01 / ESPR COMPLIANCE GUIDE
ESPR Fashion Compliance: What EU Fashion Brands Need to Know Now
In July 2024 the Ecodesign for Sustainable Products Regulation (ESPR) entered into force — the most comprehensive reform of EU product regulation in two decades. It replaces the old Ecodesign Directive, extends its scope from energy-related products to nearly all physical goods, and provides the legal basis for the Digital Product Passport, the ban on destroying unsold textiles, and binding design requirements for durability, repairability and recyclability.
In April 2025 the European Commission adopted the ESPR Working Plan 2025–2030, confirming textiles as a priority product category. ESPR compliance therefore concerns every fashion brand on the EU market: the industry stands at the beginning of a regime that reaches deeper into design decisions, supplier selection and production data than any previous EU regulation for this sector.
This guide explains what the ESPR is, which provisions apply concretely to fashion brands, which timeline to plan for, and which risks non-compliance carries.
1. What is the ESPR?
The Ecodesign for Sustainable Products Regulation (ESPR) is EU Regulation 2024/1781. It was adopted on 13 June 2024 and entered into force on 18 July 2024. It replaces Ecodesign Directive 2009/125/EC, which originally regulated only energy-related products.
The ESPR pursues four central goals: extending product lifetimes, increasing material efficiency, facilitating repair and reuse, and improving recyclability.
Unlike the old directive, the ESPR is directly applicable — it requires no transposition into national law. Once a product-group-specific delegated act becomes applicable, the requirements apply to all manufacturers, importers and distributors in all 27 member states simultaneously.
The regulation itself sets the framework. The concrete requirements per product category — materials, repair requirements, data points, thresholds — are defined in delegated acts. For textiles, this delegated act is expected in 2027; a Commission proposal is possible as early as late 2026.
2. ESPR and DPP: what is the difference?
The two terms are often used interchangeably — incorrectly. The Digital Product Passport (DPP) is a single instrument introduced by the ESPR. The ESPR covers far more. Five central components concern textiles:
First — binding design requirements. Minimum standards for durability, repairability, reusability and recyclability. The Commission can prescribe, for example, minimum lifetimes, requirements for certain fibre blends, or minimum recycled-content shares.
Second — the Digital Product Passport (DPP). Machine-readable product records with verifiable information on materials, supply chain, compliance and circularity, accessible via a data carrier on the product.
Third — the ban on destroying unsold textiles. From 19 July 2026, large companies are prohibited from destroying unsold apparel, clothing accessories and footwear. Medium-sized companies follow from 19 July 2030; small and micro enterprises are permanently exempt. The permissible derogations were set by the Commission in a delegated regulation adopted on 9 February 2026 (published in the Official Journal on 22 April 2026). Already in force: under Art. 24 ESPR, large companies must disclose how many unsold products they discard — first covering financial year 2025; from 2 March 2027 the standardised format of Implementing Regulation (EU) 2026/2 applies.
Fourth — extended market surveillance. Member states must actively verify compliance. Violations risk fines, sales stops, import bans and publication of non-compliant brands.
Fifth — consumer transparency obligations. Certain information must be accessible before purchase — for example repairability or durability information.
The DPP is thus one of five central components of the ESPR — not the only one. A brand that works only on the DPP and ignores the design requirements is not ESPR-compliant.
3. Which fashion products fall under the ESPR?
The ESPR applies in principle to nearly all physical products on the EU market. Exempt are, among others, food, feed, medicinal products, and living plants and animals.
For the fashion industry this means: apparel, footwear, leather goods, accessories, home textiles and sportswear fall under the regulation. The precise scope of products covered by the textile act will be set in the delegated act — the EU Textiles Strategy (March 2022) uses a broad definition.
There is no revenue or size exemption for the DPP and the design requirements. A micro brand with €200,000 annual revenue is subject to the same requirements as an international group. The only size-related relief concerns the destruction ban (small and micro enterprises exempt; medium-sized companies only from 2030).
Important: the ESPR applies to products placed on the EU market — regardless of production country. A German brand producing in Turkey and selling in Germany is just as affected as a Bulgarian brand with local production and a French distributor. Online sales via platforms or direct-to-consumer change nothing about the compliance obligation.
4. The central ESPR requirements for textiles
Until the delegated act, the concrete requirements are not finally fixed. From the ESPR itself, the April 2025 Working Plan, the EU Textiles Strategy and the consultation documents, the following expected requirements can be derived:
Material requirements. Minimum shares of recycled or renewable fibres, requirements for certain fibre blends for recyclability reasons, minimum durability standards for coatings and dyes.
