Full Overview of the EU Textile Strategy and Regulations

Despite recent European Union shifts toward economic competitiveness and regulatory simplification, apparel and footwear brands will face a series of binding sustainability requirements over the next few years. 

These rules will change how products are designed (ESPR), how environmental performance is communicated to consumers (ECGT / UCPD), how sustainability data is reported at the company level (CSRD), and how product information is structured and shared through tools like the Digital Product Passport (DPP).

This article summarizes the EU Textile Strategy and the main regulations that should be on the radar for fashion brands.

If you have any questions about how to stay compliant, please feel free to reach out to our team.  We’d be more than happy to help!

But first…

Understanding EU Legislation

Before we delve into the specifics, let’s take a look at how EU legislation works. (Don’t worry, this won’t be a complicated civics lesson!)

There are two key concepts in understanding how the EU makes legislation: regulations and directives.

A regulation is basically a general law that applies to all EU countries. It’s a binding act that every country must comply with.

A directive is a legal act that sets a minimum standard for EU member states. Each member state must enact its own laws or regulations within a two-year period to comply with the minimum requirements of the directive. Member states can also choose to go beyond the minimum requirements set out in the directive.

What does this mean for you? There are both EU-wide laws AND  upcoming national laws that your fashion brand will need to comply with. In regard to climate change, all new regulations and directives are part of the European Green Deal, which sets a roadmap for all future environmental legislation.

EU Legislative Process

The EU legislative process involves the proposal of legislation by the European Commission, which is then reviewed and potentially amended by the European Parliament and the Council of the European Union. If both bodies agree on the text after a dialogue phase, which can span several years, the legislation is adopted. A Regulation becomes binding across all EU member states directly, without the need for national transposition, and enters into force 20 days after its adoption.

Following the adoption of a Regulation, Delegated Acts can be developed. Delegated Acts are secondary laws that specify or amend non-essential elements of the original legislation, allowing for adjustments or details (e.g. to certain industries) to be added without going through the full legislative process again. 

Both Directives and Regulations go through the EU legislative process involving the European Commission, the European Parliament, and the Council of the European Union. Once adopted, however, their paths diverge, directives must be transposed by each member state into its national law by a given deadline.

The European Green Deal

The European Green Deal is the EU’s overarching policy framework to achieve climate neutrality by 2050. It sets the environmental objectives that underpin many of the sustainability regulations now affecting apparel and footwear brands. Key targets include a net reduction of at least 55% in greenhouse gas emissions by 2030 compared to 1990 levels, alongside broader measures on resource use, biodiversity, and ecosystem protection.

Within the European Green Deal, two policy frameworks remain central for understanding how EU textile legislation has developed and how it is now being implemented.

EU Circular Economy Action Plan (CEAP)

The CEAP is a cornerstone of the European Green Deal. Comprising 35 specific actions, it places a special spotlight on the textiles sector, which is recognized as one of the most resource-intensive industries. The Circular Economy Action Plan introduces an array of initiatives that are crafted to promote sustainable product design, establish circular economy practices, and minimize waste generation.

EU Strategy for Sustainable and Circular Textiles 

To implement the commitments of the European Green Deal and the new CEAP, the EU has developed a specific strategy for the textiles sector. The EU Strategy for Sustainable and Circular Textiles aims to reinvent the entire lifecycle of textile and footwear products, not only changing how fabrics are made, but also how they are consumed, and eventually disposed of.

This includes increasing the longevity of textiles, increasing the use of recycled fibers, curbing fast fashion, and making products easier to repair or recycle with a Digital Product Passport. 

Now let’s take a look at the main climate regulations and directives, and how they affect fashion and textile companies in greater detail.

Omnibus I Simplification Package

The EU Competitiveness Compass, launched in January 2025, is a European Commission framework aimed at strengthening EU competitiveness by simplifying how existing climate and sustainability rules are implemented, with a focus on reducing administrative and reporting burdens for companies.

In this context, “omnibus” is commonly used as shorthand for legislative simplification. The European Commission regularly introduces multiple omnibus packages, each addressing a different policy area and numbered separately. For example, Omnibus VI  focuses on simplifying EU chemical legislation, while Omnibus II targets the simplification of EU investment frameworks. 

Omnibus I sits within this broader simplification agenda and focuses on corporate sustainability reporting and due diligence, with the objective of simplifying EU sustainability rules, supporting competitiveness, and reducing administrative burdens for brands. 

