Must I record the microfibre release from my textiles?

What you must do concretely

What is expected of you

Ecological design requirements may also address microfibre release

The ESPR works through delegated acts per product group: the regulation itself (Articles 5 to 7 of Regulation (EU) 2024/1781) sets the framework for performance and information requirements, and the specification for clothing and textiles follows in a separate act. Microfibre release — the shedding of small fibre particles during washing and wearing — is one of the topics that fits within that framework, because it directly affects the environmental impact of a textile product during its use phase. For a company with 10 to 100 employees, this means above all: staying alert to what the product-group-specific act ultimately regulates for clothing, and not anticipating an obligation that does not yet exist. At present, it is not certain whether, and in what form, microfibre release will become a mandatory information or performance element in the passport.

If a requirement comes into force, it must be accompanied by a measurement method

Article 39 of the ESPR determines that requirements are supported by reliable, accurate and reproducible test, measurement or calculation methods. This applies equally to microfibre release as to, for example, fibre composition: a company cannot itself determine how the release is measured, but follows the method designated in the applicable act or underlying standard. In practical terms, this means that a clothing brand or importer is well advised to monitor which laboratory method will be used for measurement as soon as it is known, rather than setting up its own test protocol now. More on how this works in general for values in the passport is on the page about the method by which values for the passport are measured.

Recording is for now mainly a matter of preserving source and process

As long as there is no established obligation to measure or report microfibre release, there is no legal duty to include data about this in the passport. What is practical though: if a manufacturer or fabric supplier already provides data on fibre composition, finishing or coatings, it is useful to know where that data comes from and how it was determined. This aligns with what is already relevant for the passport anyway, as described on the page about how fibre composition is determined. A company that has this foundation in order is better positioned when microfibre release becomes a concrete requirement.

Where things go wrong in practice

Anticipating a standard that does not yet exist. Some companies are already having test reports on microfibre release drawn up according to a method of their own choosing, on the assumption that this will automatically remain valid later. If the final delegated act designates a different method, that test report is no longer usable for the passport.

Confusion between synthetic and natural fibres. Microfibre release is often associated only with polyester and other synthetic fibres, while release of natural fibres (such as cotton) is also a subject of discussion within the broader textile policy. A company that only monitors the synthetic line in its collection may be missing part of the picture.

No distinction between product and treatment. A coating, wash treatment or impregnation can affect the release values of a fabric. If someone does not record chemical treatments separately, they cannot later trace which batch has undergone which treatment — while that could become relevant. See also the page about this on the reporting of chemical treatments.

Assumption that the supplier will handle this. An importer who sources textiles from a factory outside the EU sometimes assumes that the supplier provides microfibre data as standard. As long as this is not a legal obligation, this usually does not happen automatically, and the data is missing at the moment it is needed.

Passport and care label treated separately from each other. Microfiber release is closely linked to washing instructions: a product that sheds more fibers at higher temperatures or longer cycles may have a connection to this on the care label. Companies that manage the care label and the product passport as two separate documents risk that future requirements in this area will not align properly. More about this on the page on the relationship between the care label and the product passport.

What you can record

• Origin of yarns and fabrics, including the supplier and country of production, so that if there is a later question about microfiber release, it is quickly clear which batch supplied which material.
• Overview of applied chemical and mechanical treatments per product line (coating, impregnation, wash treatment), so that any link between treatment and release can be made later.
• Test reports that already exist, even if these were not prepared according to an EU method — keep them with a note about the method used and the laboratory, so that it can be assessed later whether they are usable.
• Contact details and agreements with suppliers about what data they can provide as soon as this becomes relevant, including any testing capacity they already have.
• A file per collection or product line with fiber composition and finishes, as a basic structure that can be easily expanded with release data as soon as that becomes mandatory.

Anyone who already maintains a template per product line with fiber composition, treatment and supplier data does not need to start from scratch with a new requirement. For the broader question of what data will together form the product passport, the page on what data is included in the product passport for clothing and textiles is a good starting point for aligning your own files with.