COMPLIANCE DEEP DIVE

EU Ecolabel for Textiles: Why It Skips EmpCo's Certification-Scheme Test

Published 02.10.2026 · Reading time ~10 min · by Lior Gabriel Graetz · LG Fashion Labs

EU Ecolabel, EmpCo certification schemes, and the Digital Product Passport are three different things that are easy to confuse. Our EmpCo guide already covers the certification-scheme test that private marks like OEKO-TEX and GOTS have had to clear since 27 September 2026. The EU Ecolabel is a different case entirely — EmpCo's own recital names it directly as an example of a label that skips that test altogether.

This guide covers what the EU Ecolabel for textiles actually is, why it sits in a different legal lane under EmpCo than a private certification scheme, what its 28 textile criteria actually require, and how ESPR itself already links it to the textile delegated act, not yet adopted, behind the Digital Product Passport.

31 Dec 2028

The EU Ecolabel textile criteria's validity, just extended by Commission Decision (EU) 2026/66 — with the textile revision now timed to follow ESPR's textile delegated act.

28 criteria

Set by Commission Decision 2014/350/EU, from fibre sourcing to a denim-sandblasting ban. Which ones apply depends on the product's fibres, components and type.

Public authority, not a certification scheme

EmpCo's own recital names Regulation (EC) No 66/2010 as an example of a label "established by public authorities" — a different legal route from the certification-scheme test OEKO-TEX and GOTS must clear.

1. What the EU Ecolabel actually is

The EU Ecolabel is a voluntary EU-wide ecolabel scheme governed by Regulation (EC) No 66/2010 — the "flower" logo awarded to products that meet a fixed set of criteria for reduced environmental impact across their life cycle. For textiles, those criteria were set by Commission Decision 2014/350/EU, covering "textile clothing and accessories" and "interior textiles" containing at least 80% textile fibres by weight, plus the fibres, yarns, fabrics and knitted panels used in them, the non-fibre elements incorporated into them (zips, buttons and other accessories, membranes, coatings, laminates) and, as a separate item, woven or non-woven cleaning products for the wet or dry cleaning of surfaces and the drying of kitchenware. Single-use disposable items, floor coverings (covered by a separate Decision) and fabrics forming part of structures for outdoor use are explicitly excluded from this product group, as are garments, fabrics and fibres containing electrical devices or electrical circuitry, or devices or impregnated substances designed to sense or react to changes in ambient conditions.

A brand doesn't get the EU Ecolabel from a scheme owner's own certifier — it applies to a "competent body" designated by an EU Member State (Article 4 of Regulation (EC) No 66/2010). Where a product originates in a single Member State, the application goes to that state's competent body; where it originates in the same form in several, the applicant may choose any one of them; for non-EU-origin products, the application goes to a competent body of any Member State in which the product is to be or has been placed on the market (Article 9). Member States designate those bodies — within government ministries or outside them — and must ensure they are independent and neutral (Article 4). What matters under EmpCo, though, isn't who staffs the competent body: it's that the label itself was established by an EU regulation rather than by a private scheme owner.

2. Why EU Ecolabel skips EmpCo's certification-scheme test

EmpCo (Directive (EU) 2024/825) inserted a new point into Annex I of the Unfair Commercial Practices Directive (UCPD), banning the display of any sustainability label that is "not based on a certification scheme or not established by public authorities." That wording offers two separate, alternative routes to stay legal (recital 7 confirms this reading) — and for the public-authority route the Directive's own recital gives named examples:

Recital 7, Directive (EU) 2024/825

"Examples of sustainability labels established by public authorities are logos awarded when complying with the requirements of Regulations (EC) No 1221/2009 [EMAS] or (EC) No 66/2010 [the EU Ecolabel] of the European Parliament and of the Council."

