Design

Last updated: 10 Jul 2026 (V2)

Designing for Circularity

Introduction

Design is influencing every aspect of a garments' lifecycle. By integrating principles of circular design, designers can transform the industry, reduce waste, extend product lifecycles, and minimise environmental impact.

For example, embracing circular design principles can encourage retailers to offer more carefully selected product ranges that prioritise quality, durability, and longevity over high product volumes. This shift not only aligns with circularity but also reduces overproduction and excess inventory, helping businesses prepare for emerging regulatory measures such as the ESPR Ban on the Destruction of Unsold Goods, discussed later in this tool. Collaborating with fabric producers and manufacturers is also essential; they can provide insights into material innovation, waste reduction, and supply chain transparency. Through such partnerships, designers gain access to sustainable materials and production techniques, facilitating the integration of circular design principles into their creations.

Additionally, engaging with consumers throughout the design process fosters a deeper understanding of their preferences and values, enabling designers to create garments that align with product sustainability strategies.

This section outlines a range of circular design strategies that can help clothing and fashion designers reduce environmental impacts, extend product lifecycles, and improve resource efficiency. The strategies covered include Design for Repair, Design for Disassembly, Design for Durability (Timeless Fashion), Reduction in the Use of Materials, Parts, and Components, Fabric Optimisation, Minimal Seam Construction, and Zero Waste Pattern Cutting.

Design for Repair

Embracing a repair mindset involves a fundamental shift in the design approach towards creating garments that are not only aesthetically pleasing but also durable and easy to maintain. Designers can incorporate various features and techniques that facilitate repair, ultimately extending the lifespan of the garment. For instance, reinforced seams and stitching techniques, such as flat-felled or French seams, can enhance the durability of the garment, reducing the likelihood of seams unravelling or tearing. Additionally, integrating replaceable components, such as buttons, zippers, and pockets, allows consumers to easily replace damaged or worn-out parts without compromising the overall integrity of the garment.

Design for Disassembly

Designing for disassembly entails careful consideration of a garment's end-of-life from the initial stages of design. By prioritising disassembly-friendly design elements, designers can facilitate the recycling and repurposing of fashion products, thus promoting circularity. This involves not only selecting materials with product life extension or recyclability in mind but also employing construction techniques that enable easy separation of components. For instance, designers can opt for materials that are easily recyclable, such as mono-material fabrics or textiles made from recycled fibres. Additionally, fasteners like snaps, hooks, and Velcro can replace permanent stitching, allowing for effortless disassembly of garments at the end of their useful life. Modular designs, where garments are composed of interchangeable modules or panels, enable users to customise and adapt their clothing to suit their evolving needs and preferences. By designing with disassembly in mind, designers contribute to the creation of a closed-loop system where materials are continuously regenerated and reused, minimising waste and environmental impact.

Design for Durability (Timeless Fashion)

Design for durability focuses on creating garments that remain functional, desirable, and suitable for use over extended periods, rather than being driven by short-term fashion trends. This approach emphasises the use of classic styles, durable materials, and high-quality construction techniques to extend product lifespans and reduce the need for frequent replacement.

Prioritising durability and longevity not only benefits consumers but also contributes to a more sustainable fashion industry. By designing garments that withstand the test of time, designers empower consumers to cherish and maintain their clothing for years to come, reducing the frequency of replacements and minimising overall resource consumption. This shift towards durable and repairable fashion aligns with the principles of circularity, where products are designed to retain their value and functionality over multiple lifecycles.

By incorporating these timeless shapes into their designs, designers create garments that retain their relevance season after season. High-quality materials further contribute to the longevity of timeless fashion, as they not only enhance the aesthetic appeal of the garment but also ensure durability and longevity. Fabrics like silk, wool, and cashmere are renowned for their luxurious feel and exceptional durability, making them ideal choices for timeless pieces.

Meticulous attention to detail is another hallmark of timeless fashion (durability), with designers focusing on fine craftsmanship and finishes that stand the test of time. From hand-stitched seams to intricate embroidery, these thoughtful details elevate the garment and imbue it with a sense of timeless elegance. By investing in timeless designs, consumers are more likely to develop a deep emotional connection with their garments, cherishing and wearing them for years to come. This reduces the need for frequent replacements and contributes to a more sustainable approach to fashion consumption, aligning with the principles of circularity and longevity.

Reduction in Use of Materials, Parts, and Components

Simplifying garment construction and minimising unnecessary materials, parts, and components are key strategies for reducing the environmental impact of fashion production. The ability of designers to influence these decisions depends on the design brief. In larger organisations, design decisions are often shaped by commercial, technical, and sourcing requirements, whereas designers in SMEs or independent brands may have greater flexibility to incorporate circular design principles. Streamlining designs involves reducing unnecessary elements and focusing on features that contribute to both functionality and product longevity.

By eliminating excessive embellishments, such as intricate beading or unnecessary trims, designers can reduce material waste and production complexity, thereby lowering the environmental footprint of the garment. Prioritising versatile pieces that offer maximum functionality with minimal resources further enhances sustainability.

Designers can create multi-functional garments that can be styled in various ways or adapted for different occasions, reducing the need for consumers to purchase multiple items. Additionally, opting for durable materials that withstand the test of time ensures longevity and minimises the need for frequent replacements.

Embracing simplicity and efficiency not only aligns with the principles of sustainability but also fosters creativity and innovation within the fashion industry. By reimagining design processes and embracing minimalist aesthetics, designers can play a pivotal role in shaping a more sustainable future for fashion.

Fabric Optimisation

Fabric optimisation in the design of clothing involves carefully planning the use of textiles to maximise efficiency and minimize waste. This process entails the careful selection of fabric types, sizes, and shapes to ensure that each piece is used as effectively as possible. Designers can utilise advanced software to simulate and plan fabric layouts before cutting, allowing them to adjust patterns and placements to reduce offcuts. This method not only conserves materials but also lowers production costs and decreases the environmental impact of fabric manufacturing e.g. reduced energy consumption and less chemical processing.

