The EU Sustainable Products Regulation Expands Traceability Requirements for Textile Businesses

The textile and apparel industry exporting to the European market is entering a phase in which product requirements go beyond quality, price and delivery times. Data on materials, production processes, durability, repairability, recyclability and post-use treatment is increasingly becoming part of competitiveness.

The important legal foundation for this trend is Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products, commonly known as the Ecodesign for Sustainable Products Regulation, or ESPR. The regulation was issued by the European Union in 2024, replacing the previous approach, which focused mainly on the energy efficiency of certain product groups.

ESPR is not a separate set of standards intended only for textiles and apparel. It is a legal framework that allows the EU to establish specific requirements for each product group through subsequent implementing measures. However, textiles are one of the sectors identified by EU authorities as requiring attention during the expansion of the sustainable products policy. For Vietnamese manufacturers and suppliers, this means that market access requirements will increasingly be linked to their ability to create, control and share data throughout the supply chain.

ESPR changes the EU’s approach to sustainable products

A notable feature of ESPR is its shift from controlling certain individual characteristics to considering the entire product life cycle. Under this regulatory framework, future requirements may relate to durability, reusability, upgradability, repairability, recycled content, resource efficiency, environmental impact and the availability of product information.

The regulation also provides a basis for establishing a Digital Product Passport. This is an electronic data system intended to provide information related to a product and its components and materials. Depending on the product group and the specific requirements subsequently issued, the data may serve various parties, from regulatory authorities and businesses in the supply chain to consumers and end-of-life treatment operators.

The existence of a common framework does not mean that all requirements have already been applied to every textile product. Specific obligations will depend on the regulations for each product group and their respective effective dates. This distinction needs to be made clearly to avoid two extreme interpretations: assuming that businesses must immediately meet a detailed set of requirements that has not yet been issued, or conversely assuming that because the policy is still at the framework stage, no preparation is necessary.

Data becomes part of the product

Under the traditional export model, suppliers generally focus on demonstrating that products meet technical, chemical safety, colorfastness or other customer-specified criteria. Under the new approach, product information may need to be linked to data on materials and preceding processes.

For an apparel product, relevant data may begin with the fiber type, yarn source, blend ratio, weaving or knitting, dyeing, finishing, cutting, sewing and packaging processes. Not all information will necessarily be required at the same level, but businesses need to be able to identify which data they create, which data they receive from suppliers and how to check consistency across records.

A major challenge is that textile supply chains often have multiple tiers. An apparel exporter may purchase fabric from one supplier, while that supplier buys yarn from another business and uses dyes and finishing chemicals from a separate supplier network. If data is managed only at the level of the final order, responding to more detailed requests about materials will be difficult and time-consuming.

What do textile businesses need to prepare?

Preparing for sustainable product requirements is not simply a matter of purchasing traceability software. First, businesses need to map their supply chains by product group and identify the data that is relevant to customers, regulatory authorities and post-use treatment stages.

For apparel businesses, an initial step may be to standardize the identification of product codes, colors, material lots and orders. Data from fabric inspection reports, material documents, test results, chemical records and supplier information should be linked rather than stored separately across multiple departments. When information is standardized from the outset, providing data to customers or conducting internal checks will depend less on manual records.

Textile and dyeing businesses need to pay closer attention to data on fiber composition, resource consumption, chemicals used, wastewater treatment and production parameters related to the requirements of each market. Not all operational data necessarily needs to be disclosed to consumers, but businesses still need to distinguish between data used for internal management, data exchanged between businesses and data that may need to be linked to a product passport.

For material suppliers, an important requirement is consistency between commercial claims and supporting records. Descriptions such as “recycled,” “organic,” “low impact” or “recyclable” need to be linked to clear criteria, documentation and scopes of application. If information in purchase documents, material labels, test results and data sent to customers is inconsistent, the risk may not be limited to one shipment but could also affect the reliability of the entire supply chain.

Traceability does not mean disclosing every trade secret

A common concern among businesses is how much data they must share and how to protect commercial information. ESPR establishes a framework for product data, but system design and access rights must also comply with the specific requirements for each product group. Therefore, businesses should not automatically place all production data on an open system.

