Most of what fashion brands hear about the Ecodesign for Sustainable Products Regulation (ESPR) is about the Digital Product Passport: the QR code, the data fields, the hosting. That is understandable. The passport is the visible part. But the regulation is not called the Digital Product Passport Regulation. It is an ecodesign law, and its main purpose is to change how products are made.
For a small fashion brand, that changes what preparation means. A passport is something you publish. Ecodesign is something you decide, in the sourcing plan and the tech pack, months before a garment exists. This article covers what ESPR's ecodesign requirements are, what the textile rules are likely to include, why decisions made this year matter and what a brand can sensibly do this season.
Two Kinds of Requirement, Not One
ESPR, Regulation (EU) 2024/1781, is a framework. It does not set rules for clothing directly. Instead, the Commission adopts a delegated act for each product group, and that act sets the ecodesign requirements for those products.
Those requirements come in two kinds:
- Performance requirements. Minimum or maximum levels, or qualitative rules, for aspects of the product such as durability, reparability, recycled content, resource use and environmental footprint. The Commission describes one of the aims as setting benchmarks for carbon and environmental footprints.
- Information requirements. What a product must disclose, and how. The Digital Product Passport is the main vehicle.
The passport tells a buyer or an authority about the product. A performance requirement decides whether the product can be placed on the market at all. That is the bigger lever, and it is the one that reaches back into design and sourcing.
Where Textiles Stand
Textiles are one of six priority product groups in the Commission's ESPR working plan, adopted in April 2025. The timeline is worth stating exactly, because it is widely misquoted:
The Commission plans to adopt the textile delegated act in Q4 2027. ESPR Art. 4(4) gives operators at least 18 months after the act enters into force, so the earliest realistic textile application is 2029. No binding textile DPP compliance date exists.
We cover the timeline and the claims circulating about it in more depth in our honest DPP implementation timeline, and which products fall in scope in textile DPP scope.
What the textile act will actually require is not settled. The European Commission's Joint Research Centre (JRC) is running the preparatory study, and its technical report on textiles analyses design options as well as passport content. Industry bodies are already lobbying on which performance requirements should come first, and some are arguing for fewer at this stage. The responsible position is to expect performance requirements alongside the passport, without assuming which ones.
One ESPR rule already applies to clothing: the ban on destroying unsold apparel and footwear, which has covered large companies since 19 July 2026. Small and micro enterprises are exempt, and medium-sized companies come into scope in 2030.
Why Decisions Made Now Matter
A garment that goes on sale in 2029 is often designed in 2028 and sourced from suppliers chosen well before that. Supplier relationships, especially at the mills, take seasons to change. A brand that waits for the final text before looking at how its products are made will be making those changes against a deadline rather than ahead of one.
The other reason is that the footprint of a garment is mostly decided before it is sewn. In a hoodie we model with ENVRT LAB™, dyeing carries just over half of the cradle-to-gate carbon and yarn production about a quarter. Sewing, the stage most brands know best, is a small share. The levers that move the number sit upstream, at the spinner, the knitter and the dyehouse. Our article on targeting the right hotspot stage explains why that pattern is common across apparel.
Carbon and Water Do Not Always Move Together
Any performance requirement built on environmental footprint is likely to look at more than carbon. The Product Environmental Footprint (PEF) framework that ESPR's textile work draws on treats water use as one of the most relevant impact categories for apparel.
That matters for design decisions, because carbon and water often pull in different directions. Moving a wet process such as dyeing can change its water scarcity impact a great deal, because the same litre of water is scarcer in some places than others, by much more or much less than it changes the carbon. A fibre change can cut water scarcity impact sharply and raise carbon a little. A brand that measures only carbon will make some of those decisions blind.
The practical implication is simple: look at both before committing to a change, and treat an option that improves one and worsens the other as a trade, not a win.
Be Realistic About the Levers
Generic eco-design advice tends to treat the supply chain as infinitely flexible. It is not, and a plan built on moves a brand cannot make wastes a season.
- Fibre comes from where it is grown or made. A brand can change the fibre it buys, but it cannot move a cotton field.
- A stage can only move to where that work is done. Moving dyeing closer to the sewing factory helps only if there is a dyehouse there that handles your fibre.
- Moving one stage changes the journey either side. Knitting fabric next to the sewing factory removes one transport leg and lengthens another.
- Freight mode depends on geography. Sea instead of road or air is only an option between countries with a coast, and it matters most on long legs.
- Energy is often the easiest ask. Whether a spinner, knitter or sewing factory runs on renewable electricity is a supplier conversation, not a supplier change.
Sorting options by how achievable they are is as important as sorting them by impact. Some changes your current suppliers can make. Some need a new supplier. Some are your call alone, such as how goods are shipped.
What a Brand Can Do This Season
None of this requires waiting for the delegated act.
- Measure your best-selling products individually. Product-level figures show where each one's footprint sits. A category average cannot.
- Find the hotspot stage for each. In most garments it is upstream of sewing.
- Ask suppliers two questions: where each stage is actually done, and what electricity each site runs on. Many brands do not know who dyes their fabric.
- Check how your long transport legs move. Road and air on a leg that could go by sea is a decision, not a fixed cost.
- Look at carbon and water together before committing to any change.
- Do not claim a change before it is made and measured. Under the Empowering Consumers Directive, generic environmental claims are already banned unless a brand can show recognised excellent environmental performance. Our guide to the claims now banned covers what to write instead. A planned improvement is not yet a fact you can publish.
How ENVRT Approaches Ecodesign
ENVRT LAB™ calculates climate impact (CO₂e) and water scarcity impact (AWARE) for each product, cradle to gate, aligned with ISO 14040 and ISO 14044 and the PEFCR for apparel and footwear. Because each figure is built from that product's own fibre composition, weights, processes and production countries, it shows where the footprint of that particular garment sits, stage by stage, on both measures.
That same product-level model is the basis for eco-design on the ENVRT Pro plan: a way to see how a brand's own product would change if it were made differently, recalculated by ENVRT LAB™.
If you want to see where your own products' footprint sits before the textile rules arrive, get in touch with the ENVRT team.
