For Fashion: Ecodesign for Sustainable Products Regulation (ESPR)

Status: ✅ Approved EU law

The Ecodesign for Sustainable Products Regulation (ESPR) introduces product-specific performance requirements across the EU, such as durability, recyclability, or recycled content, for products placed on the European market. The legislation also bans the destruction of unsold textiles and footwear, starting in 2026.

In parallel, the ESPR introduces information requirements to ensure standardized product data is made available. A central element of this is the Digital Product Passport (DPP), one of the most visible indicators of a product’s environmental performance via a QR code or similar data carrier.

In the ESPR Working Plan for 2025–2030, textiles are identified as a priority product group. This means that apparel will be among the first sectors to receive detailed, legally binding ecodesign requirements – we break them down in the article below.

What is the Ecodesign for Sustainable Products Regulation?

Unlike product-specific regulations, the Ecodesign for Sustainable Products Regulation (ESPR) itself does not immediately impose detailed requirements on apparel or footwear. Instead, it functions as framework legislation. It gives the European Commission the legal mandate to introduce product- and sector-specific ecodesign rules through delegated acts over time.

Under the ESPR, the Commission may set two main types of requirements:

• Performance requirements, which define how a product must perform against specific sustainability parameters. These may address aspects such as durability, resistance to wear, reparability, recyclability, recycled content, or the presence of substances that hinder reuse or recycling.

• Information requirements, which define what standardized product data must be made available and how it should be communicated. For many product groups, this information will be provided through the Digital Product Passport (DPP).

The ESPR also introduces horizontal rules that apply across sectors, including obligations related to the destruction of unsold consumer products.

The ESPR Bans the Destruction of Unsold Apparel, Clothing Accessories, and Footwear

The ESPR introduces a ban on the destruction of unsold apparel, clothing accessories, and footwear.

In February 2026, the European Commission adopted two acts that add the operational detail to this ban: a Delegated Act defining the ban exemptions, and an Implementing Act setting the standardized reporting format. The ban applies from July 2026 for large brands and from 2030 for medium-sized brands.

Let’s look closer at all the requirements:

What Counts as "Destruction"?

Under the ESPR, destruction means intentionally damaging a product or discarding it as waste. This includes:

• Disposal.
• Other recovery operations (e.g., burning textiles in a waste-to-energy facility to capture the heat as electricity or district heating).
• Recycling.

The activities that fall outside the definition – and remain allowed – are higher up the waste hierarchy:

• Reuse or donation.
• Repair or refurbishment.
• Remanufacturing into new products.

However, destroying products solely for recycling purposes (for example, shredding unsold garments to recover fibers) is considered destruction and will be prohibited.

The reasoning behind this is that the EU wants to avoid brands continuing to overproduce and then just "shred" their excess inventory, even if the raw materials are going to recycling. Recycling can require significant energy and degrade the quality of recycled fibers.

Exemptions from the Destruction Ban

The Delegated Act of February 2026 lists ten specific circumstances under which destruction of unsold apparel and footwear remains allowed:

1. Dangerous product. Fails EU product safety rules.

2. Illegal product. Non-compliant with EU or national law (e.g., made with forced labor), and destruction is required by law or is the appropriate response.

3. IP infringement. Confirmed counterfeit or unauthorized reproduction.

4. Expired IP license. A license or contract makes sale or distribution after a specified date an IP infringement, and that date has passed.

5. Inappropriate or IP-protected design elements. Labels, logos, or design elements that are IP-protected or considered inappropriate (e.g., discriminatory, offensive) and cannot technically be removed.

6. Damaged or contaminated. Repair or refurbishment is not technically feasible or cost-effective (e.g., a pallet of shoes crushed in transit).

7. Manufacturing or design defect. Repair is not technically feasible (for example, a waterproof jacket with failed seam-taping).

8. Donation refused. Offered to at least 3 suitable social economy entities, or listed on the brand's website for 8+ weeks, and not accepted.

9. No recipient after donation. A social economy entity received the product but couldn't find anyone to take it.

10. No buyer after reuse-prep. Prepared for reuse by a waste treatment operator, but no buyer was found.

Brands relying on any exemptions must:

• Keep documentation for five years – quality-assessment reports, IP notifications, donation offers, inspection records, depending on which exemption is used.
• Provide documents within 30 days on request.
• Send the recipient waste treatment operator a statement specifying the applicable exemption, so it can sort the products correctly.