That's a direct, named example — not an inference. (Recitals explain how the operative text is meant to be read rather than being operative themselves, but this one is explicit about the category.) OEKO-TEX and GOTS, as private certification schemes, have to clear the Directive's separate four-part "certification scheme" test (Article 2(r) UCPD): a scheme open to all traders willing and able to comply, on transparent, fair and non-discriminatory terms; requirements developed with experts and stakeholders; a procedure for non-compliance; and compliance monitoring by a third party independent from both the scheme owner and the trader. Both certifiers have also put out their own EmpCo material for the businesses that use their labels — GOTS a claims-review guidance document (Version 1.0, September 2026), OEKO-TEX an EmpCo Recommendation for label users plus a press release of 19 August 2026 on how it restructured its governance in response to EmpCo. The EU Ecolabel doesn't need to make that case at all — it qualifies through the other route, because it was established by an EU regulation (Regulation (EC) No 66/2010) rather than by a private scheme owner, and recital 7 names it as such.

3. The catch: it only backs the claims it actually covers

Holding the EU Ecolabel doesn't give a brand a free pass on every green marketing claim. EmpCo separately bans "generic environmental claims" — words like "eco-friendly," "green" or "ecological" without a clear specification — unless the trader can demonstrate "recognised excellent environmental performance" relevant to the claim (Annex I, point 4a UCPD; the term itself is defined in Article 2(s), and compliance with Regulation (EC) No 66/2010 is one of the things it covers). The Directive's own recital draws the line precisely:

Recital 10, Directive (EU) 2024/825

"For example, a generic environmental claim such as 'energy efficient' could be made based on recognised excellent environmental performance in accordance with Regulation (EU) 2017/1369. By contrast, a generic environmental claim such as 'biodegradable' could not be made based on recognised excellent environmental performance in accordance with Regulation (EC) No 66/2010, insofar as there are no requirements for biodegradability in the specific EU Ecolabel criteria related to the product in question."

Applied to textiles: the Ecolabel's 28 criteria say a great deal about restricted chemicals, fibre sourcing and durability — so a brand can lean on it for claims that match those criteria. The textile criteria do contain biodegradability requirements, but they concern chemicals used in production (such as sizing preparations, spinning additives and surfactants) or, for non-fluorinated repellent finishes, are one of two alternatives (biodegradable or non-bioaccumulative) — none requires the finished garment itself to be biodegradable. So, on recital 10's own logic, holding the Ecolabel does not substantiate a generic "biodegradable" claim about the garment, however legitimately it holds the mark. Each generic claim is assessed against what the certification actually tested, not against the Ecolabel's general reputation. Recital 10 adds a second limit that matters for fashion: a trader "should not make a generic claim such as 'conscious', 'sustainable' or 'responsible' based exclusively on recognised excellent environmental performance", because such claims relate to other characteristics in addition to environmental ones, such as social characteristics — so the Ecolabel is not automatic cover for a generic "sustainable" claim either.

DPP AUDIT

A voluntary label and a mandatory passport are not the same project.

Whether or not you pursue the EU Ecolabel, ESPR's Digital Product Passport is expected to apply to textiles only once the delegated act is adopted and its application date arrives (normally not earlier than 18 months after its entry into force, ESPR Article 4(4)). We help you build the underlying data once, correctly. Under NDA.

Start Your DPP Audit

4. EU Ecolabel vs. the DPP — and how ESPR already connects them

The EU Ecolabel and the Digital Product Passport are built on different legal foundations, and neither is a substitute for the other. The Ecolabel (Regulation (EC) No 66/2010) is opt-in: a brand chooses to apply, meets the criteria, and can display the flower logo — or doesn't, and simply sells the product without it. The DPP (ESPR, Regulation (EU) 2024/1781) works differently: once a delegated act requires a passport for a product group, products in that group can only be placed on the market or put into service if one is available (Article 9(1)). The Commission may exempt certain product groups (Article 9(4)), but only where technical specifications for the passport are not available in relation to the essential requirements in Articles 10 and 11, or where other Union law includes a digital information system that the Commission considers achieves the objectives in Article 9(3), points (a) and (b). ESPR's DPP provisions contain no exemption tied to holding a label, and the Article 41(4) presumption (below) only works to the extent the Ecolabel criteria cover a requirement — so holding the Ecolabel doesn't exempt a product from DPP obligations, and skipping it creates no DPP problem either.

They are not walled off from each other, though: ESPR itself ties them together in at least two places that matter here. The first is a presumption of conformity:

Article 41(4), Regulation (EU) 2024/1781 (ESPR)

"Products covered by a delegated act adopted pursuant to Article 4 which have been awarded the EU Ecolabel pursuant to Regulation (EC) No 66/2010 shall be presumed to comply with the ecodesign requirements set out in that delegated act to the extent that those requirements are covered by the EU Ecolabel criteria established pursuant to Article 8 of that Regulation."

