EU Ecodesign Regulation Expands Pressure on the Textile Industry

Textile and apparel exporters to Europe are facing a change that involves more than materials or production processes. With the European Union’s Ecodesign for Sustainable Products Regulation, commonly known as the ESPR, requirements concerning durability, repairability, resource use, product information and post-consumer treatment are brought together within a single policy framework.

The regulation does not immediately apply an identical set of criteria to every product. Instead, the ESPR empowers the European Commission to develop product-specific rules through subsequent legislation. This is an important point for textile and apparel businesses: the practical impact will depend on the specific criteria established for textiles, the timing of implementation and how the requirements are translated into obligations for manufacturers, importers and other participants in the supply chain.

Even so, the policy direction is clear. The European market is moving from an approach focused only on controlling chemicals or waste toward requirements that consider the entire product life cycle. Businesses seeking to maintain market access will need not only to demonstrate that products were manufactured according to orders, but also to prepare data on materials, origins, use characteristics and their ability to circulate within a circular economy model.

ESPR changes how the EU manages products

Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products was adopted by the EU in June 2024 and entered into force in July of the same year. It replaces the previous ecodesign framework, which primarily focused on energy-related products.

The scope of the ESPR is considerably broader. The regulation provides a basis for the EU to establish requirements relating to durability, reusability, upgradability, repairability, maintenance, recyclability, resource and energy consumption, as well as recycled content in products. The requirements may also concern restrictions on substances that hinder product circularity or cause adverse environmental impacts.

The ESPR is not a regulation specifically for apparel. However, textiles are among the industries frequently mentioned in the EU’s circularity policies because textile products have complex life cycles, use various types of fibers and often incorporate dyes, accessories, coatings or components that are difficult to separate. Reuse and recycling are also heavily influenced by the product’s original design.

From the perspective of Vietnamese businesses, it is necessary to distinguish between three layers of requirements. The first consists of legal obligations already applicable under other EU regulations, such as rules on chemicals, product safety or extended producer responsibility in individual markets. The second is the ESPR framework, which provides a basis for future product requirements. The third consists of product-specific rules, which may clearly define indicators, technical documentation, conformity assessment methods and ways of providing information.

Product data is becoming part of export capability

One of the notable elements of the ESPR is the Digital Product Passport. This is a mechanism intended to link products with data on relevant characteristics, thereby helping various participants in the value chain access the information they need.

A product passport does not mean that all company data must be made fully public. The access method, the types of information that must be provided and the parties entitled to view it will depend on specific regulations. However, the general direction indicates that product information will no longer remain solely in a supplier’s internal records or in a set of delivery documents.

For textiles and apparel, the data may relate to fiber composition, material ratios, raw material origins, care instructions, durability, repairability or treatment after use. Not all of these categories of information had become universally mandatory for every product when the ESPR entered into force. Therefore, businesses should not assign themselves a list of obligations that has not been specifically established. However, if current data systems stop at the order level and cannot be linked to individual product codes, meeting future requirements will be more difficult.

Traceability is not only about raw materials

In textile and apparel operations, traceability is often understood as identifying the origins of cotton, man-made fibers, yarn, fabric or accessories. The newer understanding needs to be broader. Businesses must be able to connect data across incoming materials, spinning, weaving or knitting, dyeing and finishing, cutting and sewing, and quality inspection.

This is particularly important for orders involving multiple suppliers. A product may pass through several countries and several layers of businesses before reaching a European brand or retailer. If data is interrupted at any stage, the company at the end of the chain may have difficulty proving the product’s composition or characteristics.

Therefore, investing in data does not necessarily have to begin with a complex system. Businesses can start by standardizing material codes, naming conventions, supplier records, shipment documents and cross-checking procedures. The objective is to create consistent, verifiable data with clearly assigned responsibility, rather than simply accumulating numerous disconnected files.

Product design will affect circularity

In the traditional model, design decisions often prioritize appearance, cost, production speed and buyer requirements. Issues such as disassembly, repairability or recyclability are often considered at a later stage. The ESPR promotes a different approach, in which these characteristics are taken into account from the design stage.