Minimal Seam Construction

Minimal seam construction is a design technique that involves reducing the number of seams in a garment to simplify its assembly and enhance comfort. This approach often results in smoother, cleaner lines that can offer both aesthetic and functional benefits. Fewer seams mean less potential for irritation against the skin, making garments more comfortable to wear, especially in activewear or intimate apparel. Additionally, reducing the number of seams can decrease labour and production time, thus streamlining the manufacturing process and reducing the overall carbon footprint associated with garment production.

Zero Waste Pattern Cutting

Zero waste pattern cutting is an approach to fashion design that aims to eliminate fabric waste during the garment cutting process. Designers arrange patterns in such a way that all pieces fit together like a jigsaw puzzle, leaving no unused fabric. This method requires a rethinking of traditional cutting techniques and often involves more complex pattern design and planning stages. The benefit of zero waste pattern cutting is reducing textile waste. Designers who adopt this practice often find that it also inspires creativity, pushing them to think outside conventional design frameworks.

Conclusion

Brands and fashion designers wield significant influence in shaping the future of the industry, and their impact extends far beyond the design studio. By prioritising environmental impact reduction at every stage of the design process, from concept development to garment production, designers can inspire positive change throughout the fashion value chain.

However, this transformation requires collaboration and commitment from all stakeholders, including fabric producers, manufacturers, brands, retailers, marketers, recyclers, and consumers. Fabric producers can innovate sustainable materials, manufacturers can adopt environmentally friendly production techniques, brands and retailers can promote sustainable fashion choices, marketers can communicate the value of sustainability to consumers, recyclers can facilitate circularity, and consumers can make conscious purchasing decisions.

Environmental Regulation and Standards

A key driver of circular design in the fashion and textiles sector is the evolving policy and regulatory landscape, particularly initiatives emerging from the European Commission. The following section provides an overview of the most relevant policies, regulations, and standards shaping circularity in the sector.

Clothing, Fashion and Textiles: Policies and Standards

EU Circular Economy Action Plan 1 & 2: The EU Circular Economy Action Plan 1 (CEAP 1), launched in 2015, set the foundation for transforming the European economy from a linear to a circular model. The plan introduced 54 targeted actions, including legislative proposals including revisions related to the Waste Framework Directive, Landfill Directive, and Packaging Waste Directive. It focused on improving product design to facilitate repair and recycling, enhancing waste management systems, and developing a functioning market for secondary raw materials. Sector-specific initiatives included the EU Strategy for Plastics in a Circular Economy, which aimed to make all plastic packaging recyclable or reusable by 2030; measures to reduce food waste by setting a common EU methodology to measure food waste levels; and efforts to ensure the secure supply of critical raw materials through improved recycling and reuse.

Building on the successes of CEAP 1, CEAP 2 was introduced in 2020 as a core component of the European Green Deal. CEAP 2 identified critical shortcomings in current product design, which often fail to prioritise durability, reusability, repairability, and recyclability throughout the product lifecycle. It also highlighted the lack of accessible information and affordable sustainable choices for both consumers and businesses. To overcome these obstacles and foster a truly circular economy, the CEAP 2 emphasised the need for a well-functioning internal market for sustainable products. A central pillar is the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on 18th July 2024, which will set requirements for products to be more durable, reusable, repairable, and easier to recycle. This includes measures like Digital Product Passports (DPP), mandatory green public procurement criteria, and a ban on the destruction of unsold durable goods. CEAP 2 also targeted other resource-intensive sectors with high circularity potential e.g. textiles.

EU Strategy for Sustainable and Circular Textiles: As a precursor to policy development, the EC published EU Strategy for Sustainable and Circular Textiles in March 2022 that has guided regulatory development in the sector. The EU Strategy for Sustainable and Circular Textiles s an initiative aimed at transforming the textile industry to become more sustainable, circular, and resource efficient. While not legally binding, the Strategy set the strategic direction of for EU policy and legislation in the textiles sector, signalling the EC’s intent to introduce new regulatory measures. This strategy focuses on reducing the environmental impact of textiles throughout their lifecycle, from production to end-of-life.

The Strategy addressed key issues such as waste generation, resource consumption, and pollution associated with the textile sector. Key components of the strategy include promoting the design of textiles for durability, repairability, and recyclability. It also emphasises the importance of using sustainable and recycled materials, improving waste management, and fostering innovative business models like reuse and recycling.

The Strategy aims to ensure that textile products placed on the EU market are long-lasting and recyclable and produced in an environmentally friendly manner. By setting clear guidelines and supporting research and innovation, Strategy seeks to drive the industry towards greater sustainability and circularity, benefiting both the environment and the economy.

Key regulations that have been adopted or are currently under development and transposition are outlined below, starting with a summary of key dates and milestones, followed by further detail.

Timeline of Key EU Policy and Regulatory Developments for Textiles (July 2026)

The timeline above highlights the rapid progression from high-level strategy (2022) to binding regulation (2024 onwards), followed by phased implementation and enforcement extending into the late 2020s.

In addition to the legislative timeline outlined above, a significant body of technical and analytical work is being developed to underpin the implementation of ESPR, particularly for priority sectors such as textiles.

The European Commission’s Joint Research Centre (JRC) is carrying out preparatory studies to help shape future rules for textiles under ESPR. This work looks at key areas such as product design, environmental impact, materials, and chemicals. It is being developed in stages, with each phase building a clearer picture of what future requirements for textiles may look like. These findings will feed into the Commission’s impact assessments and future regulations. Together, this work provides the foundation for how the six key components of ESPR will apply to clothing and textiles in practice:

• Product regulations (ecodesign requirements)
• Labelling and information requirements e.g. EU ecolabel (textile)
• Digital Product Passport (DPP)
• Ban on the destruction of unsold consumer goods
• Green Public Procurement (GPP)
• Substances of Concern (SoC)

The table below summarises the key stages and findings from the JRC preparatory studies.

JRC Preparatory Studies for Textiles: Key Milestones and Findings

The following sections explore these regulatory developments in more detail.

• The Ecodesign for Sustainable Products Regulation (ESPR): ESPR is a framework regulation, which came into effect on 18th July 2024, and forms the foundation of the Commission's strategy for promoting environmentally sustainable and circular products (2020 Circular Economy Action Plan). It enables the setting of performance and information conditions e.g. sixteen ‘ecodesign requirements’ including recyclability, recycled content, durability, and repairability. It aims to help the EU meet its environmental and climate goals, double its material use circularity rate, and achieve its energy efficiency targets by 2030.

