Where do we stand with the preparatory study for the ESPR delegated act on textiles? The plenary consultation on the preparatory study’s 3rd milestone, held with the JRC in mid-January 2026, served to retrace and discuss the technical steps that led from the scientific evidence base to the first formulations of ecodesign requirements (discussed in detail here), helping to distinguish elements that are already relatively mature from those that remain more sensitive. Work on both fronts remains open to written stakeholder contributions (to be submitted by 30 March) and to the subsequent phases of the preparatory study, from the impact assessment to the analysis of policy scenarios and the use of the Digital Product Passport (DPP). Below is what emerged at the intersection of ambition and feasibility – between calls for stricter requirements and the constraints of cost, verifiability, and potential trade-offs.
ESPR: operational boundaries and the new labelling architecture
To begin with, the consultation was framed around textile apparel. Technical textiles and home/interior textiles remain out of scope due to differences in intended use and material composition. Footwear is also excluded – a point that has already prompted criticism – because the first ESPR Working Plan does not place it within the immediate regulatory cycle. Instead, it defers prioritisation to the 2028 mid-term review, preceded by a dedicated scoping study. The JRC also justified this separation on technical grounds: many footwear products are only partly “textile”, with mass and performance largely driven by the sole, implying test methods and criteria that would differ from those for apparel.
On the information side, the reference architecture is the Digital Product Passport, intended to host and convey data along the value chain with traceability and verifiability functions. How the DPP will become operational for apparel is scheduled for the next phase (4th milestone) and was therefore not examined in depth during the consultation. Nonetheless, it was inevitably raised, for two reasons: first, because most of the design options discussed in the 3rd milestone take the form of information requirements, which immediately raises questions about where the data will sit, how it will be made available, and who will ensure its verifiability; second, because stakeholders are already probing the boundary between the DPP (and thus ESPR) and the Textile Labelling Regulation (TLR), which is under revision, and how the two sets of obligations might be integrated in a way that remains intelligible to consumers. Under early hypotheses aligned with a single-label approach, new ESPR-mandated digital disclosures would be added – on a compulsory basis – to those already governed by the TLR. The option of an “hang tag” (a non-permanent physical label) is also being considered, which would display only ESPR-related performance information by physically replicating part of the DPP content.
Details on content and layout/format of labelling domains governed by the TLR (the “classical” ones) including care will have specific dedicated consultations later on, once the legislative proposal is adopted – such details should be governed by TLR Delegated Act and TLR Implementing Act.
Durability or robustness?
One of the most contentious issues – illustrating the friction between regulatory ambition and the limits of measurability and verification – is durability. The JRC argued that the data and standards currently available in the literature do not allow apparel ageing to be measured in a way that would link performance to “time-in-use” durability as understood in the ESPR text. This underpins the decision to pivot towards “robustness”, defined as a garment’s ability to withstand external stresses and maintain structure and appearance in a point-in-time sense, i.e., without explicitly accounting for the temporal dimension of ageing.
The shift from durability to robustness therefore comes with two major limitations, acknowledged by the JRC itself. First, robustness cannot identify a predictable service life anchored in the garment’s intrinsic properties. Second, a known improvement in the performance level of key robustness parameters corresponds to an unknown increase in physical durability.
For this reason – JRC researchers explained – the proposal is for an information requirement rather than a performance requirement, centred on a 0–10 robustness score based on parameters such as visual inspection, spirality, and dimensional change. Stakeholders noted, however, that these parameters are more informative for shape stability than for fabric strength. Several also argued that, as an information requirement, the expected effect on such a critical objective as extending garment lifetime is shifted largely to the point of purchase: the score would need to steer consumer choice (provided it is sufficiently clear not to be misread as “durability” in the ESPR sense) and would only indirectly push manufacturers – through competition – to improve product profiles.
Along this line of argument, broader considerations were raised about context and urgency: focusing on robustness purely as information, even if driven by the current measurability constraints around durability, may leave another decisive component of real-world lifetime less directly addressed – namely “emotional durability” – and, more broadly, the dynamics of premature consumption that bring forward end-of-life even when material integrity is not yet compromised. These issues were treated as outside the technical perimeter of the preparatory study. The discussion was brought back to the fact that premature consumption and overconsumption were captured within the market analysis and hotspot assessment, but were not translated into design options because they exceed the scope of ESPR; any future treatment was therefore deferred to other policy instruments and stages. This cross-cutting question remains in the background: to what extent ecodesign – and the Regulation governing it – should or must, beyond performance and information, also seek to reshape overproduction along use and purchasing behaviours.
Recycled content and closed loop
On recycled content, the JRC incorporated comments raised at the 2nd milestone and presented a revised definition that changes both the eligible flow boundary and the underlying logic (more oriented to “availability” than to closed loop). The previous wording was: the proportion, by mass, of recycled fibres coming from recyclable textile apparel disposed as post-consumer waste. The new definition is: the proportion, by mass, of recycled fibres from post-industrial, pre- and post-consumer waste, in a textile product. In other words, post-industrial, pre- and post-consumer waste are now explicitly included and, crucially, secondary materials from sources other than fibre-to-fibre recycling are also admitted.
The JRC justified this widening primarily on feasibility grounds: while fibre-to-fibre mechanical recycling for polyester (PES) is operational at scale, the overall availability of textile-to-textile recycled material remains insufficient for widespread uptake (figures presented: around 2% in 2023). This underpins the inclusion of flows from other value chains, notably PET from bottles, which is both quantitatively and qualitatively more substantial. On the potential “conflict” with packaging, the JRC referred to its own estimates: the combined recycled-content targets in the packaging market would account for about 56% of the material available in 2030, leaving a margin for other uses.