The second is the passport itself. Annex III says the delegated acts shall identify information that manufacturers may include in the passport, "including information on specific voluntary labels applicable to the product" — and that this "shall include whether an EU Ecolabel has been awarded to the product in line with Regulation (EC) No 66/2010."

The Commission's December 2025 Decision extending the textile Ecolabel criteria's validity points to the same link, and explains why the revision is to be finalised only after the delegated act is issued:

Recital 8, Commission Decision (EU) 2026/66

"For textile products, the ongoing revision needs to be finalised after the related delegated act under Regulation (EU) 2024/1781 of the European Parliament and of the Council [ESPR] is issued, to ensure consistency between the requirements set up in such delegated act and the EU Ecolabel criteria, considering the possibility for the EU Ecolabel to be used in the future as proof of compliance with the ecodesign requirements set out in that delegated act to the extent that those requirements are covered by the EU Ecolabel criteria."

(The Official Journal's English text reads "as a as proof" here — an evident typo, quoted above as "as proof".) Put together: the presumption in Article 41(4) is already law, but it only works "to the extent that" a delegated act's requirements are covered by the Ecolabel criteria — and neither the textile delegated act nor the revised textile criteria exist yet. Until that delegated act is adopted, the presumption has nothing to attach to for textiles, and the two schemes simply run in parallel. No adoption date has been fixed for the textile (apparel) delegated act. The Commission's 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.

5. What's inside the 28 textile criteria

Commission Decision 2014/350/EU sets out 28 criteria for the "textile products" group, which its Annex arranges into six sub-categories. Which of them apply depends on what the product is made of: the fibre-specific criteria apply to the fibres in the product (some are exempt, such as fibres under 5% of its weight, and padding or lining), for instance, and the wash-resistance criterion applies only to cleaning products.

Sub-category (per the Decision's Annex)	Criteria	Covers
Textile fibres	1–9	Separate rules for cotton, flax/bast fibres, wool, acrylic, elastane, polyamide, polyester, polypropylene, and man-made cellulose fibres (viscose, modal, lyocell) — e.g. cotton must meet organic or integrated-pest-management content thresholds plus pesticide restrictions and traceability.
Components and accessories	10–12	Fillings, coatings/laminates/membranes, and accessories (zips, buttons and similar).
Chemicals and processes	13–16	A Restricted Substance List; substitution of hazardous substances in dyeing, printing and finishing; energy efficiency of washing, drying and curing; and treatment of emissions to air and water.
Fitness for use	17–25	Dimensional changes in washing and drying; colour fastness to washing, perspiration, rubbing and light; wash resistance of cleaning products; resistance to pilling and abrasion; and durability of function.
Corporate Social Responsibility	26–27	Criterion 26, "Fundamental principles and rights at work" (the ILO Core Labour Standards, the UN Global Compact and the OECD Guidelines for Multinational Enterprises, to be observed at cut/make/trim production sites and verified by a third party), and Criterion 27: manual and mechanical sandblasting to achieve distressed denim finishes is not permitted.
Supporting information	28	The optional wording that may appear in the text box on the Ecolabel itself, for example "Made with organic cotton. Only GMO-free cotton used" where organic content is above 95%.

Where the EU Ecolabel differs from OEKO-TEX and GOTS under EmpCo isn't the length of its criteria list but its legal route: it is the label created within an EU regulation and awarded through competent bodies that Member States designate, rather than a mark owned and run by a private scheme owner.

6. What this means for your brand

If you already hold the EU Ecolabel for a textile line, the question that OEKO-TEX and GOTS marks raise under EmpCo — whether the scheme behind the mark clears the certification-scheme test — doesn't arise for you, because the Directive's own recital names the EU Ecolabel as a label established by public authorities. What still applies to you, as to every trader, is the claim-specificity rule (Annex I, point 4a UCPD): don't extend the Ecolabel to back a generic claim its own criteria don't actually address. If you don't currently hold it and are weighing whether to apply, treat it as a genuinely separate decision from your DPP work — pursuing the Ecolabel can strengthen specific substantiated claims today, and under ESPR Article 41(4), once a textile delegated act exists, an Ecolabelled product will be presumed to meet that act's ecodesign requirements to the extent the Ecolabel criteria cover them — but it is not a prerequisite for DPP compliance, and nothing in ESPR makes it one.