  The Working Plan 2025–2030, published on the 16th April 2025, identified key product groups that will be the focus of eco-design requirements and energy labelling efforts over the next five years. Textile (apparel) has been prioritised for regulatory development in the final products category. The Working Plan 2025-2030 has also identified two horizontal measures: repairability for all products, and recyclability and recycled content (electrical and electronic equipment).

  Preparatory studies and stakeholder consultations for textile-specific requirements are already underway in 2025, and remain ongoing as of early 2026, with draft delegated acts for textile ecodesign requirements have not yet been published and anticipated to be adopted in binding textile-specific product requirements in Q1/Q2 2027.

  This preparatory work is being led by the EC’s Joint Research Centre (JRC), with the third milestone study (“analysis of base cases and design options”) published in December 2025 and currently under stakeholder consultation in early 2026. The first Ecodesign Forum - the European Commission’s formal consultative mechanism under the ESPR, bringing together stakeholders to inform the development of ecodesign requirements - was held on 19-20 February 2025. This was followed by a stakeholder consultation survey conducted during summer 2025, and a second Forum meeting in November 2025.

  There are six key components of the ESPR that are particularly relevant to the textiles sector:

  • Product regulations (ecodesign requirements)
  • Labelling and information requirements e.g. EU ecolabel (textile)
  • Digital Product Passport (DPP)
  • Ban on the destruction of unsold consumer goods
  • Green Public Procurement (GPP)
  • Substances of Concern (SoC)

  Below is a review of each component of ESPR:.

  • Product regulations (Eco-design requirements): ESPR offers a framework for setting ecodesign requirements. Article 5 of the ESPR presents the 16 eco-design requirements as follows:

    • Durability
    • Reliability
    • Reusability
    • Upgradability
    • Repairability
    • Maintenance and refurbishment
    • Presence of substances of concern
    • Energy use and energy efficiency
    • Water use and water efficiency
    • Resource use and resource efficiency
    • Recycled content
    • Remanufacturing
    • Recyclability
    • Recovery of materials
    • Environmental impacts, including carbon footprint and environmental footprint
    • Expected generation of waste

    The specific eco-design requirements will be defined for individual product groups, such as the textile-specific delegated act expected in Q1/Q2 2027.

    These requirements can be applied either to specific product groups, such as textiles and clothing, or across multiple product categories through horizontal measures. They may take the form of product performance requirements (e.g. durability, recyclability, recycled content, etc) and/or information requirements (e.g. material composition, environmental impact, and care or end-of-life instructions). Performance requirements may set minimum or maximum levels for specific product parameters (e.g. energy use, recycled content, etc) or introduce non-quantitative rules (e.g. banning design features that hinder repair). Information requirements should provide clear data on environmental and carbon footprints, durability, repairability, disassembly, reuse, recycling, and the presence of substances of concern.

    This information is likely to need to be accessible via a Digital Product Passport (DPP) and may also appear on the product, its packaging, labels, manuals, or a free-access website. The DPP In May 2026, 6 of 8 horizontal European CEN/CENELEC technical standards covering information technology aspects of DPP were published. A Delegated Act (DA) is in development for textiles and clothing incorporating ecodesign requirements is expected in Q1-Q2 2027), followed by a DA focused DPP requirements for textiles in Q3-Q4 2027. The initial rollout will begin with priority product groups such as batteries. Textile-specific requirements are expected to follow, with implementation anticipated from 2028/2029 and wider rollout across additional product groups continuing thereafter.

    In 2026, the European Commission is expected to develop an impact assessment of design options and progress towards a DA setting out specific ecodesign requirements for textiles. A textile-specific DA is expected in Q1-Q2 2027. Following adoption, an 18-month transition period is expected before the requirements apply. As a result, the first ecodesign requirements for clothing/apparel are unlikely to enter into force before approximately 2028-29.

  • EU Ecolabel: The EU Ecolabel is the European Union's voluntary environmental label, awarded to products that meet high environmental standards throughout their lifecycle. For textiles, the existing EU Ecolabel criteria cover areas such as fibre sourcing, hazardous chemicals, environmental performance during manufacturing, product durability, fitness for use, social responsibility and consumer information, helping consumers identify products with a lower environmental impact.

    Under Article 34(3) of the ESPR, the EU Ecolabel may also serve as evidence that certain ecodesign requirements have been met where both apply to the same product group. To ensure consistency between the two frameworks, the existing EU Ecolabel criteria for textiles are currently being revised alongside the development of the ESPR Textile Ecodesign Delegated Act. Unlike the current EU Ecolabel, which applies a common set of criteria across textile product categories, the ESPR is expected to introduce more product- and function-specific requirements, recognising that performance expectations differ between products such as T-shirts and outerwear.

    The longer-term aim is to create a more streamlined compliance pathway, where products awarded the EU Ecolabel may also demonstrate compliance with relevant ESPR ecodesign requirements where these overlap. Ongoing technical work is also considering how future ESPR labels will interact with existing information schemes, including the EU Ecolabel, to minimise duplication and improve consistency for businesses and consumers.

    In December 2025 (published January 2026), Commission Decision (EU) 2026/66 extended the validity of the existing EU Ecolabel criteria for textile products until 31 December 2028. This extension provides sufficient time for the revised EU Ecolabel criteria to be developed following the adoption of the ESPR Textile Ecodesign Delegated Act, ensuring the two frameworks are aligned and mutually reinforcing. The final format and content of future ESPR labels and performance classes for textiles are still under development and will be established through future implementing measures and product-specific legislation.

  • EU Digital Product Passport (DPP): The EU DPP is a key initiative under the ESPR, designed to provide comprehensive, standardised information on a product’s environmental and sustainability profile throughout its entire lifecycle. DPP is a core component of the ESPR, and requirements will be established through secondary legislation for textiles as a specific product group. It aims to provide detailed information about the entire lifecycle of textile products and increase transparency and traceability related to the sustainability across all products, clothing as a final product is being prioritised in regulatory development.