The package was approved through the EU’s formal legislative process in December 2025, introducing changes to the scope and timelines of the Corporate Social Responsibility Directive (CSRD) and the Corporate Social Due Diligence Directive (CSDDD).

The Council of the European Union is expected to give final approval in early 2026, a formal step that will allow the amendments to enter into law. Under the proposal, Member States will have to transpose the Directive into national law by July 2027.

Read all about Omnibus I in our deep dive for apparel and footwear brands here.

Corporate Sustainability Reporting Directive (CSRD)

 Status:  ✅ Approved EU law, has been delayed by Omnibus I Simplification Package

Corporate Sustainability Reporting Directive (CSRD) requires companies to publish standardized sustainability reports covering environmental, social, and governance impacts, based on the European Sustainability Reporting Standards (ESRS). 

For high-impact sectors such as textiles, sector-specific ESRS are still under development. Following Omnibus I, these sector standards will be voluntary and published at a later stage. This means fashion brands will initially report under the general ESRS only.

There are 12 ESRS standards in total. Together, they cover a broad range of environmental, social, and governance topics relevant to the fashion supply chain. The ESRS outlines how and what information and ESG metrics apparel and footwear brands need to report to European regulators to comply with the CSRD. 

After the Omnibus Simplification Package, CSRD applies to companies with over 1,000 employees and €450m+ net turnover, including non-EU parent companies generating more than €450m in EU net turnover through an EU subsidiary or branch; listed SMEs are excluded.

Here is the CSRD timeline:

• CSRD entered into force in 2023.
• 2025: first CSRD-aligned disclosures by former NFRD companies (FY2024). These brands do not need to report for FY2025–2026 (transition exemption).
• 2028: first reporting for in-scope EU companies (FY2027).
• 2029: first reporting for in-scope non-EU parent groups (FY2028).

Read our CSRD deep dive for fashion here.

Corporate Sustainability Due Diligence Directive (CSDDD)

 Status:  ✅ Approved EU law, has been delayed by Omnibus I Simplification Package

The Corporate Sustainability Due Diligence Directive (CSDDD or CS3D) establishes a framework for identifying, preventing, and addressing adverse human rights and environmental impacts in brands’ own operations and key supply-chain partners. 

For apparel and footwear brands, this includes monitoring issues such as working conditions in garment factories, environmental impacts of material sourcing, and risks linked to subcontracting and logistics.

After Omnibus I, only very large brands remain in the directive's scope, those with over 5,000 employees and €1.5bn+ net annual turnover, including non-EU brands with equivalent EU net annual turnover.

CSDDD Timeline: Implementation of CSDDD into national law has been postponed by one year. This means brands will first be required to comply with due diligence obligations in 2029, covering activities carried out in 2028.

A lot of CSDDD requirements have also been simplified; for example, fashion brands are no longer required to adopt a climate transition plan. Curious to learn about all these changes? Read our CSDDD deep dive for apparel and footwear here.

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.

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.

At this stage, no final ecodesign or DPP 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).

The ESPR introduces a ban on the destruction 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.

Here is the timeline for the destruction ban:

• The obligation to disclose information about the destruction applies to large enterprises in the first full financial year after entry into force, so in 2026/2027. 
• For medium-sized enterprises, the obligation to disclose is 2030/2031 (6 years after entry into force). 
• Small and micro-sized enterprises (SMEs), however, are exempt from certain obligations to prevent undue burden on these smaller entities.

Read our fashion & textiles ESPR deep dive here.

Digital Product Passport (DPP)

 Status:  ✅ Approved EU law

The Digital Product Passport (DPP) will create product-level digital records showing a garment’s environmental performance, accessed via a QR code or similar data carrier. While final requirements are still being defined, EU studies indicate early DPPs will focus on material composition, manufacturing processes, core environmental indicators, chemical compliance, traceability, and durability.

Under current ESPR legislation, the Digital Product Passport is designed to apply to all apparel and footwear products sold on the EU market, regardless of where the brand is based or its size. 

ESPR only contains high-level information regarding the DPP; there is no textile industry-specific information just yet. These technical details are currently being worked on and will become law in the form of delegated acts.

Final delegated act for the DPP for textiles/apparel is expected to be shared in 2027; fashion brands will then have at least 18 months to implement it (exact timing to be determined in the act itself).

