Textiles are a priority sector in the ESPR Work Plan 2024–2027. The delegated act is expected in 2026, with compliance requirements entering into force in 2027–2028. Textile manufacturers must prepare for fibre composition declarations, recycled content data, chemical treatment disclosures, and repairability information in the DPP.
The ESPR textile delegated act is expected to cover: apparel (clothing and accessories), footwear, household textiles (bedding, curtains, towels), and industrial textiles. The Commission's preparatory study identified these as the highest environmental impact textile categories in the EU market.
| Data Category | Expected Requirement |
|---|---|
| Fibre composition | Percentage by weight of each fibre type (cotton, polyester, wool, etc.) — aligns with EU Textile Labelling Regulation (EU 1007/2011) |
| Recycled content | Percentage of recycled fibres by weight, with third-party certification (GRS, RCS, or equivalent) |
| Country of manufacture | Country where the fabric was woven/knitted AND country where the garment was cut and sewn (two-step traceability) |
| Chemical treatments | SVHC declarations, finishing chemicals, dye types, PFAS content (per REACH SVHC list) |
| Carbon footprint | GHG emissions per garment or per kg of product, by lifecycle stage |
| Water consumption | Water consumption in production (dyeing, finishing) per unit |
| Repairability | Availability of repair services, spare buttons/zips, care instructions for extended lifetime |
| End-of-life | Recyclability (mono-material vs blended), take-back scheme information, waste stream classification |
The ESPR delegated act for textiles builds directly on the EU Strategy for Sustainable and Circular Textiles (2022) and the existing EU Textile Labelling Regulation (EU 1007/2011). The DPP for textile products is expected to include: fibre composition by percentage, country of origin for each production stage (fibre, yarn, fabric, finishing, assembly), chemical substances used in production including any substances of concern, water consumption per kilogram of finished product, carbon footprint per garment unit, recycled content percentage with verification methodology, repairability score, recyclability at end of life, and the identity of the manufacturer and any authorised representative. For branded garments, the DPP must also reference the brand owner's EORI number.
The textile delegated act is widely understood to be aimed directly at fast fashion business models. The EU Commission's preparatory study for the textile delegated act explicitly references the environmental cost of fast fashion — the average EU consumer discards 11 kilograms of textiles per year, of which less than 1% is recycled into new fibres. The ESPR delegated act for textiles will introduce minimum durability requirements, restrictions on the destruction of unsold garments, and mandatory recycled content targets that increase over time. For fast fashion brands, this means that the current model of producing large volumes of low-durability garments at low price points will face direct regulatory pressure. Brands that cannot demonstrate compliance with durability and recycled content requirements will not be able to place products on the EU market.
Bangladesh, India, and Vietnam are the three largest textile exporters to the EU by volume. All three countries face significant compliance challenges under the ESPR textile delegated act. Manufacturers in these countries must understand that ESPR compliance is not optional — it is a market access requirement. The EU is the largest single export market for Bangladeshi garments, accounting for approximately 60% of total garment exports. Indian textile exporters face similar dependency. Vietnamese electronics and textile exporters have already begun engaging with ESPR compliance through the EU-Vietnam Free Trade Agreement (EVFTA) implementation framework. The practical compliance requirement for exporters in these countries is to implement supply chain traceability systems that can generate the data required for the DPP — fibre origin, chemical usage, water consumption, and carbon footprint — at the product level.
| Textile Category | Expected DPP Deadline | Key Compliance Challenge |
|---|---|---|
| Apparel and clothing | 2026–2027 (delegated act under preparation) | Multi-tier supply chain traceability |
| Household textiles (bedding, towels) | Same delegated act as apparel | Chemical substance disclosure |
| Technical textiles | Separate delegated act — timeline TBC | Performance data standardisation |
| Footwear | Linked to textile delegated act | Multi-material composition tracking |
| Carpets and floor coverings | Separate delegated act — timeline TBC | Recycled content verification |
Based on the EU Commission's preparatory study for the ESPR textile delegated act and the requirements of the EU Strategy for Sustainable and Circular Textiles, the ESPR textile DPP is expected to require disclosure of: fibre composition (percentage of each fibre type, with country of origin for natural fibres), chemical substances of concern (dyes, finishing agents, and other chemicals above threshold concentrations), carbon footprint per kg of finished textile (with lifecycle stage breakdown), water consumption per kg of finished textile (for dyeing and finishing processes), recycled fibre content percentage, recyclability assessment (recyclable / not recyclable), care instructions (washing temperature, drying method, ironing temperature), end-of-life instructions (collection point, recycling instructions), and the manufacturer's name and address.
Tracing the origin of textile fibres from farm to finished garment is one of the most technically challenging aspects of ESPR textile DPP compliance. Cotton, for example, passes through multiple processing stages (ginning, spinning, weaving/knitting, dyeing, finishing, cutting, sewing) before it becomes a finished garment, and at each stage the fibre may be mixed with fibres from different origins. Physical traceability methods (attaching a physical tag to the fibre bale and tracking it through the supply chain) are expensive and logistically complex. Digital traceability methods (using blockchain or other distributed ledger technologies to record each processing step) are more scalable but require all supply chain partners to participate in the traceability system. Isotopic analysis (using the isotopic signature of the fibre to determine its geographic origin) is an emerging verification method that can verify fibre origin claims without requiring supply chain-wide participation.
