The EU's Ecodesign for Sustainable Products Regulation (ESPR) is about to set the first concrete rules for textiles in the bloc. As the EU’s flagship framework for “making sustainable products the norm” and reducing carbon and environmental footprints throughout their life cycles, it has the potential to accelerate the transition to a circular economycircular economyA systems solution framework that tackles global challenges like climate change, biodiversity loss, waste, and pollution. It is based on three principles, driven by design: eliminate waste and pollution, circulate products and materials (at their highest value), and regenerate nature. in Europe.
By establishing mandatory performance criteria at an EU level, the ESPR can embed circular economy principles directly into product design and market access conditions, delivering a robust legislative framework for the EU's environmental objectives and a more competitive, resilient economy.
The ESPR and the circular economy
The ESPR is the EU's main mechanism for setting product requirements, applied at a category level through Delegated Acts. Once a Delegated Act is adopted, products in that category must meet certain obligations in order to be sold in the EU. Textiles are among the first sectors in scope.
The intent of the ESPR is to make sustainable products the norm and support a well-functioning EU Single Market. In the textile sector, this means tackling the most consequential environmental challenges, including significant carbon emissions, high water consumption, and considerable chemical pollution throughout the value chain. To address the impacts, the science and knowledge service of the European Commission – the Joint Research Centre (JRC) – has proposed four ecodesign criteria: robustness, recyclabilityrecyclabilityThe ease with which a material can be recycled in practice and at scale., recycled content and environmental footprint. Yet, the current proposal focuses on transparency, missing the need for regulation to establish mandatory performance criteria that embed circular economy principles directly into product design and market access conditions.
Information can foster change; performance requirements drive it at scale
The decisions being made now are particularly consequential. They will determine whether the ESPR will deliver circular product design at scale, and drive market transformation and resilience.
Experience from other sectors shows that information measures shift markets in the right direction, but performance requirements determine what is in the market at all. Without binding thresholds, businesses that have already invested in circular design compete against products held to no equivalent standard, with no mechanism to reward what they've built or deter what they haven't.
The implementation of a large-scale circular economy in the textile sector represents thousands of potential jobs in collection, sorting, repair, refurbishment and resale activities. These opportunities are real but will only materialise if circular activities move beyond pilot projects to reach a significant scale. An ambitious ESPR will contribute to this scale.
What the ESPR must deliver:
This white paper sets out a series of recommendations aiming at strengthening the Delegated Act. To prevent the least durable products from reaching the market, create a level playing field, and give businesses the regulatory certainty to invest in circular design, the Delegated Act should:
Convert robustness from an information requirement to a mandatory performance requirement with binding market access thresholds
Strengthen the recyclability criterion, including lowering the elastane threshold
Prioritise post-consumer fibre-to-fibre recycled content, with targets rising over time
Move toward a mandatory product-level repairability requirement in a future revision of the Delegated Act
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From information to market transformation: Why the ESPR must mandate performance requirements for textiles
