Textiles Move to the Front of the ESPR Queue
The European Commission has confirmed textiles and apparel as the second priority product category under the ESPR framework, following batteries. The public consultation for the textiles delegated act has opened, inviting feedback from manufacturers, importers, retailers, industry associations, and civil society organisations over an eight-week period.
The draft delegated act proposes data requirements across several categories that textile companies should start preparing for now — even before the final text is adopted.
Expected Data Requirements
Based on the consultation document and European Commission preparatory studies, the textile DPP is expected to require:
- Material composition — Full fibre breakdown by percentage (e.g., 70% organic cotton, 25% recycled polyester, 5% elastane), including recycled content share
- Manufacturing traceability — Country and facility for each production stage: spinning, weaving/knitting, dyeing/finishing, cutting, and assembly
- Environmental footprint — Carbon emissions per garment, water consumption, energy usage, and chemical treatments applied during production
- Durability — Wash cycle endurance, pilling resistance, colour fastness, and dimensional stability test results
- Repairability and recyclability — Repair service availability, disassembly instructions, mono-material percentage, and recycling guidance for end-of-life processing
- Chemical compliance — REACH restricted substance declarations, OEKO-TEX or equivalent certifications, and SVHC disclosures
Why Start Now
Textile supply chains are among the most complex in global manufacturing, often spanning 4-6 tiers across multiple countries. The data collection effort alone — mapping fibre origins, gathering environmental data from dyeing facilities, obtaining chemical compliance certificates from Tier 3 suppliers — typically takes 6-12 months for complex fashion supply chains. Waiting for the final delegated act adoption before starting this work means missing the compliance deadline.
Estimated Timeline
- 2025 — Public consultation (current phase)
- Late 2027 — Delegated act expected to be adopted
- ~2028-2029 — Mandatory compliance date (18 months after adoption)