    For example, by embedding digital tags or QR codes on garments, consumers, businesses, and regulators will be able to access data on the materials used, manufacturing processes, and environmental impact. This initiative aims to empower consumers to make more informed choices, foster sustainable practices among manufacturers, and facilitate efficient recycling and waste management processes. In the context of textiles and fashion, DPPs are particularly crucial due to the sector's considerable global supply chain and lifecycle environmental footprint.

    Implementation of the Digital Product Passport (DPP) has progressed significantly, with several important developments in May 2026. These include the publication of six technical standards by CEN/CENELEC JTC 24 covering:

    • EN 18216:2026 - Data exchange protocols: Defines how DPP information is exchanged consistently between different IT systems and stakeholders.
    • EN 18219:2026 - Unique identifiers: Establishes requirements for assigning each product a unique identifier to enable traceability throughout its lifecycle.
    • EN 18220:2026 - Data carriers: Specifies how DPP information is linked to physical products, including technologies such as QR codes or other machine-readable data carriers.
    • EN 18221:2026 - Data storage, availability and persistence: Sets requirements to ensure DPP information remains accessible, available and maintained throughout the product lifecycle.
    • EN 18222:2026 - Application Programming Interfaces (APIs): Defines how different digital systems communicate to support DPP lifecycle management and product searchability.
    • EN 18223:2026 - System interoperability: Ensures DPP systems can operate seamlessly across organisations, sectors and Member States, enabling consistent information sharing.

    In May 2026, the European Commission published the Implementing Regulation establishing the Digital Product Passport (DPP) Registry and Unique Product Identifier (UPI) system. This Regulation sets out the technical and operational rules for how Digital Product Passports will be registered, managed and accessed across the EU. It also establishes the central DPP Registry, verification processes for economic operators, and the unique product identifier system needed to support product traceability throughout the value chain.

    The DPP will be introduced on a product-group basis through future delegated acts under the ESPR, likely to be in Q3-Q4 2027. While implementation begins with priority product groups such as batteries, textile-specific DPP requirements will follow as the ESPR textile delegated acts are developed.

    Alongside this, the European Commission’s JRC has published methodological work in 2026 (Report: JRC145830) on defining and prioritising DPP data requirements, including how data should be structured, what level of detail is needed (e.g. product, batch, or item level), and how it supports different use cases such as compliance, traceability, and circularity. This work will directly inform the future DA and impact assessments.

    A public consultation on the certification of Digital Product Passport (DPP) service providers and the operation of the DPP system was conducted between April and July 2025, gathering over 250 stakeholder responses on data management, governance and certification approaches for DPP service providers. The consultation also supported the European Commission's impact assessment for the future implementation of the DPP. In parallel, EU-funded pilot projects (such as CIRPASS-2) and ongoing standardisation work are supporting the technical development, testing and interoperability of DPP systems.

  • Ban on the destruction of unsold textiles and footwear: The ESPR introduces a ban on the destruction of unsold textiles and footwear. Unsold products in this context, can be either overstocks (products that are produced but have never been sold), obsolete products (products for which there is no longer any demand) or products that are damaged or recalled by their manufacturer because of quality issues. In February 2026, the European Commission formally adopted the final Delegated and Implementing Acts that operationalise this ban.

    From 19th July 2026, large companies will be prohibited from destroying certain unsold products with specific rules for apparel and footwear. Medium-sized enterprises have until 18th July 2030, to comply with both disclosure and destruction rules. Micro and small enterprises are exempt.

    ESPR also imposes a transparency obligation. Large companies are required to start publicly disclosing the number and weight of all unsold products they destroy (and their reasons for doings so), starting from their 2025 financial year with disclosures due in 2026. While the first disclosures are due in 2026 based on 2025 data, a new standardised mandatory reporting format (approved in February 2026) will become the official requirement starting in February 2027.

    The ban on destroying unsold goods in the ESPR is divided into two separate regulations:

    • Implementing Regulation: Establishes which product types are covered by the ban, introduces a standardised reporting format using Combined Nomenclature (CN) product codes, and sets the requirements for verifying company disclosures. The Regulation was adopted by the European Commission on 9th February 2026 and applies from 9th February 2027. Companies are also required to retain supporting documentation for five years to enable verification by national authorities.
    • Delegated Regulation: Defines the limited circumstances (derogations) under which unsold apparel and footwear may still be destroyed, such as where products present safety risks, do not comply with legal requirements, or infringe intellectual property rights. The Regulation was adopted by the European Commission on 9th February 2026 and applies from 19th July 2026. It also requires companies to retain evidence demonstrating that any derogation has been applied legitimately. Large companies must comply with the ban from 19th July 2026, medium-sized enterprises from 19th July 2030, while micro and small enterprises are exempt.

  • Green Public Procurement: The ESPR aims to make Green Public Procurement (GPP) rules mandatory for specific products, shifting from their current voluntary status. Member States will have flexibility in applying these policies, but public authorities will be required to purchase products that meet the highest sustainability and circularity standards. At the same time, the Commission continues to describe “EU GPP” more broadly as a voluntary instrument, while noting that mandatory procurement requirements may be introduced through sector-specific legislation such as ESPR implementing acts. This mandatory approach is expected to significantly increase demand for sustainable products, encouraging companies to invest more in eco-friendly innovations.

    As of May 2026, no product-specific GPP requirements or implementation timelines have been formally adopted. However, the European Commission’s Joint Research Centre (JRC) published a 2026 methodology report outlining how mandatory GPP requirements may be assessed and developed under the ESPR. This includes consideration of factors such as market readiness, affordability, environmental benefit, and alignment with ecodesign requirements.

    The report also highlights the importance of developing GPP criteria in parallel with ecodesign requirements, ensuring consistency across the policy framework, and identifies public procurement as a key lever for accelerating the uptake of more sustainable products, including textiles.