For textiles and apparel, the challenge lies in the diversity of products. Shirts, sportswear, protective clothing, footwear, household textiles and coated products do not have the same technical requirements. A product made from multiple fiber types may provide good functional performance but be difficult to process at the end of its life. Zippers, buttons, sewing threads, prints, waterproof layers and decorative components may also increase the complexity of sorting or recycling.

From a production perspective, this does not mean businesses must immediately eliminate all blended materials or change their entire product range. Material decisions should be based on function, durability, safety, technical requirements and market regulations. However, businesses will need to provide stronger evidence for their material choices and assess the impact of those choices throughout the product’s life cycle.

Durability also has direct economic significance. A product that can be used for longer may reduce the need for replacement, but to turn this benefit into a verifiable requirement, businesses need appropriate testing methods. Claims such as “sustainable,” “environmentally friendly” or “long-lasting” cannot rely solely on marketing messages; they need to be linked to corresponding criteria, documentation and evidence.

Compliance pressure will spread across the supply chain

Brands and retailers in Europe are usually the parties that deal directly with consumers and regulators. However, much of the data needed to substantiate a product is held by suppliers. Therefore, even though specific legal obligations may be distributed differently among participants, commercial pressure will likely move upstream toward manufacturers.

Contract garment manufacturers may receive additional requests for fabric composition, chemical records, raw material certifications, resource consumption levels or information for life-cycle assessments. Suppliers of fabric, yarn and accessories may also be required to provide data in more standardized formats. Suppliers that cannot respond accurately or maintain consistency between their records and actual products may face the risk of being removed from purchasing lists.

This is a notable shift in competition. Previously, Vietnamese businesses’ advantages were often assessed through delivery capabilities, sewing quality and cost. In the new context, data management, supplier control and the ability to substantiate product information may become part of a company’s selling capability.

Costs go beyond equipment

When discussing green production, businesses often think of energy-efficient machinery, water treatment systems or renewable electricity. These remain important investments, but complying with product requirements also creates costs in less tangible areas.

In addition to equipment costs, businesses may need to train personnel, develop data collection procedures, assess suppliers, test materials, verify records and update management software. For small and medium-sized enterprises, the greatest burden may not be a single piece of equipment but the lack of coordination among purchasing, technical, production, quality and export departments.

Not every investment will produce results immediately within a single product season. A good data system can help reduce the time needed to respond to customer requests, limit inconsistencies in records and identify unsuitable material lots at an early stage. However, to achieve these benefits, businesses need to implement measures according to priorities rather than pursuing every new standard or technology at the same time.

Vietnamese businesses need to prepare through a roadmap

The first step is to map requirements by market and product category. Businesses should not view the ESPR as a single, fully completed set of criteria for the entire textile and apparel industry. Specific obligations will depend on implementing legislation, product categories, the company’s role in the chain and customer requirements.

Next, businesses need to identify the data they currently have and the data they lack. The list may include fiber composition, material codes, suppliers, production lots, finishing processes, test results and product handling instructions. Each data point should be linked to its source, update date and responsible person.

The third step is to review design and materials. The objective is not to change products merely to meet an environmental slogan, but to assess the balance between durability, functionality, repairability, recyclability, cost and actual needs. For products with many components, businesses should identify which parts create difficulties for disassembly or treatment after use.

Finally, businesses need to maintain an official update channel. EU product-specific regulations may add new requirements concerning deadlines, documentation and assessment methods. Relying only on commercial summaries or word-of-mouth information can easily lead to misdirected investments or overlooked obligations.

Competition will shift from contract manufacturing to the ability to substantiate products

The ESPR has not yet created a uniform requirement that immediately applies to every textile and apparel product, but it has laid the foundation for a new way of assessing products. Products will be evaluated not only by where they are made and their selling price, but also by how they use resources, their level of durability, the circulation of information and their treatment options after use.

For Vietnam’s textile and apparel industry, this change creates both pressure and opportunity. Businesses with strong management systems can use data and transparency to strengthen relationships with European customers. Conversely, businesses that rely on manual records, fragmented data and unstable sources of supply will find it more difficult to respond when requirements become specific.

In the immediate period ahead, the most practical task is not to predict every future criterion, but to build an adaptable foundation: clearer traceability, more consistent records, designs assessed from the outset and verifiable product information. As the market gradually shifts toward a circular economy, production capability will remain important, but the ability to demonstrate that products meet new requirements will increasingly determine opportunities to access orders.