The European Commission is moving from “strategy” to “delivery” on sustainable products. With the Ecodesign for Sustainable Products Regulation (ESPR) now in force (since 18 July 2024), the Commission has published its implementation roadmap through the first ESPR & Energy Labelling Working Plan (2025–2030), and textiles (with a focus on apparel) are among the first priority product groups. For the fashion and textiles ecosystem, this is a clear signal: circularity requirements will increasingly become a condition for doing business in the EU single market, not a voluntary add-on.
What is the ESPR in plain terms?
The ESPR is a framework law that allows the EU to set product-specific “ecodesign requirements”, rules that can make products more durable, repairable, reusable, recyclable, and resource-efficient, and improve sustainability information available across the value chain. It goes beyond the older Ecodesign Directive by covering almost all physical products (with limited exemptions) and enabling a broader set of circularity and footprint-related requirements.
What did the Commission publish in its roadmap?
Through the 2025–2030 working plan, the Commission set out the first wave of priority products where it will consider EU-level ecodesign (and in some cases energy labelling) requirements over the coming years. Priority products include:
- Textiles (focus on apparel)
- Furniture
- Steel and aluminium
- Tyres
- Mattresses
- Plus several energy-related products
The plan also flags horizontal measures, notably work to promote repairability, including a repairability score.
The big changes fashion SMEs should be ready for
1) Ecodesign requirements will become more concrete (and enforceable)
ESPR enables requirements that can affect how products are designed and placed on the market, covering areas like durability, reparability, recycled content, recyclability, and sustainability information. What SMEs can do now:
- Map where your products may be exposed: materials, trims, blends, finishes, and repairability constraints.
- Start building “design evidence”: durability choices, repair options, recycled content, and end-of-life considerations.
- Talk to suppliers early about material composition data and traceability.
2) The Digital Product Passport (DPP) will change data expectations
The ESPR introduces a Digital Product Passport, a “digital identity card” for products, components and materials, intended to store sustainability and compliance information accessible electronically for consumers, businesses and authorities (including customs checks for imports).
The Commission indicates DPP information can include, for example: technical performance, materials and origins, repair activities, recycling capabilities, and lifecycle environmental impacts (depending on product rules). What SMEs can do now:
- Treat product data as a capability (not admin): decide who owns it internally (design, compliance, sourcing).
- Begin consolidating product composition and supplier declarations in a structured, reusable format.
- If you’re already working on DPP-like data for other requirements (e.g., customer transparency, internal traceability), align it so it can be reused.
3) New EU action on destroying unsold textiles and footwear
For the first time at EU level, the ESPR introduces measures to address destruction of unsold products, including a ban on the destruction of unsold textiles and footwear, and disclosure obligations for certain companies on discarded unsold consumer products. What SMEs can do now:
- Review your end-of-season and returns strategy (resale, repair, donation, recycling partnerships).
- Track volumes of unsold stock and reasons, this is increasingly a compliance and reputational issue.
4) Public procurement can become a market-maker
ESPR enables mandatory Green Public Procurement requirements for certain products, steering public spending toward higher sustainability performance and boosting demand for better products. What SMEs can do now:
If you supply public buyers (uniforms, workwear, textiles for public services), prepare for procurement criteria that reward verifiable circular performance.
Bottom line for the fashion & textiles ecosystem
Textiles are in the first wave. For SMEs, the smart move is to prepare early: build product-data discipline, design with durability/repair in mind, and set up pathways for unsold stock management. For policymakers, this is the moment to turn “circular ambition” into practical implementation support, so compliance becomes a competitiveness lever, especially for Europe’s SME fashion sector.
