The EU’s Sustainable Products Regulation Will Change How Vietnam’s Textile Industry Exports

Vietnam’s textile and apparel industry is preparing for a change that goes beyond tariffs or rules of origin. In the European Union (EU) market, product criteria are increasingly expanding to cover durability, repairability, recycled content, supply chain information, and how products are handled after reaching the end of their life cycle.

At the center of this change is the Ecodesign for Sustainable Products Regulation, commonly known as the ESPR. The EU regulation does not apply only to one specific product category. Instead, it creates a legal framework that enables European authorities to establish sustainability requirements for a wide range of products. Textiles are among the sectors identified as having an important role in the transition to a circular economy.

For Vietnamese businesses, the impact of the ESPR will not appear overnight. However, requirements concerning material data, product design, and proof of compliance may force companies to change how they manage orders, work with suppliers, and store records. As a result, export competitiveness will no longer depend solely on processing costs or delivery capacity.

ESPR brings sustainability into the design stage

The EU’s ESPR was adopted under Regulation 2024/1781 and entered into force in July 2024. Unlike an approach that controls products only after they have been placed on the market, this regulation focuses on the design stage. This is when most decisions are made regarding the amount of materials used, product lifespan, repairability, disassembly, reuse, and recyclability.

The ESPR provides the legal basis for the EU to establish specific requirements for individual product groups through subsequent implementing measures. Therefore, not every requirement for all goods has been detailed at the same time. Businesses need to distinguish between obligations that are already in force, requirements under development, and policy directions, rather than treating every EU objective as an immediately mandatory standard.

Textiles are among the priority sectors

In its ecodesign policy plan, the EU identifies textiles and footwear as product groups that need to be examined because they use large amounts of materials, generate waste, and have significant impacts throughout their life cycles. This does not mean that all textile companies will be subject to the same set of criteria at the same time. The extent of the impact will also depend on the product type, the company’s role in the supply chain, and the sector-specific regulations introduced later.

One notable point is that compliance responsibilities may involve multiple parties. Importers and brands in the EU are generally the parties directly responsible under European law, but they will need to request more complete data and evidence from suppliers outside the EU. Vietnamese apparel companies may therefore not be the primary legal subjects of every obligation, but they will still be clearly affected by customer requirements.

The Digital Product Passport creates new demand for data

One of the ESPR’s important tools is the Digital Product Passport. This is an electronic information system linked to a product that allows relevant parties to access data about its characteristics, materials, repairability, impacts, or other sustainability information, depending on the product group and specific requirements.

A product passport is not simply a QR code printed on a label. For information to have value, businesses must establish processes for collecting, checking, updating, and sharing data. For a textile product, the data may concern fiber composition, the source of materials, processing stages, certifications, chemicals used, or instructions for handling the product after use. The final scope of the data will depend on the regulations applicable to each product group.

From order records to end-to-end data management

Many businesses are already familiar with storing export documents, technical specification sheets, test results, and raw-material and accessory records for each order. However, sustainable product transparency requirements may demand that data be linked across the entire chain rather than existing as separate files.

For example, information about a shirt does not only reside at the garment factory. Data may begin with the type of fiber, continue through the spinning, weaving, or dyeing facility, and then cover cutting and sewing, finishing, and packaging. If each stage uses a different recording method, it will be difficult for the business to prove consistency when a customer requests an audit.

This is a management change no less significant than a technological change. Businesses need to identify what data they already have, what data is held by suppliers, what data requires independent verification, and who is responsible for approving information before it is transmitted to customers. A digitized system does not automatically produce reliable data if the input process lacks controls.

What Vietnamese textile businesses need to prepare

The impact of the new regulations will vary between businesses producing basic goods, companies manufacturing technical products, and businesses that own brands. Nevertheless, some workstreams can be started early without waiting for all EU criteria to be finalized.

Inventory materials and suppliers

First, businesses need to map materials for each product group. They should not record only the commercial name of the yarn or fabric, but also identify its composition, source, blend ratio, and relevant documentation. For recycled materials, records should show the source of the input materials and the method used to verify their content when required by customers or regulations.