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 expected by the end of 2027 to assess how ecodesign and information requirements, including the DPP, could apply to this category.

Read our DPP deep dive for textile, apparel, and footwear brands here.

EU Textile Labeling Regulation

 Status:  ✅ Approved EU law, revision in progress

The current Textile Labeling Regulation requires disclosure of fiber composition and non-textile parts of animal origin. However, it also does not keep pace with the development of new fabrics and recycling technologies. The EU Commission plans to revise the current Textile Labeling Regulation to:

• Include additional product information (e.g., origin, care instructions, sustainability-related parameters).
• Define what should be on physical labels and what on DPP.
• Reflect new fibers, recycled materials, and recycling technologies.

All  EU and non-EU textile brands selling textile products in the EU must comply with the Textile Labeling Regulation. Footwear, however, is excluded, as it is regulated separately under EU footwear labeling rules.

Here is the expected timeline for the revision:

• Since 2011: Current Textile Labeling Regulation in force.
• Q2 2026 (expected): European Commission proposal for the revised regulation.
• Late 2027/2028 (expected): New labeling requirements start to apply.

Read our Textile Labelling regulations deep dive here.

Waste Framework Directive

 Status:  ✅ Approved EU law

The Waste Framework Directive (WFD) was adopted in 2021. You’re likely to see the acronym Textile EPR – short for Extended Producer Responsibility – used in reference to this directive. This contains several new rules that will make producers responsible for the full lifecycle of textile products. 

From 2025, the Waste Framework Directive already requires all EU Member States to establish separate textile waste collection systems. In 2025, the Directive was formally amended to also introduce the first EU-wide legal framework for textile Extended Producer Responsibility. This targeted revision requires all the EU Member States to establish national textile EPR schemes by June 2027.

Under these schemes, brands that place textiles on the EU market will be required to:

• Pay EPR fees to cover the cost of collecting, sorting, reusing, and recycling textile waste.
• Register as textile producers in each EU country where they sell products.
• Report the quantities of textiles placed on the market.
• Comply even if they are non-EU brands selling online to EU customers.

Curious to learn how EPR schemes already function in France, the Netherlands, Latvia, and Hungary? Learn our deep dive into Extended Producer Responsibility here.

Directive on Green Claims 

Status: Proposal published in 2023; legislative process paused.

The Green Claims Directive was proposed to establish EU-wide requirements for substantiating voluntary environmental claims, including both product- and brand-level claims. For fashion brands, it was designed to rely on life cycle–based evidence, using the Product Environmental Footprint (PEF) methodology as the main reference framework.

As of June 2025, the legislative process for the Green Claims Directive has been paused and is in serious doubt. The European Commission signaled its intention to withdraw the proposal, stating that ongoing negotiations conflicted with its simplification agenda, particularly due to the administrative burden for micro-enterprises.

 In the meantime, we recommend that brands follow the Empowering Consumers for the Green Transition Directive, an active EU law currently being transposed into national legislation, which amends the Unfair Commercial Practices Directive (UCPD) and already sets binding rules on environmental marketing in 2026.

Read our fashion Green Claims deep dive here.

Unfair Commercial Practices Directive (UCPD) and  Empowering Consumers for the Green Transition Directive

 Status:  ✅ Approved EU law

The Unfair Commercial Practices Directive (UCPD), established in 2005 for consumer protection, is the EU’s main legal framework for business-to-consumer marketing. It sets the basic rules for how claims about environmental performance, pricing, promotions, and product features can be communicated to consumers.

Notably, the UCPD has already been enforced against major fashion retailers like H&M and Decathlon for sharing misleading environmental claims without context or clarity.

In 2024, UCPD was updated through the Empowering Consumers for the Green Transition Directive (ECGT). This update bans specific green claims, such as:

• Generic, unsubstantiated claims like "eco-friendly".
•  Product claims based on carbon offsetting.
• Sustainability labels that are not backed by an approved certification scheme.

EU Member States must transpose the ECGT into national law by March 2026, with the updated rules applying from September 2026. From that point on, authorities will be able to issue fines and require corrective actions if the rules are not followed. 

Learn all about the new USCPD rules in our blog here.

Unfair Commercial Practices Directive (UCPD) and  Empowering Consumers for the Green Transition Directive

 Status:  ✅ Approved EU law

From August 2026, the Packaging and Packaging Waste Regulation (PPWR) will start introducing European Union–wide requirements to reduce the environmental impacts of packaging across its lifecycle.  The regulation sets the objective that all packaging placed on the EU market must be recyclable by 2030 and compatible with the EU collection and recycling systems.

