EU Ecodesign Regulations Will Change How Textile Businesses Prepare Orders

For many years, environmental requirements for textiles exported to Europe have mainly been expressed through brand standards, chemical regulations, social responsibility rules, and traceability requirements. This approach is now moving into a broader phase: products are expected to be designed to last longer, be easier to repair, and be reusable or recyclable, while also being accompanied by sufficiently reliable data throughout their life cycle.

At the center of this change is the European Union’s Ecodesign for Sustainable Products Regulation, commonly known as the ESPR. The EU enacted this regulation in 2024, creating a legal framework for establishing sustainability requirements for many product groups, rather than focusing only on energy efficiency as in the previous approach. Textiles and footwear are among the sectors identified by the EU as priorities in the development of product-specific requirements.

For Vietnamese textile businesses, the immediate impact is not necessarily a single set of criteria that will apply to every type of clothing right away. The more important issue is that data on materials, production processes, durability, chemicals, recycled-material content, and post-use treatment will increasingly affect market access. Businesses that only prepare documentation after an order has been confirmed may face more difficulties than those that build data systems from the raw-material purchasing stage.

ESPR Expands the Scope of Sustainable Product Policy

ESPR Regulation 2024/1781 establishes a common framework for the EU to introduce ecodesign requirements for products. According to the European Union’s text, the requirements may relate to durability, reusability, upgradability, repairability, recycled content, resource consumption, recyclability, and environmental impacts throughout the product life cycle.

An important point to note is that the ESPR is not a technical regulation specifically intended for the garment industry. It is a legal framework covering many product groups, with specific requirements to be developed through subsequent implementing instruments. Therefore, it should not be understood that all clothing products exported to the EU must already meet an identical set of indicators as soon as the framework regulation takes effect.

Nevertheless, the policy direction is relatively clear. The EU wants to shift part of the focus from treating waste after products are discarded to addressing design from the outset. For textiles, this may involve the choice of fibers, fabric structure, seam durability, the ability to detach components, the use of trims and accessories, and the information that must be provided to users or treatment operators.

The regulation also provides a basis for developing a Digital Product Passport. In essence, this is a mechanism that links a product with relevant data through digital means. The specific content will depend on each product group and on regulations issued later, but the general direction is that sustainability data should become more accessible to stakeholders throughout the value chain.

Data Is Becoming Part of Supply Capability

Under the traditional contract-manufacturing model, garment businesses typically hold some of the product information, while data on fibers, dyes, fabric finishing, or material sources may remain with upstream suppliers. When customers request certifications, businesses compile documentation for each order. This model may not be sufficient when data must be linked across the entire supply chain.

For example, a product containing recycled fibers does not merely need to state the percentage on its label. The business must also demonstrate the source of the materials, the transformation process, the quantity used, and consistency between purchasing documents and the product delivered to the customer. Similarly, claims about the origin of natural fibers, the use of chemicals, or a product’s recyclability are valuable only when supported by verifiable records.

This changes how traceability systems are viewed. Traceability is no longer merely a tool for meeting audits or handling complaints. It is gradually becoming infrastructure for sales, compliance, and risk management. Businesses that cannot control their material data will find it difficult to substantiate environmental claims, even if their factory production processes have improved.

Textiles Are a Priority Sector for the EU’s Circularity Roadmap

The EU has repeatedly identified textiles as a sector with significant impacts on resources and the environment, as well as an area that needs to be advanced toward circularity. The EU Strategy for Sustainable and Circular Textiles sets a direction for products that are more durable, easier to repair and recycle, and that reduce the use of hazardous substances and virgin synthetic fibers where appropriate.

The ESPR provides a legal tool for turning some of these directions into specific product requirements. The requirements will not affect only fabric or garment manufacturers. Fiber suppliers, dyeing companies, finishing operators, accessories businesses, importers, and brands may all need to coordinate to provide information or adjust their processes.

For Vietnamese businesses, the impact will depend on their position in the supply chain. Businesses producing goods according to designs and materials specified by customers may receive data requests from brands. Businesses that proactively develop products will have more control over fiber selection, fabric structure, and design, but will also bear greater responsibility for technical documentation.

A product with a high percentage of recycled fibers should not be equated with a product that automatically meets every sustainability requirement. A shirt may use recycled materials but still be difficult to recycle if it blends multiple fiber types, includes hard-to-separate accessories, or uses complex coatings. Conversely, a product with a simple and durable design may have advantages during the use phase, even if it has not resolved every end-of-life issue.

Durability Will Be Considered Alongside Many Other Factors

Durability is one of the factors with direct significance for garments. Products that are used for longer may reduce the need for frequent replacement, but durability cannot be assessed solely by perception. Fabric quality, colorfastness, shrinkage, seam strength, and washing resistance may all be relevant to a product’s useful life.

In practice, businesses need to distinguish between individual customer requirements and mandatory legal requirements. A brand may set testing levels higher than the market minimum or require a separate set of standards for each product line. Therefore, quality-management systems need to retain testing methods, material batches, test results, and links to the final product.

