ESPR for Fashion & Textiles: Everything you need to know in 2025

The fashion and textile industry is facing a pivotal shift. Globally, the sector is responsible for around 10% of greenhouse gas emissions and contributes significantly to water pollution and waste generation.

As pressure mounts from consumers, investors, and regulators to address these impacts, the European Union is taking decisive action.

The Ecodesign for Sustainable Products Regulation (ESPR), which officially entered into force on 18 July 2024, represents a major transformation in how products — including garments, textiles, and footwear — must be designed, manufactured, and managed across their entire life cycle.

In April 2025, the European Commission published its first ESPR Working Plan, which formally identifies textiles and apparel as top-priority sectors requiring immediate regulatory attention. This move signals the beginning of a stricter, data-driven, and circular economy approach for fashion businesses operating in or selling into Europe.

Whether you manufacture within Europe or export products into the EU, the time to act is now.

What Is the Ecodesign for Sustainable Products Regulation (ESPR)?

The Ecodesign for Sustainable Products Regulation (ESPR) is the European Union’s landmark policy for making sustainable products the norm across the single market. Introduced under the European Green Deal and the Circular Economy Action Plan 2.0, the ESPR expands and replaces the earlier Ecodesign Directive (2009/125/EC).

Unlike the Directive, which primarily addressed energy-related products such as appliances and electronics, the ESPR applies to almost all physical goods, except food, feed, and medicinal products placed on the EU market, including textiles, garments, and footwear. Its objective is to reduce the environmental and climate impacts of products across their entire life cycle, from raw material extraction to manufacturing, usage, and end-of-life disposal.

As a directly binding EU law, it does not require national governments to pass individual implementing laws, making compliance uniform across all Member States. This harmonisation ensures that companies operating within or exporting to the EU market face consistent sustainability requirements, regardless of the country.

The ESPR introduces:

• Mandatory performance requirements (e.g., durability, repairability, recycled content)
• Detailed information requirements (including Digital Product Passports)
• Measures to ban the destruction of unsold goods
• Minimum sustainability criteria for green public procurement

Through these initiatives, the ESPR is designed to support the EU’s ambitions to:

• Double the circularity rate of materials used across the economy by 2030.
• Reduce greenhouse gas emissions from product life cycles.
• Drive innovation in sustainable business models.

For the fashion and textile sector, this marks a profound shift. No longer voluntary or guided by fragmented standards, sustainable product design and transparency will now become a legal obligation, backed by enforcement measures and market surveillance at the EU level.

The aim of ESPR is simple: it’s to make sure products Last longer, are easier to repair, reuse and recycle. Contain more recycled content, use fewer hazardous substances and have a lower environmental and carbon footprint.

These requirements are not one-size-fits-all but will be tailored to each product category through a series of delegated acts (future product-specific rules).

For textiles, the first such delegated act is expected to be published by 2026, with compliance required from 2027/2028 onwards.

What were the key updates in the ESPR Working Plan 2025–2030?

On 16th April 2025, the European Commission released the first Ecodesign for Sustainable Products and Energy Labelling Working Plan, setting out the roadmap for implementing ESPR requirements across different industries.

Textiles and apparel were ranked first priority—the sector with the highest potential for environmental improvement and the most pressing need for regulatory intervention.

For fashion and textile brands, this means the clock is officially ticking.

Under the 2025 Working Plan, the European Commission has confirmed that:

• New binding ecodesign requirements for textile products and garments will be developed with a target adoption timeline of 2027.
• Footwear will be treated separately. A dedicated study on sustainability requirements for footwear will be conducted and completed by the end of 2027, laying the groundwork for future measures.
• Digital Product Passports (DPPs) will be introduced as mandatory for all regulated apparel products, significantly increasing traceability, compliance monitoring, and consumer information.
• Priority design parameters will include durability, repairability, recyclability, resource efficiency, and the reduction of hazardous substances—all with the goal of enabling genuine circularity in the textile sector.

At the same time, new information and labelling requirements—aligned with the revision of the EU Textile Labelling Regulation—will ensure that consumers have clear, verifiable data on product sustainability at the point of purchase.

What Makes a Product “Sustainable” Under ESPR?

Under the ESPR, there are two main complementary requirements for making a product sustainable:

1. Meeting the required performance aspects (such as durability, repairability, and recyclability), and
2. Providing a Digital Product Passport (DPP), which clarifies and makes accessible key information about the product’s sustainability, composition, and circularity characteristics.

