The Textile Ecodesign Study (3rd Milestone): Scope, Timeline, and What It Signals for Future ESPR Requirements
Shortly before Christmas, the European Commission’s preparatory study on ecodesign requirements for textiles reached its third milestone. While this milestone does not introduce binding rules and there is still significant uncertainty around what the final ecodesign requirements for textiles will look like, the publication of the third milestone marks an important shift in the regulatory process.
It gives more clarity on where the focus of upcoming requirements is likely to lie, shows a clear regulatory direction, and offers companies concrete ways to assess their readiness. As the focus moves more clearly toward how different regulatory approaches might work in practice, the study also reveals underlying assumptions about data availability, feasibility, and implementation.
This post explains why the third milestone matters, how it fits into the overall ESPR process, how it builds on earlier work, which textile products are covered by the study, and what it tells us — and does not yet tell us — about future information requirements, timelines, EPR eco-modulation, and related compliance obligations.
1. What the 3rd milestone is and what it is not
The textile ecodesign preparatory study supports the implementation of the Ecodesign for Sustainable Products Regulation (ESPR). Its role is to inform the Commission’s decision on what type of ecodesign requirements could be introduced for textiles through future delegated acts.
The third milestone does not establish legal obligations. In particular, it does not:
- define binding requirements or thresholds,
- introduce mandatory performance levels,
- or create enforceable compliance duties for companies.
What it does provide is a structured exploration of design options and regulatory approaches currently dominating the preparatory work. These are used to examine how different sustainability objectives could be addressed in practice, what kinds of information would be required, and where feasibility or proportionality challenges might arise.
Several steps still need to be followed before any requirements become law:
- The preparatory study must be finalised,
- A formal impact assessment must be carried out,
- and only then can delegated acts under ESPR be drafted and adopted.
For companies, this means there is no immediate compliance deadline. At the same time, the direction of regulatory thinking is becoming more concrete, particularly with regard to information requirements and data availability. The uncertainty at this stage is therefore less about whether requirements are coming and more about how they will be structured, which is precisely what makes this phase relevant for planning.
Compared to earlier phases of the study, the focus shifts from identifying what matters to exploring how those aspects could be regulated. This includes testing different regulatory logics, examining trade-offs between ambition and feasibility, and assessing whether the necessary data could realistically be made available across diverse textile value chains.
In this sense, the third milestone marks a transition from problem definition to regulatory design thinking — while remaining explicitly preparatory. It also signals that, at this stage, the main focus of potential ecodesign requirements for textiles lies in information requirements, with performance requirements (as defined in the ESPR) remaining limited, in practice, to an explored performance requirement for recycled content.
Together with the upcoming changes to the Textile Labelling Regulation in the field of digital labelling, this places the Digital Product Passport at the centre of the future ecodesign framework for textiles.
2. Which textile products are covered by the study
A key question for many companies — particularly those operating in workwear and professional apparel — is what exactly falls within the scope of the preparatory study. Scope questions are often where companies either overreact too early or wait too long, especially in segments that sit close to regulatory boundaries.
The study does not address the textile sector as a whole. Instead, it defines a proposed scope based on the ability to develop common ecodesign requirements for products that are sufficiently similar in terms of function, material composition, chemical composition, and technologies used.
Based on this assessment, textile apparel is identified as the most suitable subgroup to be addressed. This choice is justified by factors such as market relevance, availability of existing research, and contribution to environmental impacts. The scope is also aligned with the Product Environmental Footprint Category Rules for Apparel and Footwear (PEFCR A&F).
The apparel categories included cover a wide range of garments, including upper and lower body clothing, outerwear, underwear, hosiery, swimwear, and selected apparel accessories such as hats, scarves, belts, and gloves.
Importantly, the study explicitly states that technical textile apparel, such as workwear and sportswear are included in the scope, provided that:
- the product qualifies as textile apparel (containing at least 80 % by weight of textile fibres), and
- It is not part of the list of excluded products.
The study notes that, despite specific performance features (for example, thermoregulatory properties in sportswear), workwear, sportswear, and leisurewear share many functional and material characteristics with other apparel products. On this basis, they are considered sufficiently similar to be addressed within the same preparatory study and under the same potential ecodesign requirements. At the same time, this approach will be reassessed later in the process when ecodesign options are examined in more detail.
Products that are clearly excluded from scope include smart textiles and electronic textiles, textile apparel classified as personal protective equipment (PPE), medical devices or accessories to medical devices, and textile products classified as toys. Intermediate products such as fibres, yarns, and fabrics are also excluded, although they may be indirectly addressed through requirements applied to finished apparel products.
Issues related to customised and upcycled apparel, as well as the possible inclusion of other textile products such as household or cleaning textiles, are deferred to the subsequent impact assessment phase.
3. Design options and regulatory paths: how to read the study
A central feature of the third milestone is the introduction of design options and regulatory paths.
Design options represent alternative ways of addressing sustainability aspects such as durability, recyclability, recycled content, or environmental footprint. They are not cumulative requirements, but different regulatory approaches that could be pursued. Their value at this stage lies not in predicting outcomes, but in revealing the regulatory logic and data dependencies behind different approaches.