A more appropriate approach is to classify data according to its purpose and access rights. Information needed by regulatory authorities, customers, recyclers and consumers may differ. Businesses also need to determine which data they own, which data is provided by suppliers and how updates will be made when materials or processes change.

This is a governance issue, not merely a technology issue. Even a modern system can produce unreliable records if its input data is not verified. Conversely, a business can start with a simple process, provided that information is clearly identified, responsibility is assigned and the data can be checked again.

Impact on Vietnam’s supply chain

For Vietnam’s textile and apparel industry, the impact of this trend may emerge before all detailed EU requirements apply directly to each product. Brands and importers often have to manage risk across the entire supply chain. As a result, they may ask suppliers to prepare data earlier than the legally mandated deadline, particularly for orders aimed at sustainability or circular economy objectives.

This creates differentiation among businesses. Companies that already have relatively complete systems for quality management, chemical management, material traceability and production data will have an advantage as customer requirements increase. Conversely, businesses that rely heavily on paper records, purchase materials through multiple intermediary layers or have not yet controlled supplier data may need to make significant investments to maintain orders.

However, data transformation also has positive aspects. When businesses know exactly which processes materials have passed through, they can identify bottlenecks, reduce discrepancies between plans and actual operations, limit the mistaken use of lots or missing records during inspections. Good data also supports cost calculations by process and evaluation of the effectiveness of measures to save water, energy or materials.

The more difficult issue is the ability to coordinate among businesses of different sizes. A large factory may be able to build its own data system, but a small supplier in the same chain may not have sufficient staff and budget to meet the same standard. If brands use too many different forms, compliance costs will increase and data will be difficult to connect. Therefore, standardizing formats, terminology and methods of exchanging information is no less important than investing in software.

Opportunities for green production and the circular economy

ESPR was developed in a context in which the EU seeks to promote products with longer life cycles and more efficient resource use. For textiles, this expands the scope for solutions such as designing products that are easier to repair, increasing durability, using controlled recycled materials and improving sorting after products are discarded.

Nevertheless, a claim about recycled material should not be equated with complete circularity. A product containing recycled fibers still needs to be assessed in terms of the source of its materials, blend ratio, durability, ability to separate components and end-of-life treatment infrastructure. Similarly, the fact that a product is technically recyclable does not mean that collection and recycling systems are ready in every market.

For businesses, a practical approach is to incorporate environmental objectives into design and material purchasing decisions from the outset. Changes to fiber content, trims or finishing methods may affect durability, user experience, cost and recyclability. These trade-offs need to be verified through testing and data rather than relying solely on marketing messages.

Businesses should also avoid treating sustainability requirements as a separate project for the environmental department. Design, purchasing, engineering, production, quality, information technology and sales all affect the quality of product data. If each department uses different identification methods or calculations, the business will struggle to create consistent records when working with international customers.

Points to monitor in the coming period

The first point to monitor is the EU’s specific legislation for each product group. The ESPR framework is only the basis for developing detailed requirements; the scope of data, technical criteria, assessment methods and implementation dates may differ among product groups. Businesses should not take a requirement applicable to one product and generalize it to the entire textile and apparel industry.

The next point is how brands and importers translate legal requirements into commercial conditions. In practice, contracts, technical requirement sheets and supplier assessment procedures may be where businesses first receive requests for material data, production records or traceability capabilities. Monitoring communication with customers therefore needs to take place alongside regulatory updates.

Finally, businesses need to monitor the ability to connect data systems. If each organization uses a completely different platform, suppliers will have to enter the same information repeatedly. Initiatives involving data standards, identifiers and interoperability may determine the actual cost of the transition. While detailed requirements are not yet fully available, businesses should prioritize data that is accurate, verifiable and easy to export in different formats.

For Vietnam’s textile and apparel industry, early preparation does not mean spreading investment across every new technology. A sensible priority is to identify key markets and product groups, review breakpoints in the supply chain, standardize core data and establish verification procedures. When sustainable product requirements are made more specific, businesses with a strong data foundation will be more likely to adapt than those that only begin preparing when customers introduce mandatory conditions.