The Future ESPR Delegated Act for Textiles: 7 Impacts European Manufacturers Should Prepare For

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There is something paradoxical in legislating for a product that has not yet been defined. This is the position in which the European textile and apparel sector finds itself in June 2026: already identified as a regulatory priority, already subject to a legal framework in force, but still awaiting the delegated act that will specify, in technical terms, what will actually be required of a garment placed on the Union market.

The ESPR Framework and Delegated Acts

Regulation (EU) 2024/1781, which establishes the framework for setting ecodesign requirements for sustainable products — the ESPR — entered into force in July 2024. Its architecture differs from traditional product legislation precisely because it does not impose, from the outset, a uniform set of technical requirements. Instead, it creates an enabling mechanism: the European Commission may adopt, for each product group, delegated acts that determine which environmental performance and information requirements apply, how conformity must be demonstrated, and when the rules become binding. Textiles and apparel occupy the first position in the Ecodesign and Energy Labelling Working Plan 2025–2030, justified by the sector's potential to extend product lifespan, improve material efficiency, and reduce impacts associated with water consumption, waste generation, climate change and energy use.

The delegated act specific to textiles is scheduled for 2027, and the technical studies and stakeholder consultations that precede it have not yet fixed the thresholds, test methods or data fields that will ultimately define the concrete obligation. This indeterminacy, however, is not equivalent to an absence of direction. The ESPR itself already shapes the regulatory architecture within which the delegated act will operate, and it is possible, from this framework, to anticipate with reasonable confidence the effects that will fall on European manufacturers.

Key Point

The delegated act is not yet adopted, but manufacturers can begin preparing now. The regulatory direction is sufficiently clear to justify immediate action on data governance, testing protocols, and supply chain transparency.

Seven Regulatory Impacts to Prepare For

1. Durability as a Measurable Technical Requirement

The first impact concerns durability, which will cease to function as a broad statement of sustainability and will instead be treated as a measurable technical characteristic. The ESPR enables delegated acts to establish performance requirements relating to durability, reliability, reuse, repairability, maintenance and refurbishment; in the case of textiles, this may translate into requirements on dimensional stability, seam strength, abrasion resistance, colour fastness, pilling formation and the capacity to withstand repeated washing cycles. The shift is, above all, evidential: it will no longer suffice to describe a garment as durable on the basis of design intent or the company's accumulated experience. It will be necessary to hold test results, documented methodologies and technical files that demonstrate compliance with defined durability levels — a change that repositions product development decisions, previously evaluated mainly through cost and aesthetic considerations, also in light of legally relevant indicators.

2. Recyclability and Material Complexity

Recyclability follows a similar logic, though it shifts the centre of analysis from performance during use to the product's behaviour at end of life. The ESPR empowers the Commission to establish requirements relating to recyclability, material recovery and ease of disassembly or treatment of products. In the textile sector, this tends to pressure the reconsideration of complex fibre blends, coatings, laminated structures, adhesives and accessories that impede fibre-by-fibre sorting or recycling. A jacket that performs well during wear may still prove difficult to recycle precisely because it combines outer fabric, membrane, lining, filling, zip, elastic elements, printed labels and chemical finishes in inseparable structures. The ecodesign approach transforms this material architecture — until now a challenge left almost entirely to waste management operators — into a conformity issue that must be justified at the design phase. This does not mean that every textile product must become mono-material; it means that material complexity will henceforth require technical justification.

3. Evidence for Recycled Content Claims

There is also a foreseeable reconfiguration in the verification of recycled content claims. If the delegated act introduces minimum recycled content requirements, as the ESPR permits, manufacturers will need reliable evidence on the origin and quantity of recycled fibres used — and supplier declarations alone will hardly suffice when materials pass through multiple stages of spinning, weaving, dyeing and garment assembly. It is reasonable to expect greater attention to chain of custody records, transaction documentation, calculation methodologies and the distinction between pre-consumer and post-consumer recycled material. The effect also extends to environmental communication: a statement such as "made with recycled fibres" will have to correspond precisely to the methodology and product-level standard established by the delegated act, and mass balance approaches, calculation percentages and certification schemes will need to be evaluated against the final legal requirement, not used as interchangeable evidence. The practical challenge at this point is less about accumulating certificates than about connecting purchasing data to product-level information — a sustainability certificate filed in a general company folder has limited utility if the company cannot determine which batches, models or units it actually applies to.