From a commercial perspective, the ability to provide consistent data may become a supplier-selection criterion. This is an assessment of supply-chain impacts, not a conclusion that every EU customer has already adopted the same requirements. However, as import-market policy moves toward mandatory information disclosure and life-cycle control, factories lacking data will find it more difficult to participate in orders requiring a high level of transparency.

What Should Businesses Prepare Before Specific Requirements Emerge?

Preparation should not begin with the purchase of a standalone software system. First, businesses need to map their product data: where materials come from, who supplies them, which documents confirm their composition, where the data is stored, and which department is responsible for verification. This map helps identify gaps that are often overlooked between purchasing, warehousing, technical, production, and export departments.

The next step is to standardize the coding of materials and products. A fabric may be given several names in purchasing, technical, and accounting systems. Without a common identifier, reconciling goods-receipt notes, production formulas, consumption reports, and delivery records will take more time and increase the risk of discrepancies.

Businesses also need to assess suppliers based on their ability to provide evidence, not only on price and delivery time. For fibers, fabrics, dyes, and accessories, technical documentation should be reviewed from the selection stage. A supplier may make an attractive environmental claim without having a sufficiently robust substantiation system. In that case, the ultimate risk may still be transferred to the garment business or the brand named on the product.

Employee training is another area that is often underestimated. Purchasing staff need to understand terminology related to composition and certification; technical teams need to know what data must be maintained when materials change; production teams need to control differences between batches; and sales teams must avoid making unverified environmental claims. Small discrepancies in data can become major problems when records are checked at multiple levels.

Businesses Should Not Chase Green Claims Without Evidence

Pressure to meet environmental requirements may cause businesses to quickly use phrases such as “green,” “sustainable,” “environmentally friendly,” or “circular.” However, these terms do not replace specific data. A credible claim needs to clearly identify its scope, assessment criteria, applicable products, measurement period, and supporting documentation.

For example, the recycled-fiber percentage needs to be linked to the type of fiber, the weight on which the percentage is calculated, and the verification method. If a business says that a product is recyclable, it needs to clarify which treatment infrastructure that ability depends on and whether the product’s components must be separated before processing. Precise wording may be less prominent than general advertising, but it helps reduce the risk of being viewed as misleading.

This is also why businesses should coordinate early with brands, testing organizations, and technical experts. These organizations can help interpret requirements, but responsibility for the accuracy of the data must still be clearly allocated. No single certification automatically proves the entire life cycle of a textile product.

Impacts on Costs and Production Models

Moving toward data management and circular design may increase initial costs. Businesses may need to invest in information-management systems, testing, training, supplier controls, and design improvements. These costs are particularly significant for small and medium-sized enterprises, which often depend on the data systems of larger customers or suppliers.

However, viewing this solely as a compliance cost would overlook part of the opportunity. Accurate material data helps businesses reduce the time needed to locate records, respond more quickly to complaints, and better control quality fluctuations. Designs that use fewer material types can support inventory management and reduce production complexity. More durable products may also suit segments that require high quality, although this does not mean that every sustainable product will sell at a higher price.

The ability to absorb these costs will depend on commercial relationships. If a business only performs contract manufacturing at a low profit margin, most of the new requirements may be passed down to the factory without a clear cost-sharing mechanism. If a business participates more deeply in product development, it has an opportunity to negotiate based on design, data, and supply-chain management capabilities rather than competing solely on labor costs.

For factories currently serving the European market, it is essential to monitor the EU’s specific implementing instruments. The new ESPR framework provides the basis for developing requirements for individual product groups; the application timeline, data scope, and assessment methods will need to be defined in related regulations. Therefore, businesses should not establish a fixed set of criteria and treat it as the final legal requirement.

The Biggest Challenge Lies in Supply-Chain Coordination

A garment product is rarely made in a single facility. Fibers may be produced in one country, woven and dyed in another, and then cut, sewn, finished, and exported from Vietnam. Each stage retains part of the data. If this data is not consistent in terms of product codes, units of measurement, and recording dates, the business at the end of the chain will struggle to create a complete file.

Therefore, meeting ecodesign requirements cannot be assigned solely to the social-responsibility or export department. It is an issue involving design decisions, purchasing, production, quality, information technology, and legal affairs. Management needs to clearly determine which data is important for each product line, what level of verification is appropriate, and how to respond when supplier information is incomplete.

For Vietnam’s textile industry, a practical approach is to start with product groups that have stable markets and clear customer requirements. Businesses can test traceability systems on several product lines, standardize material documentation, and then expand once operating procedures have stabilized. A gradual approach helps limit the risks of scattered investment while still building the capacity needed when specific regulations are issued.

The ESPR cannot immediately answer every business question about each type of shirt, pair of trousers, or fabric. However, the regulation shows the direction of the European market: exported products will be assessed not only on price, manufacturing quality, and delivery time, but also on how they are designed, substantiated, and managed throughout their life cycle. For textile businesses, preparing data today is a way to reduce dependence on reactive measures when new requirements become conditions of an order.