The Digital Product Passport will be discussed later in the article. Let’s understand the 16 performance aspects first.

ESPR Performance Aspects: Which Ones Matter for Fashion and Textiles?

The Ecodesign for Sustainable Products Regulation (ESPR) identifies 16 environmental and circularity aspects that can be used to set sustainability requirements across different product groups.

However, not all 16 aspects will automatically apply to every sector, including textiles and apparel. Here are the aspects that are most likely to apply to fashion and textile.

The delegated act for textiles is expected to be published by 2026, and implementation will begin by 2027.

Digital Product Passports (DPP): What Fashion and Textile Brands Need to Know

Alongside meeting new performance requirements, textile and fashion products sold in the EU will soon need to carry a Digital Product Passport (DPP).

Based on decentralised data storage, DPPs are like a digital identity card for every product—a scannable passport that stores and shares key sustainability information throughout its lifecycle.

Importantly, DPPs will be designed to work in tandem with the revised EU Textile Labelling Regulation, ensuring that physical and digital disclosures complement each other, not conflict.

Under the ESPR framework:

• Phase 1 of DPPs (a minimal & simplified version) will be mandatory for textiles and apparel by 2027.
• A secure EU-wide registry to store DPPs, including their unique identifiers, will go live in 2026 to support customs and market surveillance.
• Each product must have a machine-readable physical data carrier (such as a QR code or RFID tag) linking it to its DPP.
• DPP data must be accurate, up-to-date, open and interoperable, and accessible free of charge to all relevant actors — including consumers, recyclers, authorities, repairers, and civil society organisations.
• The DPP will connect with external systems like the SCIP database (for hazardous substances) and align with broader frameworks such as CS3D/CSDDD.

There are, of course, provisions to protect sensitive business data through layered access rights — users will only see the information relevant to their role. Critically, personal data about consumers cannot be stored in a DPP unless they give explicit consent.

Based on the ESPR framework, the working plan and Textile Delegated Act (due by 2026), fashion and textile companies need to keep in mind:

• The delegated act for textiles and apparel (expected ~2026) will finalise which fields are mandatory.
• All mandatory DPP fields must be verifiable and traceable. You will need supporting documentation (e.g. LCA reports, lab test results).
• Brands can link repair services, resale programmes, or sustainability claims to the DPP — but must ensure accuracy to comply with the EU Green Claims Directive.

For larger brands, creating DPPs will be relatively straightforward.

Most of the necessary data already exists in their current systems, like Product Lifecycle Management (PLM) platforms, Sustainability Data Platforms (e.g., GreenStitch), Supply Chain Management (SCM) tools, or Enterprise Resource Planning (ERP) systems.

Modern DPP solutions are being designed to plug into these existing systems, allowing brands to generate digital passports at scale and in record time.

However, for Small and medium-sized enterprises (SMEs who lack such resources), they will receive support to ensure affordable and easy access to DPP systems, either through national helpdesks or shared digital infrastructure.

Read our blog for a deep dive into Digital Product Passports for fashion and textile from what information it must contain to a full breakdown of implementation time.

Ban on Destruction of Unsold Stock

In 2018, Burberry faced public outrage when it was revealed that the company had incinerated £28.6 million worth of unsold stock the previous year to protect brand exclusivity.

While Burberry quickly pledged to end the practice, it was only one of many brands quietly using this practice to protect their brand value and create false scarcity.

The ESPR puts an end to that.

From 19 July 2026, all large companies must refrain from destroying unsold clothing, accessories or footwear; the same rule applies to medium-sized companies from 19 July 2030. Small and micro-enterprises remain exempt, although anti-circumvention provisions prevent large brands from diverting stock for destruction via smaller entities.

“Destruction” under ESPR encompasses any disposal of usable items without first offering reuse, including landfill, incineration, shredding or recycling (if reuse is not attempted first). Instead, unsold stock must be directed towards resale, donation, refurbishment or fibre-to-fibre recycling.

Limited exceptions will apply only when:

• Safety or hygiene risks render reuse unsafe (e.g. chemical contamination, mould)
• Legal or IP issues arise (counterfeit goods, banned materials)
• Items are irreparably damaged, or
• Disposal yields a better environmental outcome than reuse

These derogations will be defined in delegated acts between 2025 and 2026.

In addition to the outright ban, large and medium-sized firms must publish annual reports detailing the weight and number of destroyed items, the reasons for discarding, and the final destination of stock (reuse, recycling, energy recovery or disposal).

These disclosures, to be made publicly available, will feed into EU-level statistics and intensify scrutiny of wasteful practices.