Regulatory paths explore how these design options might be combined. They are used to compare factors such as:
- expected effectiveness,
- data and administrative burden,
- enforcement complexity,
- and feasibility across the value chain.
The study does not assume that all options would apply simultaneously. Instead, paths function as analytical scenarios to understand the implications of different regulatory choices.
4. What the study actually explores
The main analytical focus of the study is a set of information areas that would be central under different regulatory approaches. At a high level, these include:
- robustness and durability,
- recyclability,
- recycled content,
- environmental and carbon footprint.
These should be understood as clusters of information under examination, not as final reporting obligations. The study explicitly tests where such information would originate, how reliable it could be, and what challenges different actors in the value chain would face in providing it.
A recurring theme is the presence of trade-offs between objectives. Improving one aspect may complicate another, and the study does not attempt to resolve these tensions definitively at this stage. What it does make clearer, however, is that all options rely on the existence of consistent, product-level information, even if the way that information is ultimately used remains open.
For the sake of brevity, these information areas will be explored in more detail in upcoming posts in this series. In parallel, discussions around a potential ESPR label — effectively a visualisation of selected information requirements, similar to existing ecodesign labels — are ongoing, with the aim of ensuring that information required from textiles can also be understood in practice by consumers.
5. Indicative timeline and the upcoming 4th milestone
During the Commission’s information session in January 2026, an updated indicative timeline for the textile ecodesign delegated act was presented.
Following the third milestone, the preparatory study is expected to be finalised during the first half of 2026, including scenario analysis and elements related to the digital product passport. This will feed into the impact assessment, which is expected to start in Q1 2026 and run through 2026, with targeted consultations, discussion in the Ecodesign Forum, and internal validation steps.
The Commission indicated that the fourth milestone of the preparatory study is planned for Q2 2026, with discussion at the Ecodesign Forum. This milestone is expected to focus on:
- policy scenarios,
- textile-specific digital product passport elements,
- chain-of-custody considerations,
- verification of compliance,
- and impacts on SMEs and third countries.
The impact assessment is expected to be finalised around Q4 2026, after which the Commission would move toward adoption of the textile ecodesign delegated act, followed by the usual scrutiny and transition periods. In practical terms, this means that 2026 is primarily about regulatory finalisation and system design, rather than immediate operational compliance.
6. Ecodesign, digital product passports, and the Textile Labelling Regulation
The Commission has also clarified how the textile ecodesign work is being aligned with the planned revision of the Textile Labelling Regulation (TLR).
The current policy direction is toward a single-label approach, where mandatory basic information (such as fibre composition, care instructions, size, and origin) continues to be governed by the TLR, while additional sustainability-related information is made available digitally as part of the digital product passport enabled under ESPR, together with other information requirements for textiles set out in relevant legislation.
Ensuring coherence between the textile ecodesign delegated act and the TLR revision is a formal objective. The TLR revision is tentatively planned for adoption in Q2 2026, and label layout requirements are being developed through a dedicated implementing act under ESPR. Work on label design prototypes is ongoing and will feed into the impact assessment for the textile ecodesign delegated act.
7. A broader simplification and digitalisation context
The textile ecodesign work is taking place within a wider EU policy effort to reduce administrative burden and consolidate product-related information flows.
In the Environmental Omnibus package, the Commission explicitly acknowledges that certain existing reporting mechanisms have not delivered their intended value. In particular, the obligation to report data to the SCIP database is proposed to be repealed, due to its limited effectiveness for recyclers and the high administrative costs it has imposed on companies. The Commission states that the role envisaged for SCIP will be progressively fulfilled by EU chemicals legislation — notably through the One Substance One Assessment approach — and by the digital product passport, which is expected to include information on substances of very great concern.
A similar simplification logic applies to extended producer responsibility (EPR) schemes. The Omnibus confirms steps toward reducing cross-border complexity, lowering reporting frequency, and moving toward greater harmonisation and digitalisation of EPR obligations. These elements are expected to be further developed in the upcoming Circular Economy Act, planned for 2026.
Seen together, these initiatives point toward a regulatory direction that is less about adding new reporting layers and more about reusing the same product data across multiple policy objectives, with the digital product passport acting as the technical backbone.
8. What this means now and what comes next
The third milestone does not tell us what the final textile ecodesign rules will be. It does, however, show how the Commission is approaching regulatory design, feasibility, scope, and information needs.
For companies, the main uncertainty lies in thresholds, combinations of requirements, and final scope boundaries — not in the overall direction of travel. Product-level information, structured in a way that allows reuse across ecodesign, digital product passports, labelling, and EPR-related obligations, is clearly becoming more central.
In the next posts in this series, we will look at individual design options — such as durability, recyclability, recycled content, and environmental footprint — explaining how each is explored in the study and what kinds of product data foundations they would rely on under different regulatory paths.
The aim is not to predict outcomes or take positions, but to understand the assumptions on which the future rules are being built. The main uncertainty lies in thresholds and combinations — not in the growing reliance on structured, reusable product-level information. For companies, the real risk is therefore not getting the final regulation “wrong”, but treating this phase as just another reporting discussion rather than a signal about how product data will be expected to function going forward.
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