EU Sustainable Design Regulations Pose New Challenges for Vietnam’s Textile and Garment Industry

Vietnam’s textile and garment industry is facing an important change in the way it approaches the European market. Whereas importers previously focused mainly on price, quality, delivery times and safety standards, attention is gradually expanding to the product’s entire life cycle. What materials are used, whether the product is durable, whether it can be repaired or recycled, and whether supply chain data is reliable—these questions are increasingly affecting market access.

The main driver of this change 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. This European Union legal framework was adopted on June 13, 2024. The regulation does not target textiles alone, but textiles are among the sectors receiving significant attention because their production processes use substantial amounts of raw materials, water, energy and chemicals.

ESPR does not mean that every garment product must immediately meet an identical set of criteria. The regulation establishes a basis for the EU to introduce specific requirements for individual product groups. For Vietnamese businesses, an important point is that the impact may emerge before a mandatory requirement is directly applied: European brands, buyers and distributors may need more detailed data from suppliers to prepare for new regulations.

ESPR changes how a textile product is assessed

Unlike traditional inspections, which often focus on the finished product, the sustainable design approach examines multiple stages in a product’s life cycle. Potential product requirements may cover durability, repairability, upgradability, the proportion of recycled materials, recyclability, energy or resource consumption, and the presence of substances of concern.

For textiles, this approach could change the entire sample development process. A product must have more than suitable colors, designs and pricing. Businesses may also need to demonstrate the origin of the fibers, material composition, processing methods, colorfastness, mechanical durability and other information related to long-term use. Depending on the specific requirements issued by the EU for each product group, this data may need to be provided in a standardized format and linked to each product or batch.

The important point is that responsibility does not rest solely with the retail brand. Manufacturers, fabric suppliers, spinning companies, dyeing businesses and suppliers of accessories and other inputs may all need to participate in creating the data. An export garment manufacturer may not sell products directly under its own brand, but it may still have to provide information to customers when requested within the supply chain.

Product data is becoming part of competitiveness

ESPR is also connected with the concept of a Digital Product Passport, in which product-related information can be stored and shared electronically. Specific implementation details depend on product-group regulations and relevant technical standards. However, the overall direction shows that data is no longer an administrative task separate from production.

For textile and garment businesses, data needs to be connected across multiple departments: raw-material purchasing, chemical management, production, quality control, logistics and sales. If information about fiber composition remains only in the purchasing department’s records, chemical data is held by the dyeing factory, and batch information is managed separately by the export department, compiling the product file will take considerable time and may easily lead to discrepancies.

This is an assessment of operational impacts, not a requirement that every business use the same software. The core issue is the ability to trace and verify data. An expensive system without a validation process will not resolve the risks; conversely, businesses can begin by standardizing material codes, batch codes, supplier forms and record-keeping rules before investing more deeply in technology.

Materials and design will be considered from the outset

For many years, discussions about sustainable textiles have often focused on replacing virgin fibers with recycled fibers or using materials of natural origin. However, changing the material composition alone is not enough to address all sustainability requirements. A product with a high proportion of recycled materials that wears out quickly, is difficult to repair or cannot have its components separated at the end of its life may still face limitations if policy criteria shift toward comprehensive assessments.

Businesses therefore need to consider the relationship between design, materials and production processes. Blending several types of fibers can create good performance characteristics, but it can also complicate recycling. Decorative details, coatings, adhesives, metal accessories and multilayer structures may affect the ability to sort or process a product after use. These factors were previously determined mainly by technical and aesthetic requirements; in the new context, they may become issues that need to be assessed at the product development stage.

Durability is also an important aspect. If clothing is used for longer, replacement needs may decline and the amount of waste generated over a given period may be lower. To demonstrate durability, businesses must rely on appropriate testing methods and quality-control records rather than using only broad marketing claims.

“Green materials” should not be equated with a single label

On the market, terms such as “green,” “environmentally friendly” or “sustainable” are easily used in many different ways. For exporters, the risk lies not only in selecting materials but also in how products are described. An environmental claim needs a basis, a clearly defined scope and the ability to be verified.