The inventory should also cover chemicals, accessories, packaging, and finishing processes. Not all information must be disclosed to consumers, but businesses need to know what data may be requested during a supply chain assessment. Traceability is often weakest among smaller suppliers or at outsourced stages.

Standardize product records

Each product code should have a consistent file containing technical specifications, material composition, change history, suppliers, test results, and the certifications used. This file needs to be updated whenever the yarn, dyes, finishing process, or manufacturing facility changes.

Standardized records help reduce a common risk: inconsistencies between information on labels, sales materials, technical files, and data submitted to customers. When environmental requirements become part of the purchasing process, data discrepancies may require the business to provide explanations, conduct another review, or adjust the product.

Assess design instead of checking only finished products

Finished-product testing remains necessary, but it is not enough to meet the thinking behind the circular economy. Product development teams need to consider from the outset how to reduce the number of different materials, limit structures that are difficult to disassemble, select suitable accessories, and extend the product’s useful life.

For some products, using multiple types of fibers or accessories may increase the complexity of sorting and recycling. However, there is no universal solution for every item. Businesses must balance durability, functionality, aesthetic requirements, cost, chemical safety, and post-use processing. This is a technical issue that must be assessed for each product and should not be addressed through broad environmental claims.

Compliance costs will increase, but opportunities will also expand

In the short term, meeting the new requirements may increase the costs of data management, testing, supplier assessment, and software investment. Businesses with weak traceability systems will need to devote additional resources to digitizing records and training personnel. Contract manufacturers that rely heavily on customer-designated materials may also face difficulties if they are not given sufficient information from upstream links in the chain.

However, these costs are not merely additional expenses incurred to get through an export procedure. If organized effectively, product data can help businesses reduce inconsistencies between departments, control material changes, respond more quickly when customers request documentation, and identify weaknesses in the supply chain.

Greater transparency may also help businesses move from competing purely on price to competing on capabilities. Buyers need partners that can provide reliable data, maintain consistent quality, and coordinate when product criteria change. This is an advantage that businesses investing in quality management and traceability can leverage.

Small businesses need a suitable roadmap

Not every business can immediately deploy a complex data platform. For small and medium-sized enterprises, a practical approach is to start with several key export product lines, identify important suppliers, and build a minimum set of verifiable data.

Businesses also need to clarify requirements with EU customers in writing. Distinguishing between data required by law, data required under a brand’s own standards, and data used for marketing purposes will help prevent scattered investment. If each customer uses a different form, associations and businesses in the supply chain can coordinate to standardize terminology, units of measurement, and storage methods to an appropriate extent.

From EU requirements to long-term competitiveness

The ESPR is not the only regulation shaping the European textile market. Businesses must also monitor requirements related to chemicals, extended producer responsibility, environmental claims, waste management, and rules for imported products. These policies may affect different stages, but they all increase the value of verifiable data.

For Vietnam, a major challenge is the fragmentation of the supply chain. A garment product may use materials from multiple countries and pass through many stages before being exported. If a business controls the garment factory well but does not have information about the yarn, fabric, dyes, or accessories, its ability to meet the final requirements will remain limited.

Therefore, preparing for the EU market should not be viewed as the sole responsibility of the import-export department. Purchasing, technical, product development, quality, information technology, and sales teams all have a role to play. Management needs to clearly recognize product data as an operational asset, not merely paperwork to be completed when a customer requests it.

The specific criteria for each product group will continue to be developed and updated by the EU. Businesses cannot know every requirement in advance, but they can prepare a foundation by inventorying materials, standardizing records, assessing designs, and establishing data verification processes. As brands face increasing pressure to substantiate sustainability claims, suppliers with clear and consistent information will be better positioned in order negotiations.

For Vietnam’s textile industry, the green transition is therefore not only about replacing machinery or using more recycled materials. It is also about changing how products are designed, recorded, controlled, and accounted for throughout their life cycles. Businesses that begin preparing their data and traceability capabilities early will reduce the risk of being caught off guard when market requirements shift from policy direction into specific commercial conditions.