Frequently asked questions

Does the EU Ecolabel have to pass EmpCo's certification-scheme test like OEKO-TEX or GOTS? +

No. Point 2a of Annex I to the Unfair Commercial Practices Directive (inserted by EmpCo) bans a sustainability label unless it is based on a certification scheme or established by public authorities — two separate, alternative routes. Recital 7 of Directive (EU) 2024/825 names the EU Ecolabel, awarded under Regulation (EC) No 66/2010, as a textbook example of a label "established by public authorities." That means it does not need to separately satisfy Article 2(r)'s four-part certification-scheme test (openness to all willing and able traders on transparent, fair and non-discriminatory terms, requirements developed by the scheme owner in consultation with experts and stakeholders, a non-compliance procedure, and independent third-party monitoring) the way a private scheme like OEKO-TEX or GOTS does.

Does holding the EU Ecolabel let me make any green marketing claim I want? +

No. EmpCo's recital 10 gives the EU's own example of the limit: a generic claim like "energy efficient" can be supported by top performance under EU law such as class A under Regulation (EU) 2017/1369 (energy labelling), but a claim like "biodegradable" could not be supported by EU Ecolabel compliance for a product whose specific Ecolabel criteria don't include a biodegradability requirement. Under Annex I, point 4a of the Unfair Commercial Practices Directive, the "recognised excellent environmental performance" has to be relevant to the claim being made — holding the Ecolabel lets you substantiate claims that correspond to what its 28 textile criteria actually cover, not any green claim in general. Recital 10 adds that generic claims such as "conscious", "sustainable" or "responsible" should not rest exclusively on recognised excellent environmental performance, because such claims relate to other characteristics in addition to environmental ones, such as social characteristics.

Is the EU Ecolabel the same thing as the Digital Product Passport? +

No, and they run on entirely different legal tracks. The EU Ecolabel (Regulation (EC) No 66/2010) is a voluntary scheme a brand opts into for products that clear a fixed set of environmental and social criteria; the DPP (ESPR, Regulation (EU) 2024/1781) will be a mandatory requirement to have a passport for every product group whose delegated act requires one, certified or not. Holding the Ecolabel does not exempt a product from DPP obligations, and not holding it does not create any DPP problem. The two are nonetheless linked in the law: ESPR Article 41(4) presumes that Ecolabelled products comply with a delegated act's ecodesign requirements to the extent the Ecolabel criteria cover them, and Annex III provides that the delegated acts shall identify the voluntary-label information that manufacturers may include in the passport, including whether an EU Ecolabel has been awarded. For textiles none of that can take effect until the delegated act exists — and Commission Decision (EU) 2026/66 is why the Ecolabel's own textile revision is waiting for it.

Why was the EU Ecolabel's validity for textile products just extended to 2028? +

Commission Decision (EU) 2026/66 of 23 December 2025 extended the validity of the textile products Ecolabel criteria (set in Commission Decision 2014/350/EU) from its previous 31 December 2025 expiry to 31 December 2028. The Commission's own recitals give the reasoning: the ongoing revision of the textile criteria has to be finalised after ESPR's textile delegated act is issued, to keep the Ecolabel criteria consistent with the ecodesign requirements that act sets — including the stated possibility of the Ecolabel being usable as evidence of compliance with it — and the extension gives time to finish that revision while the current criteria stay valid in the meantime.

What does a fashion brand actually have to do to get the EU Ecolabel for a textile product? +

Apply to a national "competent body" designated under Article 4 of Regulation (EC) No 66/2010 — a competent body of the Member State where the product originates (or of one of them, if it originates in the same form in several), or, for non-EU products, of any Member State in which it is to be or has been placed on the market (Article 9). The product must then meet the criteria in Commission Decision 2014/350/EU for the "textile products" group that apply to it (the Decision sets 28, including Criterion 28 on optional label wording), covering fibre-specific sourcing and chemical restrictions (applying to the fibres the product contains, with exemptions such as fibres under 5% of its weight and padding or lining), a restricted substance list, dyeing and finishing chemicals, energy-efficiency measures and emissions limits in processing, durability and colourfastness performance testing, a labour-rights criterion (Criterion 26), and, for denim, a ban on sandblasting to create distressed finishes (Criterion 27).

Sources

EU Ecolabel — frameworkRegulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU Ecolabel. Article 4 (competent bodies); Article 9 (award procedure, application routing for non-EU-origin products). CELEX 32010R0066 ↗
EU Ecolabel — textile criteriaCommission Decision 2014/350/EU of 5 June 2014 establishing the ecological criteria for the award of the EU Ecolabel for textile products, as amended by Decisions (EU) 2017/1392, (EU) 2020/1805 and (EU) 2026/66 (consolidated version of 6 January 2026, which is the text read here). Article 1 (product-group scope and exclusions); Annex (28 criteria, including Criterion 26 on labour rights and Criterion 27 banning denim sandblasting). CELEX 02014D0350-20260106 (consolidated) ↗
EU Ecolabel — 2028 validity extensionCommission Decision (EU) 2026/66 of 23 December 2025 amending Decisions 2014/350/EU, 2014/391/EU, (EU) 2016/1332, (EU) 2016/1349 and (EU) 2017/176 as regards the period of validity of the EU Ecolabel criteria and the related assessment and verification requirements for textile products, bed mattresses, furniture, footwear and wood-, cork- and bamboo-based floor coverings. Recital 8 (the textile revision to follow ESPR's delegated act); Recitals 9–10 (reasons for the extension and the 2028 date); Article 1 (new 31 December 2028 validity date for textile products). CELEX 32026D0066 ↗
EmpCo — the certification-scheme testDirective (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information (amending, among others, the Unfair Commercial Practices Directive, UCPD). Recital 7 (EU Ecolabel as an example of a "public authorities" label); Recital 10 (claim-specificity limit, the "biodegradable" example); Annex, points 2a and 4a (the Annex I insertions: sustainability labels; generic environmental claims); Article 2, points (q)–(s) UCPD as amended (definitions of sustainability label, certification scheme, recognised excellent environmental performance). See our EmpCo certification-scheme guide for the private-scheme side of this same test. CELEX 32024L0825 ↗
ESPR — the Ecolabel linksRegulation (EU) 2024/1781 of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC (consolidated version, which incorporates the corrigendum published in OJ L 90356 of 28.4.2025 and is the text read here). Article 9(1) and (4) (placing on the market only with a passport; product-group exemptions); Article 41(4) (presumption of conformity for Ecolabelled products); Annex III, final paragraph (voluntary labels in the passport, including whether an EU Ecolabel has been awarded). CELEX 02024R1781-20240628 (consolidated) ↗
Commission — textile delegated act timelineEuropean Commission, "Textile Apparel and the Digital Product Passport (DPP)" page — indicative timeline entry "Q4 2027: Planned adoption of the ESPR Delegated Act for textiles" (the Commission's general DPP page groups textiles, aluminium and tyres under "Q3–Q4 2027"; both are marked indicative). single-market-economy.ec.europa.eu ↗
OEKO-TEX® — EmpCo materialOEKO-TEX®, press release "OEKO-TEX® strengthens its governance and prepares for the future", 19 August 2026, and the "EmpCo Recommendation" page of its Labelling Guide. Press release ↗ · EmpCo Recommendation ↗
GOTS — EmpCo claims guidanceGlobal Standards gGmbH, "Practical guidance for reviewing GOTS/GRTS-related claims and communications", Version 1.0, September 2026 (includes an "EmpCo Compliance Review" step). global-standards.org ↗

EU legal texts were read in the Official Journal versions published by the EU Publications Office (EUR-Lex) — for Decision 2014/350, the consolidated version of 6 January 2026, and for Regulation (EU) 2024/1781, the consolidated version incorporating the corrigendum of 28 April 2025; the European Commission, OEKO-TEX and GOTS pages were accessed on 02.10.2026; the Commission pages on the timing of the textile delegated act were last read on 13.10.2026. This is general information, not legal, financial or investment advice.