  • Substances of Concern (SoC): Substances of concern (SoC) are those that pose risks to the environment or human health or hinder the recyclability of products. These substances are defined by specific criteria, including being identified as a Substance of Very High Concern (SVHC) under REACH, classified under certain hazard classes in the Classification, Labelling and Packaging (CLP) Regulation, or regulated under the Persistent Organic Pollutants (POPs) Regulation. In addition, substances that negatively affect the reuse or recycling of materials are also included, with specific substances to be identified at product-group level. The inclusion of these substances expands the focus beyond intrinsic hazards to include circularity and end-of-life performance. Information on SoCs is expected to be tracked across the product lifecycle and integrated into the DPP.

    The approach to identifying, assessing and managing Substances of Concern (SoCs) in textiles has evolved progressively through the JRC preparatory study. Early work (2023) considered SoCs within the broader context of lifecycle impacts and existing legislation, without defining textile-specific approaches. In 2024, this became more focused, with stakeholder input and early data collection. By 2025, the work became more detailed, including identifying the types of substances used in textile products, introducing the concept of a Bill of Substances (a structured record of chemicals used), and linking this information more closely to the Digital Product Passport (DPP) and supply chain transparency.

    In parallel, JRC published a methodology report (JRC143683, 2025), which explains how SoCs could be identified, tracked, and assessed in practice. This includes mapping chemicals used across supply chains and deciding what information may need to be reported. The report also highlights key challenges for textiles, such as the large number of chemicals used, complex global supply chains, and limited visibility over what substances are used in production. It emphasises the importance of better data and digital tracking systems, including the DPP, to support compliance, recycling, and circularity.

    Many of the substances that may be identified as SoCs are already regulated under the REACH Regulation, which is the EU's main chemicals legislation protecting human health and the environment from the risks posed by chemicals. REACH provides the framework for identifying, authorising and restricting hazardous substances, including Substances of Very High Concern (SVHCs), and therefore forms an important foundation for the SoC requirements under the ESPR. The European Commission has been reviewing the REACH Regulation; however, as of 2026, planned revisions have been delayed and remain on hold following prolonged negotiations and concerns around regulatory burden. As a result, no updated legislative proposal has been formally adopted, and timelines remain uncertain.

    Despite this, targeted restrictions continue to be introduced under the existing REACH framework. For example, the European Commission has adopted restrictions on undecafluorohexanoic acid (PFHxA) and PFHxA-related substances, which are part of the broader family of per- and polyfluoroalkyl substances (PFAS). For the textile sector, this includes restrictions on the use of PFHxA in certain consumer textile products, such as rainwear. Manufacturers and designers will therefore need to ensure that materials and components do not contain prohibited chemical substances.

    As of May 2026, no textile-specific SoC requirements have yet been adopted under the ESPR. These will be established through future delegated acts, informed by the ongoing JRC research and technical work.

Non-ESPR Related Regulations

In addition to ESPR, there are several other regulations that will impact on the fashion and clothing sector that need to be monitored.

• Empowering Consumers for the Green Transition Directive (EmpCo2024/825): this is the primary EU legislation addressing greenwashing and is currently moving into implementation. Although it is a horizontal consumer protection measure, it has significant implications for the fashion and clothing sector. The Directive entered into force on 26th March 2024, Member States were required to transpose it into national law by 27th March 2026, and the new requirements will apply from 27th September 2026.

  The Directive strengthens consumer protection by introducing clear restrictions on misleading environmental claims. This includes banning vague or generic claims such as eco-friendly or green where these cannot be substantiated, prohibiting claims of climate neutrality based solely on carbon offsetting, and restricting the use of sustainability labels that are not based on recognised certification schemes. It also introduces new requirements to provide consumers with information on product durability and repairability at the point of sale.

  The rules apply to all businesses selling products to EU consumers, including SMEs, with no exemption based on company size. In June 2026, the European Commission published implementation guidance to support the consistent interpretation and application of the Directive, clarifying that businesses should review product packaging, labels, websites and marketing materials before the application date to ensure compliance. In practice, this means companies must ensure that environmental claims are supported by credible evidence, sustainability labels are robust, and product information is clear, accurate and verifiable.

  The proposed Green Claims Directive (GCD) is a complementary initiative intended to establish more detailed rules on how explicit environmental claims should be substantiated and verified. However, as of June 2026, the proposal has neither been adopted nor formally withdrawn. Although it remains procedurally active, it is politically stalled following the European Commission's June 2025 announcement of its intention to withdraw the proposal and the subsequent suspension of trilogue negotiations. While the proposal remains included in the Commission's 2026 Work Programme, no substantive legislative progress has been made since June 2025, and the future of the Directive remains uncertain.

• EU Waste Framework Directive: The Waste Framework Directive (Directive 2008/98/EC) is a cornerstone of the EU's waste management policy. It requires that waste be managed without endangering human health and harming the environment, without risk to water, air, soil, plants, or animals, without causing a nuisance through noise or odours and without adversely affecting the countryside or places of special interest. This directive sets the basic concepts and definitions related to waste management, including the "waste hierarchy" which prioritises waste prevention, followed by reuse, recycling, recovery, and disposal as the last resort. The directive also introduces the concept of Extended Producer Responsibility (EPR), holding producers accountable for the entire lifecycle of their products, including take-back, recycling, and final disposal.

  A 2023 Amendment to the Waste Framework Directive requires that by 1st January 2025, EU Member States must implement separate textile collection systems. This requirement is now in force, with the legal obligation for separate collection of textiles applying across the EU, although implementation levels vary. To achieve this, significant investments are needed to enhance infrastructure and develop new technologies for collection, sorting, reuse, and recycling of textiles.

• EU Extended Producer Responsibility (EPR) Scheme for Textiles: The European Commission has established a mandatory EPR framework for textiles through the revision of the Waste Framework Directive, adopted as Directive (EU) 2025/1892 amending Directive 2008/98/EC, which entered into force on 16th October 2025. This introduces common EU rules requiring all Member States to establish EPR schemes for textiles and footwear. Member States have 20 months from 16 October 2025 to transpose the rules into national legislation (i.e. by June 2027), and 30 months to establish EPR schemes, with producer cost coverage expected to begin by April 2028. EPR schemes must be fully operational within this timeframe, while the detailed treatment of micro-enterprises (including any additional compliance periods) will depend on national implementation within the EU framework.