Who Needs to Comply with ESPR?

The ESPR casts a wide net, applying to any economic operator that places goods on the EU market:

• Manufacturers (including brand owners) designing or producing textile and footwear products.
• Importers of non-EU goods must ensure products meet ESPR requirements before sale.
• Distributors and retailers are responsible for verifying that products bear the correct markings, labels and DPPs.
• Fulfilment service providers and online marketplace operators, who facilitate sales into the EU, must cooperate with market surveillance.

Critically, non-EU companies exporting into Europe are treated the same as EU-based operators: if you sell into the EU, you must comply.

Small and micro-enterprises enjoy limited exemptions for only the destruction ban, but they remain subject to core ESPR obligations such as DPP implementation, performance requirements (once delegated acts take effect) and reporting duties.

In practice, every link in the value chain—wherever based—must check conformity, maintain documentation, and enable authorities or consumers to access required sustainability data. Non-compliance can lead to market withdrawal, fines or reputational damage.

Long story short, if you make, import, sell or ship fashion and textile products into the EU, ESPR compliance is mandatory. SMEs should prepare now for rising obligations, even where some bans are phased in later.

How Fashion and Textile Companies Can Comply with ESPR

Complying with the ESPR requires a structured, end-to-end approach. Fashion and textile brands should consider the following roadmap:

1. Assess Scope and Timing
   • Identify which product lines fall under ESPR (textiles, garments, footwear).
   • Note key deadlines: performance requirements (from 2027 onward), destruction ban (2026/2030), DPP registry (July 2026).
2. Gap Analysis and Planning
   • Audit current designs, materials and processes against anticipated ESPR criteria.
   • Map existing data systems (PLM, ERP, SCM) to determine what new data must be gathered or workflows updated.
3. Supply Chain Engagement
   • Communicate forthcoming requirements to all suppliers and contract manufacturers.
   • Institute traceability protocols so that fibre origins, chemical inputs, and batch information can feed into DPPs and conformity assessments.
4. Design for Circularity
   • Redesign products to meet durability and repairability thresholds.
   • Opt for mono-material constructions or easily separable components to simplify recycling.
   • Integrate recycled content targets and phase out substances of concern in line with REACH/SCIP.
5. Digital Product Passport Preparation
   • Establish or upgrade digital infrastructure to collect and maintain all required DPP data fields.
   • Ensure each item carries a unique QR code or RFID tag linked to a secure DPP entry.
   • Plan for layered access controls and interoperability with EU databases (SCIP, CS3D/CSDDD).
6. R-Strategy Implementation
   • Develop processes for resale, donation, repair and remanufacture of unsold stock.
   • Integrate take-back, refurbishment and recycling programmes to avoid destruction and meet reporting obligations.
7. Reporting and Documentation
   • Set up systems to track unsold stock volumes, destruction reasons and end-of-life pathways.
   • Prepare templates for annual compliance reports and maintain technical documentation (test reports, conformity declarations).
8. Training and Governance
   • Educate design, procurement and quality teams on ESPR rules and timelines.
   • Appoint an internal ESPR compliance lead and establish a cross-functional task force.
9. Engage with Authorities and Stakeholders
   • Participate in EU consultations on delegated acts.
   • Liaise with market surveillance authorities early to understand inspection procedures and documentation requirements.

By following these steps, fashion and textile companies can not only achieve ESPR compliance but also position themselves as leaders in the emerging circular economy.

Conclusion

The ESPR deadline clock is already ticking. By embedding circular design, robust data systems and transparent reporting into their core operations, fashion and textile brands can transform what might seem a regulatory burden into a powerful growth engine.

Acting now mitigates the risk of fines, market withdrawals and reputational harm while smoothing your path to market. Not to mention, drive innovation by embedding durability and circularity, but also build consumer trust and reduce costs through resource efficiency and take‑back initiatives.

For fashion and textile brands, mastering performance requirements and Digital Product Passports (DPPs) is the first big step on the ESPR compliance journey. Performance requirements ensure garments are durable, repairable and recyclable.

Greenstitch makes DPP creation fast and hassle‑free. By tapping into your existing PLM or ERP data, Greenstitch automatically generates accurate, interoperable passports—so you spend less time wrestling with spreadsheets and more time innovating.

References

1. Ecodesign for Sustainable Products Regulation (ESPR)
2. European Green Deal
3. Circular Economy Action Plan 2.0
4. Ecodesign for Sustainable Products and Energy Labelling Working Plan