The regulation established new standards and targets for all packaging materials. The goal is to use less packaging, minimize (and in some cases, ban) single-use plastics, and adopt more circular packaging solutions. Harmonizes national packaging Extended Producer Responsibility schemes across the EU member states.

The PPWR applies to any brand that places packaging or packaged apparel and footwear products on the EU market, regardless of where the brand is headquartered. For the fashion industry, packaging covers everything from protective garment bags to e-commerce shipping materials. 

Here is the timeline:

• August 2026: Obligations start to apply, including harmonization of national packaging EPR schemes. Brands must also start preparing for the 2030 requirements.
• 2030: All packaging must be recyclable and meet a minimum recyclability performance grade. Plastic packaging must meet minimum post-consumer recycled content thresholds, while grouped, transport, and e-commerce packaging must comply with the 50% maximum empty-space limit.
• By 2030 and 2040: EU Member States must reduce per-capita packaging waste by 5% by 2030, 10% by 2035, and 15% by 2040, compared to 2018 levels.

Curious to learn about all the PPWR requirements for your brand? Read our fashion deep dive here.

EU Deforestation Regulation (EUDR)

 Status:  ✅ Approved EU law

The EU Deforestation Regulation (EUDR) seeks to curb global deforestation linked to the EU market by making companies responsible for ensuring that their products are not linked to deforestation or forest degradation.

The regulation applies to several high-risk commodities, including cocoa, coffee, soy, palm oil, and timber, as well as products made from these materials, such as leather, chocolate, and furniture. Companies must prove that their products are not associated with land that was deforested after 31 December 2020.

The importer must also submit a Due Diligence Statement (DDS) and will receive a reference number, which should be reported in the customs declaration for import.

In 2025, EUDR was delayed. The biggest practical change is that due diligence responsibilities will sit with the first downstream operator placing products on the EU market, rather than being passed along the entire value chain. 

For example, a footwear brand imports leather sneakers into the EU and submits the DDS for the leather at import. The sneakers are then sold to an EU distributor and later to retail stores. Under the updated EUDR rules, only the importing brand submits the DDS. The distributor and retailers do not submit new due diligence for the same sneakers. 

Key new dates:

• 30 December 2026: Rules apply to medium and large companies.
• 30 June 2027: Rules apply to micro and small companies.

If the product is not traceable, do not comply with the rules and cannot be placed on the EU market or exported.

Read more about EUDR here.

Product Environmental Footprint Method (PEF for Apparel and Footwear)

 Status:  ✅ Final

Since its introduction in 2019, the European Green Deal continues to roll out new legislative initiatives designed to transform the EU into the first climate-neutral continent by 2050. A myriad of technical methodologies and tools have been introduced to reach this goal, one of which is the Product Environmental Footprint (PEF), a methodology for Life-Cycle Assessments (LCA).

On its own, an  LCA is a very broad methodology for assessing the environmental impact of products. As such, the PEF method was developed to serve as a common language for LCAs, standardizing how the environmental performance of products is measured, communicated, and improved across the continent. 

Housed within the PEF method are PEF Category Rules (PEFCR), designed to provide more specific guidelines for individual product categories.

After five years of work, the Product Environmental Footprint Category Rules (PEFCR) for the fashion sector are now considered final, with “no further modifications” needed. 

France: Environmental Cost

 Status:  ✅ Approved French law

The French Eco-score, part of the 2021 Climate and Resilience Law, is also known as “environmental labeling” or “affichage environmental” and has been officially renamed to "Environmental Cost" or “cout environmental”.

This methodology assigns a single environmental score (Environmental Cost) to textile products sold in France. Evaluates 16 environmental indicators (e.g. climate change, water use, land use) based on Life Cycle Assessments (LCAs).

The law applies to all producers, importers, and distributors placing textile products on the French market, regardless of country of origin.

Eco-Score took effect in October, 2025. Here are the timeline details important for apparel and footwear brands:

• 1st October 2025: Entry into force. Only brands may voluntarily calculate and submit their product Eco‑Scores to the public portal. 
• From October 2026: If the fashion brand has not yet published a score themselves, any third party, e.g., retailers, NGOs, will be able to publish the Environmental Cost on behalf of textile brands – without needing the brand’s prior approval.  Scores calculated by brands themselves will automatically replace third-party scores, with a maximum delay of one month.
• From October 2026, as well, if the brand communicates any other environmental score (such as carbon footprint on the e-commerce store),  then displaying the Environmental Cost label becomes mandatory.