  EPR schemes are designed to reduce waste, promote recycling, and encourage more sustainable product design. The scheme applies to a broad range of producers, including manufacturers, importers, distributors, and online platforms placing textile products on the EU market.

  A key feature of the scheme is “eco-modulation,” where the fees paid by producers are adjusted based on the environmental performance of their products. This means products that are more durable, recyclable, or made from lower-impact materials may attract lower fees, while less sustainable products may face higher costs. The directive also allows additional fee adjustments to address issues such as ultra-fast and fast fashion, linking financial incentives directly to product design and environmental impact, and aligning with relevant ecodesign requirements under the ESPR.

  The products covered by the regulation are defined using Combined Nomenclature (CN) codes in Annex IVc and include clothing and accessories, footwear, and household textiles (e.g. bed linen, curtains, and blankets). Member States may also extend the scope to additional products, such as mattresses. By covering a wide range of products and actors, the scheme aims to ensure responsibility is shared across the full textile lifecycle, supporting improved collection, reuse, and recycling.

  Manufacturers, importers, distributors, and brand owners are directly responsible for the cost and organisation of waste management (including collection, sorting, recycling, and disposal). They must register with national EPR authorities, report data on the volume of products placed on the market, and are typically required to pay fees to Producer Responsibility Organisations (PROs).

  Several countries, including France, the Netherlands, Hungary, and Latvia, have already implemented EPR schemes for textiles. These provide early examples of how EPR can support improvements in collection, sorting, reuse, and recycling infrastructure. Other countries, such as Italy and Sweden, are in the process of developing their schemes.

  EPR will also work alongside the revised EU Regulation on Waste Shipments, which introduces stricter rules to ensure that exported textile waste is only sent to countries where it can be managed in an environmentally sound manner.

• EU Regulation on Waste Shipments: The EU Waste Shipment Regulation (EU) No. 2024/1157 aims to limit the export of textile waste, particularly to non-OECD countries. The new Regulation on waste shipments entered into force on 20^th May 2024 and most core provisions will apply from 21^st May 2026. A key change is the mandatory use of the Digital Waste Shipment System (DIWASS), through which all notifications, consents, and movement documents must be submitted. This replaces paper-based processes and introduces a more standardised and transparent system for tracking waste. At the same time, updated procedures aim to support circularity within the EU, including faster approval processes for shipments to pre-consented recovery facilities. The Regulation also introduces stricter definitions to prevent waste being misclassified as “used goods” or “by-products”, which is particularly relevant for textile exports such as second-hand clothing. In addition, certain waste streams, such as non-hazardous plastic waste, will be subject to stricter controls, requiring prior consent from destination countries before export.

  From 21 May 2027, more stringent export requirements will apply, particularly for shipments outside the EU. Exporters will be required to ensure that receiving facilities in third countries meet standards equivalent to those in the EU, supported by independent third-party audits. Exports of non-hazardous waste to non-OECD countries will be restricted unless those countries are included on an approved list demonstrating their capacity for environmentally sound waste management. The Regulation also introduces enhanced monitoring of exports to OECD countries, with the possibility of restrictions if volumes increase significantly or standards are not maintained.

  This Regulation aims to prevent the EU from exporting its clothing/textile waste problems by ensuring environmentally sound management and strengthening enforcement against illegal shipments both within the EU and to third countries. It also seeks to improve the traceability of waste shipments inside the EU to better facilitate recycling and reuse.

• Corporate Sustainability Due Diligence Directive (CSDDD): This directive entered into force on 25^th July 2024. It aims to promote responsible corporate conduct by requiring companies to identify and address human rights and environmental impacts across their operations and value chains, both within and outside the EU. Large companies must also adopt climate transition plans aligned with the Paris Agreement and EU climate targets. An Omnibus package adopted in February 2026 simplifies due diligence requirements. Member States must transpose the Directive by 26^th July 2027, with phased application starting in 2028 and full implementation by 26^th July 2029.

• Corporate Sustainability Reporting Directive (CSRD): Under the proposed Omnibus I changes, the scope of the CSRD has been narrowed to focus primarily on larger companies, generally those with more than 1,000 employees. These companies are required to disclose information on the risks, opportunities and impacts associated with environmental, social and governance (ESG) issues. Textile companies especially large firms, listed SMEs, and non-EU businesses earning over €150 million in the EU must publish detailed sustainability reports, even if textiles are not their core business. By requiring regular disclosures on environmental and social matters, the CSRD aims to help investors, consumers, and other stakeholders understand and compare textile companies' sustainability performance.

  As of May 2026, the EU is introducing simplification measures through the Omnibus I package. These proposals reduce the number of companies covered by the CSRD, delay certain reporting deadlines (including through the 'stop-the-clock' Directive), simplify reporting requirements, and introduce targeted changes to the implementation of the CSDDD.

  Although CSDDD and CSRD primarily apply to larger companies, they are still likely to have indirect implications for SMEs. Many SMEs will fall be parts of the value chains of in-scope companies, meaning they may be required to provide data on environmental and social performance, supply chain practices, and risk management. This can include information on emissions, materials, labour practices, and due diligence processes.

  As a result, SMEs may face increasing data requests, transparency requirements, and expectations to align with sustainability standards, even where they are not directly regulated. This is particularly relevant in the textile sector, where supply chains are complex and traceability is a growing priority. Over time, this may create both compliance pressures and opportunities, as SMEs that can demonstrate stronger sustainability performance may gain a competitive advantage in working with larger brands and retailers.

Relevant standards

This section highlights various international, European, and industry-specific standards that provide guidance on quality, environmental management, resource efficiency, waste management, responsible sourcing, and transparency. This overview covers key standards shaping sustainable practices in the fashion and textile sector, including ISO environmental management systems, circular economy frameworks and textile-specific sustainability certifications. This section is divided into horizontal standards, which apply broadly across industries, and sector-specific standards, tailored to the unique sustainability challenges of the textile and fashion sector.