Design requirements for repairability. Availability of spare parts (buttons, zips) for defined periods, repair information for consumers, minimum durability of seams and closures.
Design requirements for recyclability. Preference for mono-material constructions, easily separable components, requirements for glued or welded joints.
Chemical compliance. Stricter requirements for substances of concern, disclosure above the 0.1% threshold, microplastics information for products with high synthetic content.
Data transparency via DPP. Complete dataset per product, accessible via a data carrier on the product — with the LGFL DPP Data Framework as the reference framework — 10 domains under four ESPR legal-basis categories.
Take-back and recycling information. Information on take-back options and recycling instructions for consumers and professional sorters.
The final delegated act will equip these requirements with concrete thresholds, test methods and transition periods. Brands should assume the requirements will land at the more ambitious end of the outlined range — textiles are positioned as the ESPR's visible flagship category.
5. The timeline: what applies when
18 July 2024 — ESPR in force. The framework regulation applies, without product-specific requirements for textiles yet.
16 April 2025 — ESPR Working Plan 2025–2030. Textiles confirmed as priority category; preparatory work for the delegated act underway.
Financial year 2025 — disclosure obligation active. Large companies must disclose for the first time how many unsold products they discard (Art. 24 ESPR); first reports in 2026, initially in free format.
9 February 2026 — Commission adopts two implementing measures. Implementing Regulation (EU) 2026/2 standardises the disclosure format (applicable from 2 March 2027); the delegated regulation sets the derogations from the destruction ban (applicable from 19 July 2026).
19 July 2026 — destruction ban for large companies. Unsold apparel, accessories and footwear may no longer be destroyed, subject to the defined derogations.
19 July 2026 — EU DPP Registry. The central technical infrastructure for all product passports is scheduled to become operational (Art. 13 ESPR).
Late 2026 — Commission proposal possible. The proposal for the textile act and horizontal DPP acts (data carriers, identifiers, service providers) are expected.
2027 — textile delegated act expected. Final data requirements, design specifications and thresholds published; the transition period of an expected 18 months then begins.
Expected from 2028 — mandatory application. All textile products placed on the EU market thereafter must comply. Stock placed on the market before the date is exempt.
19 July 2030 — extension of the destruction ban and disclosure obligation to medium-sized companies.
Through 2030 — further product categories. The Working Plan 2025–2030 provides for delegated acts for additional priority categories.
6. Compliance risks of non-conformity
The ESPR leaves the concrete design of penalties to the member states (Art. 74) but requires them to be effective, proportionate and dissuasive; the company's annual turnover is among the assessment criteria. In Germany, surveillance is expected to sit with the market surveillance authorities of the Länder; the precise allocation of responsibilities is not yet final.
Non-compliant brands face the following risks:
Fines. Levels are set by member states. For context: the GDPR, a comparably enforcement-heavy EU regulation, provides for fines of up to four percent of global annual turnover.
Sales stops and recalls. Authorities can stop the sale of non-compliant products and order delivered goods recalled — at the brand's expense.
Import controls. Non-compliant products from third countries can be stopped at the EU's external border.
Publication. Established violations can be made public — with substantial reputational risk.
Competitive pressure. Compliant brands can report non-compliant competitors to authorities; in several member states, unfair-competition claims add a private enforcement layer.
Greenwashing liability. In parallel, EU Directive 2024/825 (EmpCo) bans generic environmental claims without substantiation from 27 September 2026. DPP-verified data substantially lowers this risk; unsubstantiated sustainability claims raise it.
7. Preparation path for fashion brands
Three priorities for the next 18 months:
Priority 1 — build data architecture. Start with an inventory: which ESPR-relevant data do you hold today, in which format, with which update frequency? A readiness assessment against the LGFL DPP Data Framework provides the baseline. A DPP Readiness Audit answers this question in structured form.
Priority 2 — adapt the design process. The ESPR will regulate design decisions directly. Fibre blends permissible today could fall under future recyclability requirements. Start building mono-material options, separability and repairability into the design process for upcoming seasons.
Priority 3 — structure the supplier network. A substantial share of ESPR data comes from suppliers. Start structured supplier onboarding with a clear data requirements catalogue. Your tier-1 suppliers should be able to deliver the core data fields in standardised form by mid-2027.
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