The EU Textile Labelling Regulation (EU 1007/2011) requires textile products to bear a label indicating the fibre composition. The ESPR textile DPP will incorporate and extend the textile labelling requirements — the DPP will contain the same fibre composition data as the physical label, plus additional data on the origin of the fibres, the chemical substances used in processing, and the environmental performance of the product. The EU Commission has indicated that the ESPR textile delegated act will align the DPP fibre composition data format with the existing textile labelling requirements to minimise the compliance burden for manufacturers that are already complying with the Textile Labelling Regulation.
ESPR Article 28 requires member states to establish extended producer responsibility (EPR) schemes for textiles by 2025. EPR schemes require textile producers to fund the collection, sorting, and recycling of post-consumer textile waste. The ESPR textile DPP will integrate with EPR schemes — the DPP will contain the producer's EPR registration number and the EPR scheme's collection point locator URL. This integration will enable consumers to find their nearest textile collection point and will help EPR scheme operators to track the volumes of textiles placed on the market by each producer. Textile manufacturers that are already participating in voluntary textile collection schemes (such as H&M's garment collection programme or Zara's InStore collection) will have experience with the operational aspects of EPR that will be useful when mandatory EPR schemes are established.
The ESPR textile delegated act is expected to be published in 2026, with compliance requirements entering into force in 2027–2028. The Commission's preparatory study was published in 2022 and identified apparel, footwear, and household textiles as priority subcategories.
Yes. The EU Textile Labelling Regulation (EU 1007/2011) requires fibre composition labelling and remains in force. ESPR will add DPP requirements on top of existing labelling requirements. The DPP will contain the same fibre composition data as the label, plus additional sustainability data.
The ESPR textile delegated act is expected to require recycled content declarations for recycled polyester (rPET), recycled cotton, and recycled wool. The minimum recycled content thresholds will be set in the delegated act. The DPP must include the verification methodology and third-party certification.
Yes. ESPR applies to all textile products placed on the EU market, regardless of the brand's business model. Fast fashion brands with high product turnover will face significant compliance costs due to the volume of DPP registrations required.
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa's first ESPR-compliant DPP registry.
Register Your Digital Product Passport →The EU textile industry generates approximately 12.6 million tonnes of textile waste annually in the EU alone. The global textile industry is responsible for approximately 10% of global carbon emissions and is the second largest consumer of water globally. ESPR identifies textiles as a priority product category for ecodesign requirements because of the scale of the environmental impact and the significant potential for improvement through better product design, longer product lifetimes, and higher recycled content.
The ESPR textile delegated act is expected to be one of the first delegated acts adopted under ESPR, with publication expected in 2025-2026 and mandatory compliance expected from 2027-2028. The delegated act will apply to clothing and textiles placed on the EU market — including products manufactured outside the EU and imported into the EU. This means that textile manufacturers in Bangladesh, Vietnam, India, Morocco, Ethiopia, and other major textile exporting countries must prepare for ESPR compliance.
| Data Category | Expected Requirement | Basis |
|---|---|---|
| Fibre composition | Percentage of each fibre type by weight | EU Textile Labelling Regulation (EU 1007/2011) |
| Recycled content | Percentage recycled fibres, verification method | ESPR Annex III |
| Country of origin | Country where fabric was woven/knitted and where garment was assembled | EU Customs Code |
| Chemical treatments | Substances of concern used in dyeing, finishing, and treatment | REACH Regulation |
| Carbon footprint | CO2e per garment or per kg, lifecycle stage breakdown | ESPR Annex III |
| Water consumption | Litres per garment or per kg, production stage breakdown | ESPR preparatory study |
| Durability | Wash cycles, pilling resistance, colour fastness test results | ESPR Annex III |
| Repairability | Availability of spare buttons, zips, and repair instructions | ESPR Annex III |
| End-of-life | Recyclability, disassembly instructions, waste classification | ESPR Annex III |
The ESPR textile delegated act is expected to require supply chain traceability data in the DPP — evidence of where the fibres were grown or produced, where the fabric was woven or knitted, where the garment was assembled, and where the chemical treatments were applied. This traceability requirement is designed to address concerns about greenwashing (false claims of sustainable sourcing) and forced labour in textile supply chains.
Supply chain traceability is a significant compliance challenge for textile manufacturers with complex global supply chains. A garment assembled in Bangladesh may contain cotton grown in India, polyester made from recycled plastic bottles collected in China, and dyes produced in Germany. Collecting accurate traceability data for all these supply chain stages requires engagement with multiple suppliers across multiple countries, many of whom may not have the systems or the incentive to provide it.
African textile exporters — particularly those in Ethiopia, Morocco, and South Africa — face specific challenges in meeting ESPR textile requirements. Ethiopia's textile industry is growing rapidly, with major international brands sourcing garments from Ethiopian factories. Ethiopian manufacturers must prepare for ESPR compliance by collecting supply chain data, measuring carbon footprints, and implementing DPP systems before the textile delegated act enters into force. Country-specific guidance is available at Ethiopia and ESPR and Morocco and ESPR.