on apparel, as a priority product group alongside products such as steel, aluminium, furniture, tyres and mattresses. The Commission's information on the textile passport indicates a planned adoption of the textiles delegated act in the fourth quarter of 2027. Requirements typically apply after a transition period.
As of autumn 2026, the content of that act is still being prepared. Timing for EU secondary legislation can move, and the final requirements may differ from early proposals. Brands should follow official Commission communications and consultations rather than secondary summaries.
How should brands prepare now?
- Product data: make sure composition, care and origin information is held per variant in a system, not in documents.
- Material choices: review fibre blends that are hard to recycle and assess where mono-materials or easier separation are realistic.
- Durability testing: document quality testing you already do, so you can show performance when requirements arrive.
- Unsold stock: design end-of-season routes that avoid destruction and record what happens to every unsold unit.
- Consultations: follow, and where relevant contribute to, Commission consultations on the textile measures.
The ESPR rewards brands that already know their products well. Companies with weak product data or opaque supply chains will find compliance expensive, while those with good data will find much of the work is reporting what they already know. This article is general information, not legal advice; companies should seek legal advice for their specific case.
Frequently asked questions
Does the ESPR apply to brands based outside the EU?
The ESPR applies to products placed on the EU market, regardless of where the company is based. Non-EU brands selling into the EU will therefore be affected, and obligations fall on the relevant economic operators defined in the regulation.
Is the destruction ban a ban on all disposal?
No. It prohibits destroying unsold apparel, clothing accessories and footwear, subject to specific derogations. Products can still be resold, donated, reused or prepared for recycling, and companies must disclose information about unsold products they discard.
What is the link between the ESPR and the Digital Product Passport?
The Digital Product Passport is created by the ESPR. Each product-specific delegated act decides whether a passport is required and what information it must carry.
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