The EU’s Sustainable Products Regulation Reopens the Green Challenge for Vietnam’s Textile Industry

Vietnam’s textile and garment industry is facing a change that concerns not only technical product standards, but also how businesses collect, manage and substantiate data throughout the entire lifecycle of goods. The European Union’s Ecodesign for Sustainable Products Regulation, commonly known as the ESPR, has created a new legal framework for incorporating durability, repairability, resource use, recycled content and recyclability into the product design process.

For textiles and garments, the impact of this regulation does not yet lie entirely in a single set of criteria that applies immediately to every product. The ESPR requires the EU to continue developing specific regulations for individual product groups. However, the main direction is clear: businesses seeking to maintain access to the European market will need to prepare more effectively in terms of traceability, raw-material data, environmental information and evidence supporting sustainability claims.

This represents an important shift for Vietnamese manufacturers. In the past, competitiveness was generally assessed primarily through price, sewing quality, delivery times and the ability to fulfill orders. In the new phase, the ability to record data and coordinate with customers and material suppliers may also become a condition for retaining orders.

ESPR puts the product lifecycle at the center of textile policy

The EU’s ESPR was enacted in 2024, replacing the previous ecodesign legal framework, which focused primarily on energy-using products. The new scope is broader, covering most groups of physical products and allowing the EU to establish sustainability requirements for individual industries through subsequent implementing legislation.

A notable point is that the regulation does not look only at the production stage. A product may be assessed across multiple dimensions: durability, reusability, repairability, upgradability, recyclability, resource and energy consumption, recycled-material content, the amount of waste generated, or the presence of substances of concern. This approach means that reducing environmental impacts is no longer solely an activity for the garment factory, but begins with design and material selection.

For the textile and garment industry, this could change how businesses receive requirements from brands. A new product design will no longer be discussed only in terms of color, fabric consumption and sewing standards. The parties will also need to consider the type of fiber, blend ratios, dyes, trims, the ability to separate components and options for treatment after the product reaches the end of its life.

Digital Product Passports will increase data requirements

An important tool under the ESPR is the Digital Product Passport. Essentially, this is a digital information system linked to a product that allows relevant parties to access data on its characteristics, origin, repairability, treatment or recyclability, depending on the specific requirements for each product group.

For textile and garment products, the Digital Product Passport could require data currently scattered across multiple businesses to be connected. Garment factories need information from yarn and fabric suppliers; suppliers, in turn, need data on fibers, chemicals or sources of incoming materials. Conversely, retailers, recyclers and consumers may each need different portions of that information.

The Digital Product Passport should not be understood as a simple QR code attached to a product label. The identification code is only the visible part. Behind it are requirements concerning structured data, the ability to update information, access rights and the reliability of the data. If a business does not have an adequate data-management system, compliance may become costly even when its production processes have already obtained certain environmental certifications.

Direct impacts on Vietnamese textile and garment businesses

Vietnam is an important manufacturing link in the global apparel supply chain, but many businesses still operate under contract-manufacturing models with limited decision-making authority over design and materials. When sustainability requirements are converted into mandatory supply-chain data, the gap between CMT and FOB businesses and models capable of participating more deeply in product development may become more apparent.

For businesses receiving orders from European brands, immediate requirements may come through contracts, supplier standards or customer assessment systems before a specific regulation for textiles and garments is fully applied. Businesses should therefore not wait until the EU issues final forms before beginning preparations.

Preparation does not necessarily mean immediately investing in a complex technology system. An initial step could be to map the data: where materials come from, who supplies them, according to which criteria they are tested, which department stores the data and who is responsible for validating it. Information related to material consumption, fiber composition, chemicals, energy, water, waste and the handling of defective products should also be standardized in terms of how it is recorded.

Traceability will no longer be paperwork for compliance purposes alone

In many factories, traceability already exists to support quality control, social audits or customer requirements. However, data serving the ESPR may need to be more detailed and connected across multiple stages. An individual certificate cannot replace all product information if a business cannot prove that the data is linked to the correct batch, materials and production process.

This issue is particularly complicated for products blending multiple types of fibers, using different trims or changing suppliers during the same season. If composition ratios are not consistently controlled, the information in the product file may not match the actual goods. In that case, the risk is not limited to being asked to provide additional documents; it may also affect the supplier’s reputation within the purchasing system.

Businesses also need to be cautious with claims such as “green,” “environmentally friendly,” “sustainable” or “recycled.” These terms only have value when accompanied by an appropriate scope, measurement method and supporting evidence. Using general claims without identifying which aspect of the product has been improved may increase the risk of being asked by customers or regulators to provide an explanation.