Enforcement happens at the Member State level. The ESPR requires national penalties to be 'effective, proportionate, and dissuasive,' but each Member State sets the specific amounts. Member States are now in the process of publishing their penalty details ahead of the July 2026 deadline.

Disclosure Obligations for the Destruction of Unsold Goods

The ESPR requires brands to publish, on their website, information about the unsold consumer products they discard as waste, per financial year. The disclosure must cover:

• The count of individual items destroyed (e.g., number of garments or pairs of shoes) and the total weight of those items, differentiated by type or category.
• The reasons for destruction, including the specific exemption invoked under the Delegated Act.
• The waste treatment operation used (preparing for reuse, recycling, other recovery, energy recovery, or disposal).
• The measures taken and planned to prevent the destruction of unsold products.

In February 2026, the Implementing Act introduced a standardized template for these disclosures, harmonizing how the data is presented and reported. The template applies from February 2027 – see the disclosure template for the exact format.

Which Fashion Brands Should Disclose and When?

• The disclosure obligation itself is already in force for large enterprises under the ESPR. They are required to publish information on destroyed unsold products on their website per financial year.
• The standardized reporting format for those disclosures applies from February 2027. Until then, large companies disclose under the ESPR text without a harmonized template.
• Medium-sized enterprises must disclose from 2030.
• Small and micro-sized enterprises are exempt to avoid a disproportionate burden. See here the EU company size definitions.

Digital Product Passport for Fashion

Where the destruction ban governs what happens to unsold goods, the ESPR's other big lever is information – what product-level data must be made available when products are placed on the EU market.

Under the ESPR, the Digital Product Passport will serve as a standardized digital record containing product information. For products covered by delegated acts, the DPP will need to be made accessible via a data carrier, such as a QR code or a similar scannable identifier.

The ESPR requires the European Commission to:

• Establish a Digital Product Passport registry by July 2026, which will store unique product identifiers.
• Define, through delegated acts, which data must be included, who is responsible for providing it, and how it should be accessed.

At this stage, textile-specific DPP requirements have not yet been adopted. Details such as the exact data carrier format and mandatory data fields for apparel will be confirmed in textiles/apparel delegated acts (expected in 2027).

Although footwear is not among the first-priority product groups, the Commission has acknowledged the environmental relevance of footwear and its potential link to eco-modulated extended producer responsibility (EPR) fees under the Waste Framework Directive. As a result, a dedicated study on footwear is planned for 2027 to assess how ecodesign and information requirements, including the DPP, could apply to this category.

Read all about the Digital Product Passport requirements for fashion brands in our deep-dive here. Curious to see how DPP could look for your product? Scan below!

The JRC's 3rd Milestone – Proposed Requirements for Textile Ecodesign

The destruction ban and the DPP are both anchored in the ESPR text itself. The remaining information – the specific ecodesign requirements textile products will have to meet, and the exact data fields the textile DPP will carry – is still being written. Both will land in the same document: the textile delegated act, expected in 2027.

Before the European Commission writes a delegated act, it needs the underlying research first. That work is done by the Joint Research Centre (JRC) – the Commission's in-house science service. The Commission then uses that evidence to draft the legally binding rules.

In December 2025, the JRC published the 3rd milestone of the preparatory study on textile products. This is the most concrete picture yet of what the textile ecodesign requirements will look like.

The study covers apparel containing at least 80% textile fibers, including workwear and sportswear. Footwear is out of scope – a separate study is expected by the end of 2027.

What the JRC’s Life Cycle Assessment Found

The JRC ran a full Life Cycle Assessment on three representative product categories – knitted, denim, and other woven. The analysis shows where a garment's environmental impact comes from:

• Raw material production: 60–63% (biggest impact)
• Manufacturing: 21–29%
• Distribution: 4–6%
• Use: 5–15% (highest for denim, due to laundering)
• End of life: <0.5%

Raw materials are by far the largest driver of a garment's environmental footprint. Across all 16 Product Environmental Footprint impact categories, the three largest contributors are water use, climate change, and fossil resource use.

Proposed Ecodesign Requirements

Based on these findings, the JRC has put forward four candidate ecodesign requirements for the delegated act – three as information labels and one with a mandatory performance threshold:

1. Robustness score (0–10): an information requirement scoring how well a garment holds up after five standardized wash cycles. The score is based on technical, measurable parameters, including visual inspection, spirality, and dimensional changes after multiple cleaning cycles. The JRC is clear that it measures resistance to laundering stress, not actual product lifetime – current tests cannot reliably predict how long a garment will last in real use (e.g., after how many wears people throw garments away).