Read our French Textile Eco-Score deep dive here in English.

France: Fast Fashion Bill

 Status:  Proposal

France has proposed a dedicated law targeting “ultra-fast fashion” business models, with a focus on high-volume, low-price apparel sold through e-commerce platforms. The proposal aims to address the environmental impacts associated with rapid product turnover, low durability, and high textile waste generation.

The bill would introduce higher eco-modulated textile EPR fees for brands operating under ultra-fast fashion models, alongside restrictions on advertising and promotional practices. It would also require additional consumer information disclosures, including information related to product reuse, repair, recycling, and environmental impacts.

Because the proposed measures could affect cross-border trade and competition within the EU single market, France notified the draft law to the European Commission. The Commission raised concerns regarding potential conflicts with EU internal market rules, competition law, and proportionality. As a result, the legislative process has slowed, and the final scope and timing remain uncertain.

Italy: Fast Fashion Bill

 Status:  Proposal

In 2025, Italy proposed Bill DDL S. 1690, which bundles several measures into one law, all aimed at curbing the environmental impacts of ultra-fast-fashion and protecting Italy’s domestic textile industry from the competitive pressures of low-cost, high-volume products. 

The new draft law targets ultra-fast-fashion with three main measures:

1. Eco-Score system (SNET): An A–E scoring system for textile products used by the government to decide which companies to punish and which to reward for environmental performance.

2. Advertising ban: From January 1, 2026, ads for ultra-fast-fashion are proposed to be banned, including influencer promotions.

3. Parcel eco-tax: A €2–4 tax on small parcels (<2 kg) with textile products shipped from outside the EU.

If your brand is selling in Italy, this bill should be on your radar – read our deep dive on Italy's Fast Fashion bill for apparel and footwear brands here.

Norway: Transparency Act (Åpenhetsloven)

 Status:  ✅ Approved Norwegian law

In force since July 2022, Norway’s Transparency Act applies to large and mid-size companies operating in Norway or selling goods and services into the Norwegian market. The law focuses on preventing and addressing adverse impacts on human rights and working conditions across companies’ operations and supply chains.

The Act requires in-scope companies to carry out due diligence in line with the OECD Guidelines for Multinational Enterprises and to make information about this work publicly available. Enforcement and guidance are overseen by the Norwegian Consumer Authority.

Climate and environmental impacts are relevant under the Act when they lead to negative impacts on human rights or working conditions.

The Act applies to companies meeting at least two of the following thresholds: more than 50 employees, annual turnover above NOK 70 million, or a balance sheet total above NOK 35 million. 

Germany: Supply Chain Due Diligence Act

 Status:  ✅ Approved German law

Similar to Norway’s Transparency Act, this piece of German legislation addresses human rights and working conditions in the supply chain.

The law remains legally in force. Brands are still required to maintain internal due-diligence systems to identify, assess, and address human-rights and certain environmental risks in their own operations and direct supply chains. This includes having risk-management processes, preventive and corrective measures, a complaints mechanism, and internal documentation. 

What has changed is the enforcement of the public reporting obligation: German authorities have paused active scrutiny of annual LkSG reports as part of a government effort to reduce administrative burden while amendments to the law are prepared. In practice, this means fashion companies must continue doing due diligence, even though authorities are currently not penalizing reporting failures.

How to Stay Compliant With the Upcoming EU Textile Regulation

As the EU continues to introduce and refine its climate regulations and directives, it will be essential for apparel and textile brands to have a clear understanding of their products’ environmental impact throughout the entire life cycle. As an apparel or footwear brand, it’s important to prepare for the EU textile strategy regulations and directives – especially as gathering and consolidating all your data takes quite a lot of effort. You will be required to report retroactively, so it is important to get the right tools in place now. 

Carbonfact is here to help. We are a team of climate scientists, engineers, and data experts who came together to build innovative software to simplify environmental footprint measurement for fashion and textile brands.

We deliver accurate, third-party reviewed environmental data for each of your products, so fashion brands can reduce their absolute and per unit environmental footprint. 

Get in touch to see how we can help you stay compliant.