4. Chemical Information Across the Supply Chain

Chemical information, in turn, will need to travel further within the supply chain. The ESPR does not replace REACH or the Persistent Organic Pollutants Regulation; its impact instead lies in expanding the tracking and communication of substances of concern throughout the product lifecycle, potentially requiring the identity of the substance, its location in the product, its concentration, instructions for safe use and information relevant to reuse, recycling or environmentally sound waste treatment. For manufacturers, this converts chemical compliance into a deeper task of data management across the chain: it may no longer be sufficient to confirm that the final product respects a list of restricted substances, with more granular information needed on dyes, coatings, water-repellent treatments, printing inks, adhesives, plasticisers and other substances present in individual components. The difficulty becomes particularly visible for manufacturers sourcing fabrics or semi-finished products from suppliers outside the Union, where contracts and purchase specifications will have to demand more detailed chemical disclosure, as well as procedures for updating information whenever formulations change.

5. Digital Product Passport and Product-Level Data

The Digital Product Passport represents, within this ensemble, the element of change that is both most visible and most underestimated when reduced to the image of a QR code. The DPP will be associated with a persistent unique identifier, accessible via a data carrier placed on the product, its packaging or the accompanying documentation, and it will be for the delegated act to determine whether the relevant data refers to an individual article, a batch or a product model. The passport may contain information intended for different users — consumers, authorities, customs services, repair professionals, recyclers and other supply chain actors — with access rights that vary according to the type of information. This requires manufacturers to have systems capable of collecting, validating, storing and updating data from multiple internal departments and external suppliers: fibre composition, manufacturing locations, chemical information, durability performance, care instructions, recycled content, end-of-life guidance. Legal responsibility, it must be emphasised, does not disappear when a software provider is contracted to manage this structure; the economic operator placing the product on the Union market remains responsible for ensuring that the passport exists and that its information is reliable. For many small and medium-sized enterprises, the real starting point is not choosing a DPP platform but building a structured product data model and defining internally who is responsible for each data field.

6. Technical Documentation and Conformity Assessment

Once a textile product falls within the scope of an ESPR delegated act, the manufacturer will also need to evaluate its conformity with the applicable ecodesign requirements before placing it on the Union market — which may require technical documentation describing the product, the applicable requirements, the standards or test methods used, supporting calculations and conformity evidence, possibly accompanied by a conformity marking and an EU declaration of conformity. The impact here is both organisational and technical: sustainability data ceases to remain isolated in a corporate ESG report and becomes part of a market access file subject to inspection by national authorities. This presupposes clear document control procedures, in which test reports are linked to the correct product model, evidence supplied by manufacturers remains locatable and any product change triggers a re-evaluation of the validity of already-existing conformity documentation — a challenge that multiplies in companies with high seasonal collection turnover, where the number of technical files and necessary updates grows proportionally.

7. Contractual and Commercial Effects Across the Value Chain

Finally, there is an effect that tends to spill beyond the strict regulatory domain into commercial relationships. The ESPR formally imposes obligations on manufacturers, importers, authorised representatives, distributors, retailers and e-commerce platforms, but it is through commercial contracts that these effects will be felt in practice. European manufacturers will tend to demand more information from their weaving mills, dyehouses, notions suppliers and outsourced production units, while brands and retailers will in turn require that manufacturers provide them with structured and verifiable data before accepting products into their collections. Supplier selection thus becomes increasingly dependent on the capacity to generate data: a technically competent supplier may become commercially inadequate if unable to disclose fibre origins, chemical composition, manufacturing information or evidence supporting a recycled content claim. This is particularly relevant for small and medium-sized enterprises embedded in global value chains, which may not be formally covered by all sustainability reporting or due diligence instruments, but which still receive extensive information requests from larger customers seeking to meet their own ESPR obligations. Contracts will need to address data accuracy, audit rights, confidentiality, notification of material changes or formulation shifts and responsibility for incorrect information — and procurement departments, in this shift, become part of the compliance structure itself. The competitive effect should not be underestimated: companies capable of producing reliable data quickly tend to gain advantage over those that still treat regulatory information as an administrative task, executed only after production is complete.

