New EU Ecodesign Regulations Put Textile Supply Chains Under Greater Transparency Requirements

Textile supply chains exporting to the European Union are entering a phase in which information about a product may become almost as important as the product itself. In addition to requirements concerning quality, chemical safety and environmental responsibility, businesses will need to be better prepared to demonstrate what materials an item is made from, how far it can be repaired or recycled, and how the product’s environmental impact is being controlled.

The main driver is the EU Ecodesign for Sustainable Products Regulation, commonly known as the ESPR. This legislation establishes a legal framework for the EU to develop sustainability requirements for many product groups, including textiles and footwear, which are among the groups under consideration. The ESPR does not automatically make every textile product subject to a single set of criteria. Specific requirements will depend on the product-group regulations adopted later.

This creates an important preparation period for Vietnamese businesses. The challenge is not limited to changing a type of fiber, dye or finishing process. The larger issue is building a data system that runs from materials and suppliers through production and distribution, while also turning that data into verifiable evidence.

ESPR changes how product sustainability is viewed

Previously, environmental compliance activities in the textile industry were often implemented through material certifications, chemical management systems, social responsibility standards or reports from individual factories. These tools remain valuable, but the EU’s new policy direction places greater emphasis on the product’s entire life cycle.

Under the ESPR, the EU may introduce requirements concerning durability, reusability, upgradability, repairability, the proportion of recycled materials, resource efficiency and recyclability. For textiles, future requirements could relate to product design, fiber composition, durability during use, disassembly or treatment after the product is discarded. However, the specific content must be determined in legislation or implementing regulations for each product group; the ESPR framework should not be treated as identical to obligations already in force for all products.

This approach changes the starting point for businesses. Instead of asking only whether a shipment meets the customer’s technical specifications, businesses must also consider how the product is designed, how many types of materials it uses, which components make recycling difficult and what data needs to be retained throughout its life cycle.

The Digital Product Passport becomes an important part of the data system

One prominent tool under the ESPR is the Digital Product Passport. This is an electronic information system linked to a product that allows relevant parties to access data appropriate to their rights and responsibilities. Its goal is to improve access to information about a product’s sustainability, origin or characteristics.

For the textile industry, the Digital Product Passport could require data that is currently stored in separate locations to be more standardized. A product may need information about fiber composition, the origin of materials, the proportion of recycled materials, care instructions, repairability or post-use treatment options. The exact data categories will depend on the requirements adopted for each product group.

Businesses should therefore not wait until the final requirements are issued before beginning digitization. The first step could be to map the data: what information already exists, what data is held by suppliers, what data lacks a consistent measurement method and what information exists only in the form of commitments. This is a way to distinguish verifiable information from environmental claims that do not yet have sufficient evidence.

Which parts of Vietnamese textile businesses will be affected?

The impact will not be the same for contract garment manufacturers, fabric producers, yarn manufacturers and material suppliers. However, at least four groups of activities require attention: traceability, material management, process control and coordination with customers.

Material traceability needs to go beyond a purchase document

In a textile product, yarn may pass through multiple stages and countries before becoming fabric or a finished garment. If a management system stops at invoices or delivery documents, a business may face difficulties when a customer requests specific confirmation of yarn origin, the proportion of recycled materials or the production process.

This does not mean that every business must immediately build a complex technology platform. A standardized lot-coding system, updated supplier records, a certification-checking process and a mechanism for storing test results can provide a foundation. The data can then be connected to a production management system or supply chain management software.

The important point is that data must be consistent across departments. If the purchasing department records one fiber composition, the technical department uses a different name and the export department cannot link the two pieces of information to the same production lot, traceability will take more time and discrepancies are likely to arise.

Product design will directly affect compliance costs

Sustainability requirements are often viewed as a production issue, but design determines much of a product’s ability to meet those requirements. A product that uses too many types of blended fibers, difficult-to-separate components or complex finishes may be harder to recycle than a product with a simple structure. Conversely, design that improves durability and repairability can extend the product’s useful life, although it may sometimes increase initial costs.

For Vietnamese suppliers, this is an area where early coordination with brands is necessary. Garment factories often do not have full decision-making authority over the style, materials or components, but they can provide technical data, propose alternative materials and assess manufacturing feasibility. If requirements are received only at the final stage, businesses will find it difficult to change the product without affecting delivery schedules and costs.

