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.
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.
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:
The ESPR also introduces horizontal rules that apply across sectors, including obligations related to the destruction of unsold consumer products.
Ecodesign refers to the integration of environmental considerations into a product’s design process to reduce the environmental impact of products throughout their life cycle.
Based on the ongoing European Commission textiles preparatory study, the following design aspects are currently being assessed as potential ecodesign parameters for apparel:
Environmental footprint information: The preparatory study is assessing whether standardized information on environmental impacts during manufacturing – such as carbon or broader environmental footprints – should be included as an information requirement. Existing methodologies, including the Product Environmental Footprint Category Rules (PEFCR) for apparel and footwear, are being considered as reference frameworks.
At this stage, no final ecodesign requirements have been adopted – the textiles/apparel delegated act is expected to be adopted around 2027, leading to compliance deadlines around mid-2028 (18 months later).
In addition to potential performance requirements, the ESPR introduces information requirements that define 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:
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 ESPR introduces a ban on the disposal of unsold consumer products, and specifically textiles, apparel, and footwear items. Unlike ecodesign requirements, this obligation is already defined in the Regulation itself and does not depend on future delegated acts.
Under the ESPR, destruction means discarding unsold products as waste. This includes:
Activities higher up the waste hierarchy, such as reuse, refurbishment, or remanufacturing, are not considered destruction.
In practical terms, this means that unsold garments or shoes may be:
However, destroying products solely for recycling purposes (for example, shredding unsold garments to recover fibers) is considered destruction and will be prohibited once the ban applies.
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 might require quite some energy consumption and/or lead to a degradation of the recovered raw materials.
The Regulation allows limited exemptions where destruction may still be permitted, including cases where:
Before the ban fully applies, the ESPR obliges brands to disclose information about destroyed unsold products on their website.
The following information has to be disclosed per financial year:
See here the EU company size definitions.
The prohibition of destroying unsold footwear and textiles starts in 2026 for large enterprises and in 2030 for medium-sized enterprises.
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 management 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 incorporate carbon impact in the earliest stages of the design and sourcing processes.
See a demo video here: