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ESPR Fashion Compliance: What EU Fashion Brands Need to Know Now

Published 13.04.2026 · Updated 13.10.2026 · Reading time ~8 min · by Lior Gabriel Graetz · LG Fashion Labs

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 apparel, clothing accessories and footwear, 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.

Jul 2024

The Ecodesign for Sustainable Products Regulation entered into force — the most comprehensive EU product-regulation reform in two decades.

Apr 2025

The European Commission adopted the ESPR Working Plan 2025–2030, confirming textiles as a priority category.

Every brand

ESPR compliance concerns every fashion brand on the EU market, not only large enterprises.

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, no adoption date has been fixed for this delegated act: the Commission's Digital Product Passport pages give Q3–Q4 2027 (DPP timeline) and Q4 2027 (textile-apparel page), both marked indicative — see section 5.

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:

01BRAND DATAtech packs · certificates · suppliers02STRUCTURED PASSPORT10 domains per style03EU DPP REGISTRYArt. 13 ESPR04CONSUMER SCANQR data carrier
From raw production data to a live passport: structured per style, registered with the EU, read by a scan.

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 apparel, clothing accessories and footwear. From 19 July 2026, large companies are prohibited from destroying unsold apparel, clothing accessories and footwear. Medium-sized companies follow from 19 July 2030; micro and small enterprises are not covered, although the Commission may extend the ban and the Art. 24 disclosure duty (see below) to them by delegated act where there is sufficient evidence that they could be used to circumvent the ban or the duty (Art. 25(5) ESPR). 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 the first full financial year during which the ESPR is in force (2025 for a calendar-year company). Implementing Regulation (EU) 2026/2, which applies from 2 March 2027, sets a standardised format for products discarded as from the first full financial year after that date.

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 exemptions in the ESPR itself concern the destruction ban and the disclosure duty for discarded unsold products: micro and small enterprises are not covered by either as the regulation stands today (the Commission may extend both to them by delegated act where there is sufficient evidence of circumvention, Art. 25(5)), and medium-sized companies are covered from 19 July 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:

AIdentificationESPR Annex III b–d, g–k100Brand Information200Supply ChainInformation300ProductInformationBProduct-specificparametersESPR Art. 7(2)(b)350MaterialInformation660DurabilityInformation600CircularityInformation650SustainabilityInformationCSubstances of concernESPR Art. 7(5)500Substances ofConcernDOther Union lawESPR Annex III a, e, f400Care Information501Compliance &Certifications370Foundational / system layerCEN/CENELEC JTC 24 · EN 182xx series (6 of 8 published)
The LGFL DPP Data Framework: domains nested under the EU’s four ESPR legal-basis categories, on a foundational system layer (CEN/CENELEC JTC 24).

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.

18 July 2024ESPR entered intoforceApril 2025EC Working Plan —textiles confirmedpriority13 May 2026JRC study —proposed textileDPP data content15 July 2026EU cites 6 of 8DPP standards inOfficial Journal20 July 2026EU DPP registrylive (testing)27 Sept 2026Green claimsban in forceH2 2027 (indicative)Delegated act fortextiles expected2029 earliestEarliest textileDPP application(18-month rule)19 July 2030Destruction banextends to medium-sized companies
The timeline — from ESPR entering into force to the earliest textile DPP application and the extension of the destruction ban to medium-sized companies. The H2 2027 node is indicative: no adoption date has been fixed for the textile (apparel) delegated act (details below), and 2029 is our calculation, not a date the Commission has published.

16 April 2025 — ESPR Working Plan 2025–2030. Textiles confirmed as priority category; preparatory work for the delegated act underway.

First full financial year after the ESPR entered into force (2025 for calendar-year companies) — disclosure obligation active. Large companies must disclose for the first time how many unsold products they discard (Art. 24 ESPR); Art. 24 sets no deadline for the first disclosure; the standardised format applies only to products discarded from the first full financial year after 2 March 2027.

9 February 2026 — Commission adopts a delegated and an implementing regulation. 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, clothing accessories and footwear may no longer be destroyed, subject to the defined derogations.

20 July 2026 — EU DPP Registry. The central technical infrastructure for all product passports launched (Implementing Regulation (EU) 2026/1778, Art. 13 ESPR) and is live in a testing and onboarding phase; mandatory registration is phased in per product category as each delegated act takes effect.

Second half of 2027 (indicative) — textile delegated act planned. No adoption date has been fixed for the textile (apparel) delegated act. The Commission's first ESPR Working Plan (April 2025) gives 2027 as the indicative year; its Digital Product Passport pages list adoption for Q3–Q4 2027 (DPP timeline, together with aluminium and tyres) and for Q4 2027 (textile-apparel page), both marked indicative. The act sets the final data requirements, design specifications and thresholds. The Commission's Have Your Say entry for the act (initiative 16116, published 18 December 2025 and not updated since) still shows "First quarter 2027" for adoption and "Fourth quarter 2025" for a public consultation that has not opened; none of the 2026 Commission or JRC documents reviewed repeats that date.

2029 at the earliest — mandatory application. ESPR Article 4(4) provides that a delegated act's date of application shall not be earlier than 18 months from its entry into force, except in duly justified cases; for an act adopted in the second half of 2027 that means 2029 at the earliest (our calculation, not a date the Commission has published). 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; Article 74(2) lists eight factors member states must weigh, including the financial situation of the responsible company, the nature and duration of the infringement, and any economic benefit derived from it — not a fixed turnover-based formula. 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.

One member state has already put a concrete figure on it: Germany's Ökodesign-Gesetz sets fines of up to €100,000 for violating the ESPR's destruction ban (Article 25), applying from 1 November 2026 — see our penalties guide for the full national breakdown.

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.

DPP AUDIT

How ready is your collection for the ESPR?

Benchmark one complete collection against the LGFL DPP Data Framework. 10 domains, four ESPR categories. Under NDA, files sent whole and unedited.

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Frequently asked questions

What is the difference between ESPR and DPP? +
The ESPR is the overarching EU regulation; the Digital Product Passport (DPP) is one of its instruments. The ESPR additionally contains design requirements, the destruction ban, market surveillance and transparency obligations.
Does the ESPR apply to my brand if we only sell online? +
Yes. The ESPR applies to all products placed on the EU market — regardless of sales channel. Online, brick-and-mortar, wholesale, D2C and marketplace are all equally covered.
We produce in Turkey and sell in Germany — are we subject to the ESPR? +
Yes. The ESPR applies regardless of production country. The EU responsible economic operator — typically the brand placing the product on the market — carries the compliance obligation.
Which fines apply for ESPR violations? +
Levels are set by member states; the ESPR requires effective, proportionate and dissuasive penalties, with the responsible party's financial situation among the criteria (Article 74(2)). For context: the GDPR provides for up to four percent of global annual turnover.
Do we have to wait for the delegated act before acting? +
No — and it would be expensive. No adoption date has been fixed for the textile (apparel) delegated act. The Commission's first ESPR Working Plan (April 2025) gives 2027 as the indicative year; its Digital Product Passport pages list adoption for Q3–Q4 2027 (DPP timeline, together with aluminium and tyres) and for Q4 2027 (textile-apparel page), both marked indicative. Brands that only start once the act is adopted have effectively around 18 months to build a data architecture for several running seasons — too short for most.
Who supervises ESPR compliance in Germany? +
The precise allocation is not yet final. Surveillance is expected to sit with the market surveillance authorities of the Länder.
Does the DPP obligation also apply to small fashion brands? +
Yes. The DPP concerns every textile product on the EU market, regardless of company revenue. Size-based relief exists only for the destruction ban and the disclosure duty for discarded unsold products: micro and small enterprises are not covered by either as the regulation stands today (the Commission may extend both to them by delegated act where there is sufficient evidence that such enterprises could be used to circumvent them, Art. 25(5)), and medium-sized enterprises are covered from 19 July 2030.

Sources

All sources were accessed and verified directly on EUR-Lex and the European Commission's published Working Plan on 29.09.2026; the Commission pages on the timing of the textile delegated act were last read on 13.10.2026. The Commission's ESPR Working Plan sets priorities and indicative timing, not binding deadlines, and may be revised. This is general information, not legal, financial or investment advice.

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