Design discussions should therefore include questions about the product life cycle. For example, can the product be repaired; which details can be removed; do washing and care have a significant effect on durability; and do the usage instructions help consumers extend the product’s useful life? These are more practical questions than simply placing a general “green” message on the product.

Data transparency will differentiate competitiveness

The ESPR does not only create additional compliance requirements. From a business perspective, it may clarify the difference between companies with strong data management capabilities and those dependent on fragmented records from multiple suppliers.

Businesses that already have relatively complete systems for managing quality, environmental issues, chemicals and traceability will have an advantage when expanding to meet new requirements. They can identify missing data more quickly, determine which processes create risks and identify which suppliers need to be reassessed. Smaller businesses, by contrast, may face greater pressure because testing, digitization and training costs are spread across a limited production scale.

In the short term, international customers may continue to request data even before all EU implementing regulations apply to a specific product group. Brands generally have to manage risks throughout the supply chain, so they tend to pass some requirements concerning materials, chemicals, emissions and traceability down to suppliers. As a result, a business’s level of preparedness may affect its ability to retain orders, not just its customs-clearance procedures.

However, not every customer requirement should be viewed as a direct legal obligation under the ESPR. Businesses need to clearly distinguish among three groups: mandatory rules in the importing market, a brand’s own standards and voluntary objectives under a sustainability program. This classification helps avoid duplicate investment and reduces the risk of making commitments that exceed the ability to provide evidence.

Costs involve more than alternative materials

When sustainable production is discussed, attention often focuses on the price of recycled fibers, renewable energy or water-treatment technology. In practice, compliance costs also include testing, supplier assessments, software, staff training, data audits and the time required to coordinate with customers.

Businesses need to assess costs by product line rather than applying one solution to the entire factory. Some product groups may be suited to reducing the number of material types or standardizing components. Others may require investment in traceability systems or durability testing. A risk-based approach helps prioritize resources for the processes that have the greatest impact on compliance capabilities.

The transition must also avoid a common misconception: recycled materials do not automatically mean that a product is more sustainable in every case. Assessment also depends on the source of the materials, the production process, durability, the possibility of long-term use and treatment options after the product is discarded. Businesses should rely on data and appropriate assessment methods rather than using a single attribute to describe the product’s entire environmental impact.

Three things businesses should prepare early

First, businesses need to create a minimum data inventory for each product and each stage. This inventory may include material composition, lot codes, suppliers, relevant certifications, test results, chemical information and production records. The initial goal is not to collect every type of data, but to identify the information that may be requested repeatedly and needs to be retrieved quickly.

Second, businesses need to check the quality of supplier data. An expired certificate, a certificate that does not cover the relevant product scope or one that cannot be linked to a specific shipment is not equivalent to fully controlled evidence. The purchasing, quality and product development departments should agree on criteria for accepting records instead of allowing each department to apply a different interpretation.

Third, businesses should include requirements concerning repairability, durability, materials and end-of-life treatment during the product development stage. If these aspects are checked only after an order has been completed, the cost of making changes will be higher and the available options will be more limited. For contract manufacturers, participating early in technical discussions with customers can create additional value instead of competing only on price and delivery capacity.

Industry associations, regulators and solution providers also have a role to play in this process. Small businesses may find it difficult to build an entire system on their own without common guidance on terminology, measurement methods and data standards. Training programs, testing laboratories and shared platforms can help reduce initial costs while limiting the situation in which each business has to create a different set of records for the same requirement.

Preparation time matters more than waiting for the final regulations

The ESPR currently remains a policy framework for many product groups; specific obligations for textiles will depend on the process of developing and adopting product-sector regulations. Businesses should therefore not conclude that every requirement concerning Digital Product Passports or specific material proportions already applies in the same way to all textile products.

Even so, waiting until the final legislation takes effect before acting may reduce the available options. Building foundational data, standardizing lot codes, reviewing suppliers and improving product design all take time. These are also capabilities that can support other requirements, such as chemical control, emissions reporting, supply chain assessments and compliance with customers’ own standards.

For Vietnam’s textile industry, the green transition is therefore not only a matter of changing materials or installing new equipment. It is a process of turning product information into a verifiable management asset. In a market where buyers increasingly demand specific evidence, businesses that control data effectively and understand the product life cycle will have more room to maintain relationships with EU customers and participate in orders with higher technical requirements.