Which chemical treatments must I report?

What you must do concretely

What is expected of you

The ESPR itself does not mention "chemical treatments" as a separate, distinct data point to be reported. What it does state is that the delegated act per product group — for clothing and textiles still to be published — will establish the performance and information requirements, and that these can expressly extend to substances used during the production or finishing of a product (Articles 5 to 7 of the ESPR, Regulation (EU) 2024/1781). Chemical treatments — such as water-repellent coatings, crease-resistant finishes, antimicrobial treatments, bleaching or dyeing processes with specific auxiliaries — fall within that possibility, but the precise list of what must be reported is not yet available.

Record which treatments have been applied

In practical terms, for a company with 10 to 100 employees, there is already scope for gaining an advantage by inventorying which chemical finishes are applied to which product lines. Companies working with multiple garment manufacturers or laundries often have different finishing recipes per supplier. This information is usually scattered among the manufacturer and does not automatically come with an order confirmation or invoice.

Aligning with the fibre information that is already mandatory

Chemical treatments rarely stand alone: a water-repellent coating belongs to a specific fibre composition, a crease-resistant treatment to a different fabric. If you already systematically record fibre composition using the approach described under how I record the fibre composition in the product passport, you can expand that same structure with a field for applied treatments. This will save work once the delegated act becomes concrete.

Taking account of the measurement method once it is established

For some chemical treatments — particularly those with a potential effect on microfibre release or biodegradability — a link with a measurement method is appropriate. At present, there is no established method specifically for chemical treatments in clothing and textiles; however, the ESPR does require in Article 7 that requirements be substantiated with measurable, verifiable data. How this works in practice will depend on the method established per product group, as described under the method for measuring values for the passport.

Determining what is and is not commercially sensitive

Part of the information on chemical treatments — for example, the precise composition of a coating or a supplier's recipe — may be commercially sensitive. Article 10 of the ESPR (Regulation (EU) 2024/1781) provides for a distinction between data that is publicly accessible and data that is visible only to certain parties, such as supervisory authorities. For a company that already documents chemical finishes, it is worthwhile to determine in advance which part of that documentation will later appear in the passport and which part will remain internal to the company. More on this can be found under whether commercially sensitive data on clothing and textiles must be made publicly available.

Where things go wrong in practice

An importer has a pair of trousers finished by a third party after the fabric has already been purchased from the garment manufacturer. No one in the chain records the fact that a chemical treatment has been applied after fibre production, because organisationally it belongs to a different link in the chain.

A brand works with a fixed laundry for a crease-resistant finish, but regularly switches suppliers for the base textile. The finish is thus applied to constantly changing fibre compositions, without a separate note being made for each combination of which treatment applies to which batch.

A company assumes that a chemical treatment that is "standard" in the sector — such as a crease-resistant finish on shirts — does not need separate mention, because "everyone does it". This is an assumption about the future content of the delegated act that cannot be substantiated at present.

A private label client asks the manufacturer for a list of chemicals used, but receives a vague or incomplete response because the manufacturer itself works with a subcontractor for finishing. The information stops at the first link in the chain, while the treatment takes place further down.

A company documents the chemical treatment, but not in which language or format that documentation should ever reach the product passport, so when the delegated act is published, everything must be retranslated or rewritten. That also touches on the question that arises in the language in which the data in the product passport for clothing appear.

What you can record

• An overview per product line of which chemical treatments have been applied (type of treatment, purpose, supplier or executing party).
• The link in the chain where the treatment takes place, separate from where the fibre production or manufacturing takes place.
• Contact details and responsibilities of the party carrying out the treatment, so that inquiries do not always have to go through an intermediary.
• A separate note of which information about the treatment is considered commercially sensitive and which is not, in anticipation of the categorization that follows from Article 10 of the ESPR.
• A link in own administration between fibre composition and applied treatment, so that both data can later be included together in the product passport.
• Documentation of how often and when a treatment is repeated or modified, relevant to the question that arises in how often the data in the product passport are updated.

Once the delegated act for clothing and textiles has been published, this will be supplemented with which chemical treatments must specifically be reported and in what manner.