2. Recyclability score (0–10): an information requirement scoring how easy it is to recycle the garment. The cleaner and more homogeneous the fiber composition, the higher the score. Products with more than 15% elastane (or 20% in nylon-rich blends) score 0. Products below these thresholds can gain points for mono-material construction, matching inner and outer composition, and the absence of recycling disruptors such as prints, coatings, sequins, or certain dyes. Additional points are linked to compatible recycling pathways. For example:

• Pure cotton → compatible with chemical recycling into man-made cellulosic fibers (+2 points)
• Polyester- or acrylic-rich blends above 80% → compatible with thermo-mechanical recycling (+2 points)

3. Recycled content: the JRC proposes potential minimum recycled-content thresholds as part of future performance requirements, though these are still under assessment and optimization. The levels currently explored include:

• 20% recycled cotton in denim

• 15% recycled polyester in knitted and other woven products
• 10% recycled wool in knitted and other woven products
• 5% recycled nylon in knitted and other woven products

4. Manufacturing footprint: the JRC suggests that the European Commission pick between two versions of the score:

• Environmental footprint: a single score summarizing all 16 PEF impact categories.

• Carbon footprint: only the climate change category (the biggest impact one).

How would the score be calculated?

In either scenario, the score would be calculated using the PEFCR methodology, but limited to the manufacturing stage – raw materials are excluded. The JRC justifies excluding raw materials by arguing that the datasets available for different fiber types use inconsistent system boundaries, which prevents their fair comparison. The JRC argues the raw materials hotspot is addressed elsewhere via the robustness, recyclability, and recycled content requirements.

The proposal suggests distinguishing products calculated using primary data from those relying mainly on secondary data to incentivize the use of primary supply-chain data.

Which brands would display the score?

Calculation would be voluntary – brands can choose not to calculate it at all. For brands that do calculate: only products that outperform the PEFCR category benchmark can display the indicator (showing by how much, as %). This means that only products with better-than-benchmark environmental or carbon performance would disclose it. The label would be "excellence-only."

Carbonfact’s Feedback for JRC 3rd Milestone

Carbonfact has submitted a joint position to the JRC consultation on the Digital Product Passport, together with three other LCA vendors and 2BPolicy. This is the first time these platforms have formally united on a policy position.

Here's what we argued:

1. Include raw materials

It's the biggest driver of impact: The JRC's own preparatory study acknowledges that raw material production accounts for 60–63% of a textile product's environmental footprint. Excluding raw materials means the regulation cannot distinguish between the most and least impactful products on the market. It also removes the market incentive for brands to invest in lower-impact fibers, which often come at a higher cost.

2. Make it mandatory, not voluntary

A voluntary disclosure framework creates selection bias: only better-performing products would report, leaving the majority of the market invisible to consumers. Mandatory requirements, as demonstrated by EU energy labeling, are what actually shift markets – nearly 80% of EU citizens consult the energy label at the point of purchase. The DPP for textiles should work the same way.

3. The technology is ready, and the costs are manageable

The JRC estimated a per-SKU calculation cost of €2,550, based on figures from the Battery Regulation. Aggregated data from our platforms tells a different story: the actual cost ranges from €1 to €10 per SKU. Collectively, our four platforms have calculated environmental footprints for over 3 million unique SKUs in the last 12 months alone. 20–40% of users of these tools are already SMEs.

4. Use the A&F PEFCR as the methodology

A multi-indicator Environmental Footprint based on the Apparel & Footwear PEFCR ensures comparability across the industry and consistency with other EU legislation – including the EU Battery Regulation, which already mandates PEF-based declarations. A carbon-only metric would miss critical textile-specific impacts like water consumption and land use.

The JRC will now review all feedback before the Commission's impact assessment.

How to Prepare for the ESPR as a Fashion Brand

Fashion and textile brands can best prepare for the implementation of the ESPR by adopting a proactive approach to ecodesign. Conducting thorough assessments of your product lines can help identify areas of improvement in terms of ecodesign and assist with reporting.

Carbonfact is an environmental data platform tailored to the needs of apparel, footwear, and textile companies. The platform enables fashion brands to perform life cycle assessments (LCA) for their products, allowing them to measure and simulate products' carbon footprint in real-time.

Carbonfact provides apparel and footwear brands with the tools they need to incorporate carbon impact into the design process from the beginning, allowing them to estimate, simulate, and reduce the footprint in the earliest stages of the design and sourcing processes.