For example, using recycled fibers does not automatically prove that a product has a lower environmental impact in every respect. The outcome also depends on the source of the materials, recycling technology, transport distances, dyeing processes, energy consumption and the length of time the product is used. A cautious approach is therefore to accurately describe verified characteristics rather than expanding them into a broader claim than the evidence can support.

Immediate impacts lie in the supply chain and buyer requirements

The EU is an important export market for Vietnam’s textile and garment industry. According to trade reports from Vietnam Customs and industry reports from the Vietnam Textile and Apparel Association, Vietnam’s textile and garment exports depend significantly on major markets such as the United States, the EU, Japan and several others. In this context, any change in European buyer requirements can spread to suppliers outside the EU through contracts, factory standards and supplier evaluation processes.

A business with strong production capabilities but insufficient raw-material data may still face difficulties when customers request verification. Conversely, a medium-sized supplier that maintains good records, codes its processes and demonstrates product consistency may gain an advantage in orders requiring a higher level of transparency.

This may increase compliance costs in the short term. Businesses must allocate resources to training, testing, certification, supplier audits and the digitization of records. Some investments do not generate immediate revenue, but they may help reduce the risk of being removed from supplier lists when purchasing criteria change.

However, not all sustainability-related costs should be viewed as purely legal expenses. Standardizing data on materials and accessories can help businesses reduce errors in production planning. Strict chemical management can limit quality and safety risks. Product designs that are easier to repair or use fewer mixed materials may support material savings in some cases. Actual efficiency depends on the production model, technology and requirements of each customer.

What roadmap should Vietnamese businesses prepare?

ESPR is an EU-level legal framework, while specific requirements for each product group need to be developed and implemented through subsequent steps by European authorities. Businesses should therefore not assume that all obligations already apply simultaneously to every textile product. A more appropriate preparation strategy is to build foundational capabilities that can be used for multiple requirements.

First, businesses should map the supply chains for products exported to the EU. This map should identify suppliers of fibers, fabrics, dyes and accessories, as well as the relevant processing stages. For each material group, businesses need to know what information is currently available, what information is provided only in the form of claims, and what information cannot yet be verified.

The next step is to establish minimum data requirements for each product. Fiber composition, color codes, batch codes, sources, test results, chemical information and quality records should be linked through a clear coding system. Businesses do not necessarily need to digitize everything at once, but they should avoid a situation in which each department records information differently.

Third, product development teams need to become involved earlier in circularity objectives. Decisions about fiber types, fabric structures, accessories and finishing methods should be assessed alongside requirements for quality, cost and delivery time. If sustainability is checked only after a sample has been completed, the ability to make adjustments will be limited and the cost of changes may be higher.

Finally, businesses need to monitor documents directly from the European Commission, customs authorities, industry associations and customers. Specific requirements may differ by product and by implementation date. Relying on unclear commercial summaries or online marketing claims may lead to preparation in the wrong direction.

Opportunities are not limited to large businesses

The new regulation may create greater pressure for small and medium-sized businesses because they often lack dedicated personnel for environmental matters, data and compliance. Nevertheless, transparency requirements also create opportunities for businesses with specialized capabilities. Fabric suppliers with clear material records, garment factories with strong quality controls, and companies providing repair and recycling services may participate more deeply in the value chain.

For these opportunities to produce practical results, coordination is needed among businesses, associations, regulatory authorities, testing organizations and training institutions. Issues such as testing methods, data standards, information sharing between different supplier tiers and the cost of demonstrating conformity cannot be resolved effectively if each business has to handle them independently.

For Vietnam’s textile and garment industry, the greatest challenge may not lie in a single criterion, but in shifting from a mindset of “fulfilling orders” to managing the product’s entire life cycle. As environmental requirements become integrated into design, purchasing, production and sales, competitiveness will depend more heavily on data quality and the ability to coordinate across the supply chain.

ESPR is not the entirety of the EU’s sustainable textile policy, nor is it possible to accurately predict the impact of every requirement while specific product regulations have not yet been fully applied. But the legal direction is relatively clear: products placed on the European market will increasingly need to be accompanied by reliable information about how they were produced, their composition, durability and options for handling them after use. Businesses that prepare early with verifiable data, appropriate designs and transparent supply chains will be in a more proactive position when new requirements become conditions for doing business.