Sector Specific Standards:

• ISO 5157 Textiles — Environmental aspects — Vocabulary: ISO 5157:2023 is a comprehensive standard established to ensure the quality, safety, and sustainability of products across various industries. This standard outlines the requirements for environmental management systems, focusing on reducing environmental impacts, enhancing resource efficiency, and promoting sustainable practices. By adhering to EN ISO 5157:2023, organisations can demonstrate their commitment to environmental responsibility and improve their operational performance. The standard provides a framework for identifying and controlling environmental aspects, setting objectives, and implementing policies that align with global sustainability goals. It also includes guidelines for continuous improvement and compliance with relevant legal and regulatory requirements.

• ISO standards for the fashion and clothing sector: ISO 22120:2021 (Recycled Textile Materials) for criteria for defining and certifying recycled content in textiles. ISO 105-C06:2010 (Colour Fastness Tests) to ensure durability and longevity of textiles to minimize waste. ISO 18383:2016 (Quantification of Fibre Content) to support recycling and material reuse through accurate identification. ISO 15797:2017 (Industrial Washing and Finishing) to address durability and quality retention in professional applications.

  Some CEN standards are specific to the fashion and textile sector, including CEN/TR 16985:2016 (Textile Recycling Symbols), EN 16848:2016 (Communication of Bio-based Products) and EN 16732:2014 (Dimensional Change in Washing). In addition, CEN/TC 248/WG 39 (Circular Textiles Chain - Requirements and Categories) is currently developing a suite of standards to support circular textile products, including design for circularity, durability, non-virgin input materials, and the collection, handling and sorting of used textiles and textile waste.

Horizontal Standards:

• ISO 14001 Environmental Management System: ISO 14001 is an international standard for environmental management systems, providing a framework for organisations to minimise their environmental impact, comply with regulations, and continuously improve their environmental performance.

  A revised version, ISO 14001:2026, was published on 15 April 2026, replacing the 2015 standard. The update is evolutionary but introduces stronger focus on climate change, biodiversity, supply chains, and life-cycle thinking, with a new requirement to assess environmental impacts of organisational changes. Organisations are expected to transition by April 2029

• ISO 9001:2015 Quality Management System: ISO 9001 is the international standard for quality management systems, supporting consistent product quality and continuous improvement. A revised version, ISO 9001:2026, is expected in September 2026 (currently in final draft), with a transition period to around September 2029. The update introduces a stronger focus on quality culture and ethics, clearer risk management, and greater emphasis on climate considerations, digitalisation, and data integrity.

• ISO 26000 Social Responsibility:ISO 26000 provides guidance on social responsibility, including labour practices, human rights, and community engagement. While not specific to the textile industry, it is relevant for fashion brands seeking to address social issues in their supply chains.

• ISO 59000 Family of Standards: The ISO 59000 family of standards focuses on establishing a comprehensive framework for implementing and managing circular economy practices and are located within ISO/TC323. These standards provide guidelines on key areas such as terminology, principles, action planning, performance evaluation, and continuous improvement. The primary aim is to harmonise the understanding and application of circular economy concepts, while also supporting organisations in aligning with emerging regulatory requirements and circular procurement practices.

  The first three standards were published in 2024 and as at July 2026 have been moved into revision process to be concluded by Q4 2028.

  Together, these standards support organisations in transitioning from linear to circular value chains by redefining value propositions, enabling system-level changes across supply chains (e.g. take-back systems, repair, remanufacturing, and service-based models), and improving the measurement and communication of circular performance.

• CEN/TC473-Circular Economy: CEN/TC 473 is the European standardisation committee responsible for developing horizontal standards that support the transition to a circular economy across sectors. The committee develops standards that provide guidance, methodologies, requirements and tools to help organisations implement, support and measure the transition to a circular economy, while supporting European legislation and policy. CEN/TC 473 is supported by several Working Groups (WGs) that focus on key areas of circular economy standardisation, including:

  • WG1 - Terminology, framework and principles
  • WG2 - Circular business models and circular procurement
  • WG3 - Information sharing across value chains
  • WG4 - Extended Producer Responsibility (EPR)

• CEN/CLC/JTC 10: launched a series of standards related to reuse, repair, and recycling (EN 4555X Series). Initially the standards were focused on energy-related products sector related to the Ecodesign directive. Under ESPR, the JTC 10 is required to broaden out its standards development to cover and be relevant to all products including clothing/textiles. These include EN 45554:2020 (methods to assess the ability to repair, reuse, and upgrade energy-related products), EN 45555:2019 (methods for assessing the recyclability and recoverability of energy-related products), EN 45556:2019 (methods for assessing the proportion of reused components in energy-related products) and EN 45557:2020 (methods for assessing the proportion of recycled material content in energy-related products).

• CEN/CLC/JTC 10/WG 8 Method to Achieve Circular Designs of Products: EN 45560:2024 provides a standardised method for integrating circularity into product design and development, supporting the transition towards more resource-efficient and sustainable products. Published in November 2024, it is the 1st standard to be published under the ESPR broader product remit, the standard sets out a structured approach to incorporating circular design principles across the product lifecycle, including material selection, manufacturing processes, use phase, and end-of-life management. Key aspects include life cycle thinking, material efficiency, and practical design guidance to support durability, repairability, reuse, and recyclability. EN 45560 is applicable across a wide range of product categories, particularly where no product-specific circular design guidance standards exist, and is intended to support the implementation of EU policy frameworks such as the ESPR.

• CEN/CLC/JTC 24 – Digital Product Passport Framework and System: CEN/CLC/JTC 24 has developed the core European standards framework for the Digital Product Passport (DPP), supporting implementation of the ESPR. In May 2026, six horizontal DPP standards were published, covering the main technical elements needed for the DPP system:

  • EN 18219:2026 – Unique identifiers
  • EN 18220:2026 – Data carriers
  • EN 18216:2026 – Data exchange protocols
  • EN 18221:2026 – Data storage, archiving and data persistence
  • EN 18222:2026 – Application Programming Interfaces (APIs) for DPP lifecycle management and searchability
  • EN 18223:2026 – System interoperability

  Two further standards remain under development: prEN 18239:2026, covering access rights management, information system security and business confidentiality; and prEN 18246:2026, covering data authentication, reliability and integrity. Together, these standards provide the technical foundation for how DPP systems will operate across product groups, while the specific information required for textiles will be defined later through product-specific ESPR delegated acts.