Materials and design will determine the ability to comply

In the textile and garment value chain, sewing is often the stage where the final product is created, but it is not the stage that determines the product’s entire environmental impact. The type of fiber, spinning, weaving or knitting processes, dyeing and finishing, the number of trims and the way the product is designed all affect resource use and post-consumer treatment.

Therefore, green production cannot be understood solely as installing additional energy-saving equipment or replacing light bulbs in the factory. These measures may be necessary, but they are not sufficient if the product is designed to be difficult to repair, disassemble or sort when collected. For Vietnamese businesses, early participation in product development could help them move from merely executing requirements to being able to propose solutions.

Designing for durability is an important direction. More durable products can reduce the need for frequent replacement, but businesses need to assess durability using specific criteria rather than relying only on promotional messages. Similarly, increasing recycled-fiber content needs to be considered together with quality, color fastness, stability and the product’s subsequent recyclability.

Blending multiple types of fibers is also a technical challenge. Blended fabrics may provide suitable performance characteristics, but they are generally more difficult to separate after consumer use than materials with a single composition. There is no single material choice suitable for every product; what matters is that businesses assess the entire lifecycle and can explain the reason for their choice.

The major challenge lies with lower-tier suppliers

Export garment factories generally do not control the entire materials supply chain themselves. Fabric, thread, buttons, zippers, labels, packaging and chemicals may come from many different suppliers. If one link cannot provide reliable data, the business at the final stage will find it difficult to complete the documentation for its customer.

This creates pressure to upgrade supplier relationships. Instead of evaluating suppliers solely on price and delivery time, businesses may have to add criteria concerning data capabilities, chemical-management systems, recycled-material ratios, energy consumption and the ability to meet independent verification requirements.

Small businesses may face greater difficulties because the costs of testing, software and dedicated personnel are often high relative to their scale of operations. One suitable approach is to standardize a minimum data set by product group, use shared internal procedures and coordinate with associations, customers or solution providers to reduce implementation costs.

From regulatory compliance to changes in business models

The ESPR may create additional costs in the short term, but it also opens opportunities for businesses capable of supplying reliable products and data. As brands have to provide more evidence of environmental impacts, they will tend to seek suppliers with stable records, transparent processes and the ability to improve continuously.

Vietnamese businesses can take advantage of this trend by developing capabilities at three levels. The first is compliance: ensuring that product, chemical, origin and production-process data are accurate. The second is efficiency: reducing energy, water and material consumption, as well as the defective-product rate. The third is innovation: participating in design, developing materials, testing products with longer lifecycles and building services related to repair, collection or reuse.

These steps could help businesses reduce their dependence on cost advantages alone. However, green investment only creates business value when it is connected to actual market demand. A new production line without measurement data, without improving quality or without customer acceptance will struggle to create a sustainable advantage.

International organizations such as the OECD and the International Labour Organization often approach sustainability in the garment industry from a whole-supply-chain perspective, in which the environment, working conditions, corporate responsibility and traceability are interconnected. For Vietnam, this means that emissions-reduction programs should not be separated from supplier management, chemical safety, working conditions and workforce training capabilities.

What should businesses monitor during the transition?

First, businesses need to monitor the EU’s implementing legislation for each product group and the specific data-related requirements. The ESPR is a legal framework, while the content applied to each product group will determine what information businesses must provide, in what format and at what level of detail.

Second, businesses need to distinguish between legal requirements and the individual requirements of each brand. A customer may request data exceeding the legal minimum in pursuit of emissions reductions or a brand strategy. Businesses should build systems capable of meeting multiple levels of requirements instead of handling each questionnaire separately.

Third, businesses need to invest in personnel capable of connecting production, quality, purchasing, environmental management and information technology. Sustainability data cannot be generated solely by the environmental department if the purchasing department cannot control material sources or if the production department does not accurately record consumption.

Finally, businesses should start with product lines serving European customers or facing high traceability requirements. Testing the approach on several product groups can help identify data gaps, actual costs and coordination bottlenecks with suppliers before expanding it across the entire product portfolio.

For Vietnam’s textile and garment industry, green production is therefore no longer a matter solely of meeting a communications campaign or a periodic audit. As the market shifts toward requiring evidence of product lifecycles, data will become part of product quality. Businesses that prepare early in design, materials, traceability and information management will have more options for retaining customers, moving up the supply chain and adapting to trade regulations that are increasingly closely linked to environmental objectives.