One point emerged clearly in the consultation: the transition towards a closed-loop approach is not being scheduled at this stage. When asked why no timeline has been set to move from an “open-loop” to a “closed-loop” approach, the prudential response reported was that, for now, the immediate objective is to describe the state of the art and make a first step practicable by leveraging today’s available flows; more ambitious scenarios remain possible, but are deferred to later phases. A related point is that, once PET is recycled into apparel, it cannot be converted back into bottles due to food-contact material standards, which weighs as a lower-value application (downgrading). If the textile sector draws PET from bottles, it may displace a potentially more circular or higher-value use in packaging (with the likely next fate being incineration, or, at most, future chemical recycling), while not necessarily building the industrial base for textile-to-textile recycling. The balance is delicate: making use of available streams without locking in a model that does not ultimately deliver closed loop.
Recyclability and elastane
In the 3rd milestone, the JRC framed recyclability as an information requirement, translating it into a recyclability score (0–10) in which elastane acts as a threshold discriminator. Above 15% – or above 20% in the case of PA6-rich blends (>80%) – a product is classified as “non-recyclable” and the score is set to zero. Below the threshold, the score increases as design choices reduce downstream disruptors for sorting and recycling (for example finishes, coatings, prints, or components that complicate processing).
Some stakeholders argued for clearer performance requirements on recycling disruptors, warning that a score alone risks shifting the choice—along with the interpretation of trade-offs—onto consumers, without sending a sufficiently strong and unambiguous industrial signal. Conversely, industry representatives pointed to the mirror risk: rigid thresholds could remove functional segments from the market where elastane appears justified. For now, the JRC intends to make the effect of design choices visible through information and to defer any tightening until a more complete system-level picture is available. Unsurprisingly, the gap between “design-for-recyclability” and recycling in practice (installed capacity, collection, incentives) was explicitly deferred to the next scenario analysis (4th milestone), while maintaining that the increase assumed in preliminary models would, at present, remain within absorbable margins.
Manufacturing environmental/carbon footprint
The consultation also opened discussion on the possibility of measuring an environmental or carbon footprint limited to manufacturing and linking it to an “excellence” label. The proposal draws on PEFCR benchmarks and, to avoid distorted comparisons across fibres and datasets, excludes the raw-materials stage, citing non-homogeneous system boundaries. Distribution is likewise excluded, on the grounds that including it could introduce competitive disadvantages tied to imports and transport (and therefore potential trade frictions). Here too the approach is cautious: not a performance requirement, but an information indication – moreover voluntary – for operators wishing to demonstrate superior performance.
As some stakeholders highlighted, a voluntary scheme risks functioning more as a reputational signal than as a generalised information requirement, especially if secondary data are permitted (despite the stated intention to incentivise primary data). The JRC, by contrast, links voluntariness to cost and the still-limited diffusion of these practices, arguing that a recognition mechanism for excellence could nonetheless shift the market without immediately imposing a uniform burden on all operators.
Design options excluded from the 3rd milestone proposals
The consultation also addressed what is not, for now, translated into an ecodesign option. Particulate release from textiles is described as a life-cycle-wide phenomenon: it occurs during production (effluents and dispersions not always intercepted by control systems), during use and maintenance (friction, detergents, UV exposure, washing-machine characteristics and water hardness, as well as user behaviour), and in end-of-life management (landfilling, incineration, recycling). The stopping point in the preparatory study is methodological: the JRC reports that there is currently no sufficiently shared standardised definition of particulate matter and, crucially, no harmonised methods for sampling, characterisation, and quantification across all release points along the value chain. ISO 4484 is cited as a useful but partial reference (focused on post-wash emissions) and therefore insufficient, on its own, to robustly identify hotspots or build verifiable mitigation strategies. The reiterated conclusion is that, before proposing a regulatory requirement, the topic must be “unblocked” through standardisation (definitions, methods, and comparable measurements), including a distinction between biodegradable and non-biodegradable particulate matter.
A second strand concerns repairability. The JRC explained why it did not advance a performance requirement or scoring approach: based on its investigations, in principle any garment can be repaired, and attempts to convert repairability into an “objective” score collide with multiple hard-to-quantify factors – even if proxy indicators exist (component accessibility, ease of disassembly, availability of spare parts, or repair services). The residual option—considered but not modelled in calculations – is an information requirement: indicating in the DPP whether the brand offers repair services, with details and contacts, to make visible an infrastructure that already exists where present.
Finally, on the sustainability of fibre production, the consultation drew a similar boundary between the topic’s relevance and the current capacity to translate it into ecodesign requirements at this stage. Some stakeholders asked why, despite ESPR’s reference to sustainable raw materials, the JRC does not move towards more substantive requirements on fibres and production pathways. The response was structured around two considerations. First, there is no shared operational definition of “sustainable raw material”, and constructing one would require a systemic assessment addressing land use, competition with other sectors, coherence across EU strategies, and risks of market distortion. Second, the scale of work required is incompatible with the timeline and the ESPR perimeter: it is not only a matter of distinguishing 7–8 major fibres, but of addressing production variants, different feedstocks for man-made and synthetic fibres, and a plurality of industrial routes. The remaining feasible proposal therefore sits, again, on the voluntary information side: indicating compliance for certain fibres with criteria already codified under the EU organic regulation.
Read also: Andreas Rasche: The great contradiction of corporate sustainability in the European Union
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