The EU Is Shifting Its Focus to Product Life Cycles: What Must the Textile Industry Prepare For?

The textile industry is entering a period in which product requirements no longer stop at quality, cost, or delivery time. In major markets, particularly the European Union (EU), businesses increasingly have to demonstrate what materials a product is made from, how many resources it uses, how it can be repaired or recycled, and what happens after the product reaches the end of its life cycle.

At the center of this change is the EU Ecodesign for Sustainable Products Regulation, commonly known as the ESPR. Regulation 2024/1781 was enacted in 2024, establishing a legal framework for the EU to develop specific requirements for different product groups. Textiles are among the sectors receiving attention because of their high consumption of raw materials, uneven product life spans, and complex supply chain structures.

ESPR does not mean that every garment immediately has to meet an identical set of criteria. The actual impact will depend on the detailed regulations issued for each product group. However, the direction is already quite clear: businesses exporting to the EU need to move from an “order fulfillment” approach to managing the entire product life cycle.

From Product Standards to Managing the Entire Life Cycle

In the traditional production model, a supplier’s responsibilities are often measured by criteria such as matching the sample, delivering the correct quantity on time, and meeting inspection requirements. These criteria remain important, but they no longer cover all market requirements. The EU’s new policies expand the scope of assessment to design, raw material sourcing, production processes, long-term usability, and post-consumer treatment.

ESPR provides a basis for the EU to establish requirements for the durability, reusability, upgradability, repairability, maintainability, and recyclability of products. The regulation also aims to limit products that waste resources or are difficult to process after disposal. For the textile industry, this may involve fiber composition, colorfastness, mechanical durability, the ability to disassemble components, and the ease of sorting materials.

An important point to note is that a design requirement can affect several departments at the same time. If a product must be easier to recycle, businesses may need to reconsider fiber blends, trims, labels, thread, zippers, coatings, and finishing methods. If a product must have a longer life span, the design and purchasing departments will no longer be able to select materials based solely on the lowest price.

The Regulation Does Not Replace All Existing Requirements

ESPR is a new legal framework and does not automatically eliminate other regulations currently applicable in the EU. Textile businesses must still pay attention to requirements concerning chemicals, product safety, extended producer responsibility, labeling, and the separate regulations of individual member states where relevant.

Therefore, preparation should not begin by looking for a single “ESPR certification.” A more practical approach is to map the requirements for each product and market, then identify which data is already available, which data is missing, and which data needs to be verified by an independent party.

Product Data Will Become Part of Competitiveness

One of the notable elements of ESPR is its direction toward establishing a Digital Product Passport. This passport is designed to store and provide information related to products, materials, or sustainability factors throughout the value chain. The specific implementation method will depend on the relevant sector-specific regulations and technical standards.

For textile businesses, data requirements may change the way information is managed. Product files will no longer consist only of technical specifications, bills of materials, and shipping documents. Businesses may need to link data on fiber sources, suppliers, composition percentages, chemicals used, dyeing and finishing processes, energy consumption, care instructions, and options for handling products after use.

Not all data necessarily has to be made public to every party. However, businesses need to demonstrate that the information provided is consistent, traceable, and appropriate to the scope of the requirements. This creates a major challenge for multi-tier suppliers, as a garment may use materials from several countries and pass through multiple stages at different facilities.

Traceability Is Not Just a Software Issue

Many businesses may think that data digitalization means purchasing new management software. In reality, software is only part of the issue. If input data is not collected consistently or there are no verification procedures, a digital system will merely store inaccurate information more quickly.

Businesses need to standardize the names of materials, product codes, units of measurement, and calculation methods across departments. A recycled fiber must also be clearly identified as either pre-consumer or post-consumer recycled fiber, with the basis for calculating the percentage and the evidence used for verification clearly defined. Concepts such as “sustainable,” “environmentally friendly,” or “recycled” should not appear in records without an appropriate scope and basis for verification.

This is where small and medium-sized businesses may face difficulties. They often do not control the entire supply chain and have limited resources to maintain complex data systems. Nevertheless, starting with key product groups, high-risk materials, and customers with the greatest traceability requirements can help allocate resources according to priority.