  At the international level, DPP standardisation is also progressing beyond Europe. ISO/AWI 25534-1 (Overview and Fundamental Principles), developed jointly by ISO and UNECE under ISO/TC 154, progressed to Approved Work Item (AWI) status in February 2026 and aims to establish a global framework and architectural principles for DPP systems. In parallel, ISO and IEC have established the Joint Technical Committee on Digital Product Passports (ISO/IEC JTC 5) to develop international standards covering DPP terminology, system architecture, core technical components and data interoperability. The IEEE is also developing IEEE SA P3828, which focuses on the reference architecture and technical requirements for DPP systems. In addition, China is developing its own DPP framework through national standards and pilot initiatives, including the establishment of a dedicated national DPP standardisation working group in 2026. Together, these initiatives demonstrate increasing international convergence towards interoperable Digital Product Passport systems.

Other Industry Standards:

• Global Organic Textile Standard (GOTS): GOTS is a leading standard for the processing of organic fibres, including ecological and social criteria. It covers the entire textile supply chain, from harvesting of raw materials to environmentally and socially responsible manufacturing. For SMEs, GOTS provides a recognised route to verify organic claims, but requires full supply chain traceability, certified inputs, and compliance with strict processing and chemical use criteria, which can be resource-intensive to implement.

• Bluesign® System: The Bluesign® System is a holistic approach to textile production that aims to eliminate harmful substances from the manufacturing process, ensure resource efficiency, and promote sustainable practices. It provides guidelines and tools for brands and manufacturers to improve the environmental performance of their products. For SMEs, the Bluesign® System is particularly relevant when selecting suppliers and sourcing materials, as working with Bluesign®-approved manufacturers and material suppliers can help support more sustainable production practices.

• OEKO-TEX® Standard 100: OEKO-TEX® Standard 100 is a certification system for textile products that ensures they are free from harmful substances. It focuses on consumer safety and sets limits for the use of certain chemicals in textiles, including dyes and finishes. For SMEs, it is one of the more accessible entry-level certifications, often used to demonstrate compliance with chemical safety expectations and support market access, particularly in EU markets.

• Better Cotton Initiative (BCI): Aims to make global cotton production better for the people who produce it and the environment. Central to its mission is the Better Cotton Standard System, a holistic approach to sustainable cotton production that comprehensively covers all three pillars of sustainability: environmental, social, and economic. This system encompasses clear Principles and Criteria, alongside robust monitoring mechanisms that demonstrate results and impact, all of which work together to support the credibility of Better Cotton and BCI. For SMEs, BCI offers a more scalable and accessible sourcing route compared to organic cotton, but does not provide full product traceability, meaning it is typically used to support sourcing strategies rather than product-level sustainability claims.

More information

Textile Exchange: Textile Exchange is a global nonprofit organisation that provides resources and information on sustainable fibres and materials. Their website offers reports, standards, and guides on topics such as organic cotton, recycled polyester, and responsible wool production. Here is a link to their Circularity Companion Guide. Resources such as the Circularity Companion Guide can help SMEs begin integrating circularity into product development without requiring full system redesign.

The Ellen MacArthur Foundation: The Ellen MacArthur Foundation is a thought leader in the circular economy space, including textiles and fashion. Their reports and publications, such as the "A New Textiles Economy" series, offer insights into sustainable material selection and circular design principles.

WRAP and The Circular Design Working Group: The Circular Design Working Group is a collaborative initiative between WRAP (Waste and Resources Action Programme) and Textiles 2030 that develops guidance and resources on circular design for the textile and fashion sector. Its outputs include the Circular Design Toolkit, case studies and design guidance that support the application of circular design principles during product development. These resources may be particularly useful for UK-based SMEs.

ZDHC Manufacturing Restricted Substances List (MRSL): The ZDHC Foundation (Zero Discharge of Hazardous Chemicals) plays a pivotal role in the fashion and textile industries by promoting safer chemical management practices. It was established with the goal of eliminating the use of hazardous chemicals in the production process. The ZDHC’s approach includes developing tools like the Manufacturing Restricted Substances List (MRSL) and providing a platform for industry stakeholders to collaborate on sustainable chemical management practices. The MRSL is a critical tool in the fashion industry's push towards sustainability and sets forth strict guidelines on the chemical substances that can be used in the production and manufacturing of textiles, leather, and footwear. Its primary goal is to avoid the use of hazardous chemicals that could potentially harm workers, consumers, and the environment. The list specifies acceptable concentration limits for each chemical listed, ensuring that any chemical used in manufacturing processes is safe, controlled, and within the recommended limits. Compliance with the ZDHC MRSL is part of the broader commitment by brands and manufacturers to improve chemical management practices, promote worker safety, and reduce environmental impact.

Carbon Trust: The Carbon Trust is an international organisation focused on helping businesses, governments, and other organisations reduce their carbon emissions and become more resource-efficient. Their mission is to accelerate the move to a sustainable, low-carbon economy by providing specialist support to help organisations cut carbon emissions, save energy, and commercialize low-carbon technologies. The Trust offers advice, footprinting, and technology development services, along with certification and verification to standardize sustainability claims, thereby encouraging and guiding companies in their efforts to make real changes that benefit both the environment and their economic status.

Water Footprint Network: The Water Footprint Network (WFN) is a dynamic global network dedicated to promoting sustainable, fair, and efficient use of fresh water resources worldwide. Founded in response to the growing recognition of water scarcity issues, the WFN develops methods to calculate and report water footprints, helping businesses and governments to understand water use and reduce their water consumption. Their work includes providing tools and guidelines that assess water use across various products and processes, aiming to improve water management practices and support the creation of water stewardship standards.

World Resources Institute: The World Resources Institute (WRI) is a global research organisation that focuses on environmental sustainability and the well-being of people. WRI works to address urgent environmental challenges by providing insights, analysis, and practical solutions to governments, businesses, and civil society. The organisation conducts research and analysis on a wide range of topics, including climate change, water resources, forests, energy, food systems, and sustainable cities. WRI collaborates with partners around the world to develop innovative strategies and implement practical solutions that promote economic development while safeguarding natural resources and ecosystems.