"The ESPR is altering the regulatory meaning of a textile product itself."

— Canindé analysis

What This Means for SMEs

Preparation does not require waiting for the final delegated act. Begin with these foundational actions:

Durability Testing

Establish testing protocols and accumulate durability data on key products. Document dimensional stability, seam strength and abrasion resistance now.

Material Mapping

Create detailed records of fibre composition, material origins and supplier information. Identify complex blends early to plan simplification or justification strategies.

Chemical Disclosure

Request detailed chemical information from suppliers. Begin documenting substances in dyes, coatings, treatments and accessories at the component level.

Recycled Content Evidence

If making recycled content claims, establish chain of custody documentation and calculation methodologies. Link evidence to specific product batches or models.

Supplier Traceability

Review contracts with mills, dyers and manufacturing partners. Define data-sharing obligations and quality assurance procedures for sustainability information.

Product Data Governance

Begin building structured product information systems. Define roles and responsibilities for data accuracy, storage and updating before DPP systems are mandated.

What Is Already Binding, What Remains Under Development

At this point, it is important to distinguish clearly what is already legally binding from what remains under construction. In June 2026, the complete ecodesign requirements for textile products have not yet entered into force, and the ESPR Working Plan indicates 2027 as the expected horizon for adoption of the delegated act relating to textiles and apparel — a final date that will still depend on the text actually adopted and its respective transition period. There is, however, a distinct obligation already becoming applicable: as of 19 July 2026, large enterprises will be prohibited from destroying unsold apparel, clothing accessories and footwear, subject to the derogations established by the Commission; medium-sized enterprises benefit from a later implementation period, and micro and small enterprises are excluded from this prohibition. It is important not to confuse this measure — which is part of the same regulatory framework but constitutes a separate obligation — with future textile ecodesign requirements or the DPP itself.

Regulatory Timeline

Key Dates for Textile Manufacturers

July 2024: ESPR entered into force

Regulation (EU) 2024/1781 establishing the framework for ecodesign requirements for sustainable products came into force.

2025: Ecodesign and Energy Labelling Working Plan 2025–2030

The Working Plan was published with textiles and apparel at the top priority. Preparatory studies and stakeholder consultation commenced.

19 July 2026: Prohibition on destruction of unsold apparel

Large enterprises must cease destroying unsold garments, clothing accessories and footwear. Medium-sized enterprises have until 2027; micro and small enterprises are exempt.

2027: Expected adoption of textile delegated act

The Commission is expected to adopt the delegated act with specific ecodesign requirements, DPP technical specifications and implementation timelines. This is an expected planning horizon, not a guaranteed final date.

Two Symmetrical Errors to Avoid

European manufacturers thus face two symmetrical errors to avoid. The first is to assume that any hypothetical ESPR requirement is already legally binding, when the concrete thresholds, test procedures and DPP data fields can only result from the final delegated act. The second is to wait for publication of that act before beginning any preparation. Between these two extremes, there is real scope for a preparation programme centred on product durability testing, material mapping, chemical disclosure, recycled content evidence, supplier traceability and product-level data governance — whilst simultaneously monitoring the Commission's technical preparatory work, since it is that process which will determine the final scope and content of the rules.

Canindé Analysis

The ESPR is reshaping the regulatory meaning of a textile product. Manufacturers need not treat hypothetical requirements as already binding, but should not wait for the final delegated act before building the data systems and conformity infrastructure that will soon be required. The regulatory direction is clear; execution can begin now.

The Changing Meaning of a Textile Product

The ESPR is, in this sense, altering the regulatory meaning of a textile product itself. A garment will cease to be evaluated solely on what it is made from and whether it is safe for sale; it will increasingly need to explain how long it should last, how its materials can circulate, what substances it contains and whether the information that accompanies it can withstand scrutiny. For manufacturers in the sector, the regulatory track has already begun — even if its final destination is still being built.

Sources & Further Reading

Isaque Pires

Isaque Pires is a Brazilian-trained lawyer and researcher in European environmental law. His work focuses on EU sustainability regulation, circular economy and the textile sector.

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