Materials and Design Will Be Affected Early

In the textile industry, material selection directly affects recyclability, durability, water and energy consumption, and the ability to meet customer criteria. However, no single fiber is suitable for every product. Material substitution needs to be based on functional use, durability, safety, care conditions, and the ability to recover the material after consumption.

For example, a product made from a blend of several fiber types may provide suitable performance or comfort, but it is often more difficult to sort and process at the end of its life than a product with a simpler material structure. Conversely, switching to another material without assessing durability, supply, and production conditions may create new risks. Therefore, circular design is not simply about replacing materials; it involves considering the entire product structure.

Small design changes can also have a significant impact. Businesses can explore reducing the number of components that are difficult to separate, selecting trims that are easy to remove, designing seams to facilitate repair, or providing care instructions that help extend the period of use. These solutions need to be tested in practice rather than relying solely on marketing claims.

For Vietnamese suppliers, this increases the role of the product development department. Businesses must not only receive technical requirements from customers but also participate earlier in the selection of materials, the design of product structures, and the development of data records. Consulting capabilities may become a factor that helps suppliers maintain their position in the value chain instead of competing solely on manufacturing capacity.

Impact on Businesses and Supply Chains

The first impact may appear in purchasing. Raw material suppliers will have to provide clearer information about composition, origin, and production methods. These requirements may increase the cost of testing, supplier assessment, and document management, especially when a business uses multiple material sources for the same product code.

The second impact concerns production planning. If a business wants to maintain product lines with recycled material content or high traceability requirements, it needs to ensure supply stability and the ability to separate materials in storage. Replacing materials at the last minute may affect the product file, test results, and commitments to customers.

The third impact is a change in contractual relationships. Customers may require suppliers to take responsibility for data accuracy, notify them of material changes, and retain records for a specified period. These provisions mean that quality management, purchasing, legal, and information technology systems must work together more closely.

In the short term, the transition may increase costs. Businesses will need to invest in training, testing, digitalization, supplier assessments, and design improvements. However, delaying preparation may also create greater costs if a business cannot meet customer requirements or prove product information when requested.

Opportunities Extend Beyond Exporting

The circular economy is often viewed primarily as a compliance requirement. This perspective is incomplete. When businesses effectively control material data and production efficiency, they can identify sources of waste, reduce defects, manage inventory more effectively, and design products that better match usage needs.

Transparent information can also help businesses access higher-value orders, in which customers are concerned with traceability and environmental performance alongside production capabilities. Businesses that build data processes early may reduce the time needed to answer customer questionnaires and avoid having to recollect information for every order.

Nevertheless, the circular economy should not be equated with using large amounts of materials described as “green.” Results need to be assessed across the entire life cycle and in light of the intended use. A product with a short life span or poor repairability does not necessarily become sustainable simply because it contains a percentage of recycled material. Conversely, a durable, long-lasting, repairable product can create significant benefits even when its material solution is not yet fully optimized.

What Road Map Should Businesses Follow?

First, businesses need to identify the products connected to the EU market and classify them according to their level of dependence on customers, materials, and supply chains. They should not implement a very broad data program that is not linked to a specific product or market.

The next step is to map the supply chain from raw materials to finished products. This map should identify direct suppliers, outsourced processes, data transfer points, and locations where evidence may be lacking. For important materials, businesses should agree in advance on the types of documents required and how to handle situations where information from different parties does not match.

At the same time, businesses should establish a minimum product data set. This data set may begin with material composition, supply sources, product codes, care instructions, and testing records. Once the operating process is stable, businesses can expand to more complex indicators. A phased approach helps reduce the risk of spreading investments too thinly.

Finally, circular design needs to be incorporated into product development from the outset. The design, purchasing, engineering, quality, and sales departments should jointly assess a product before materials are finalized. This helps prevent sustainability requirements from being added only at the end of the process, when all major decisions have already been completed.

The EU has not turned every ESPR requirement into an identical obligation for the entire textile industry. However, this policy framework shows how the market is changing: information about products, long-term usability, and post-consumer treatment options will increasingly be linked to business conditions. For textile businesses, early preparation is not only a way to reduce compliance risks but also an opportunity to improve their position in the supply chain. Businesses that control their data, understand their materials, and incorporate life-cycle thinking into design will have greater advantages as detailed requirements are implemented.