what is the difference between the ESPR and the European textile strategy

What you must do concretely

What is expected of you

The ESPR and the EU textile strategy are often mentioned in the same breath, but they are two different things. The ESPR — Regulation (EU) 2024/1781 — is a law. The textile strategy is not: it is a policy document from the European Commission that sets out the direction Europe wants to take with textiles, and what legislation still needs to be introduced or has already been adopted for that purpose. The ESPR is one of the instruments with which that strategy is implemented, but not the only one. For a company placing clothing or textiles on the market, that distinction is relevant because only legislation creates concrete obligations. The strategy itself creates no obligation; it indicates what is to come.

The ESPR is a framework regulation

Article 1 of the ESPR describes the subject matter and scope: the regulation establishes a general framework for requirements for products in the field of ecodesign, with the aim that products on the EU market become more sustainable, circular and energy-efficient. That framework applies in principle to almost all product groups, not only textiles. For a company of this size, this means that the ESPR itself does not yet impose concrete requirements on a garment or textile product — those requirements must still be worked out per product group. Anyone who now wants to know whether a collection falls under the scheme should first read which products from the clothing and textile sector fall under the ESPR.

The concrete requirements come via delegated acts

Article 4 and Article 8 of the ESPR provide that the Commission is empowered to establish delegated acts per product group, containing the content of the requirements that will then apply — think of sustainability, reusability, recyclability and the data that must be included in a digital product passport. For textiles and clothing, that act does not yet exist. This means that a company cannot yet determine what exactly must appear in the passport, only that a passport will come. Those who wonder why this structure was chosen and what that means in practice will find the background in what a delegated act is and why it determines what must be done.

Textiles are on the agenda, but the date is not yet fixed

Article 18 of the ESPR determines how the Commission prioritises which product groups come first. Textiles are listed in the work plan 2025-2030 as one of the first categories, with clothing containing eighty per cent or more textile fibres as the starting point. For a company, this means there is a clear signal that textiles receive priority, but no fixed date on which the obligation enters into force. A plan is not law; it can shift. The current status of that plan, and what is already fixed in it, is kept up to date on when the product passport becomes mandatory for clothing and textiles.

The textile strategy describes the broader package

In addition to the ESPR, the textile strategy also contains other components, such as extended producer responsibility for textiles — a separate process that does not run via the ESPR, but via separate legislation on waste management and financing thereof. For a company that wants one integrated picture of all obligations arising from the textile strategy, it is useful to know that the product passport and extended producer responsibility are two separate tracks, each with their own timeline and their own legislation. More on that connection is available in what extended producer responsibility for textiles is and whether it has anything to do with the product passport.

Where things go wrong in practice

A number of misunderstandings come up regularly among companies preparing for this legislation.

First, the textile strategy is sometimes read as a set of requirements that already apply, whereas it is a policy document without direct obligations. A buyer who already sets requirements on the basis of the strategy is ahead of legislation that does not yet exist.

Second, "the ESPR" is sometimes confused with "the product passport for textiles", whereas the ESPR is the framework and the passport for textiles only comes once the delegated act for textiles has been published. This is not yet the case.

Third, some companies assume that the date from the work plan 2025-2030 is already set as an obligation date, and plan processes accordingly. A work plan is an intention of the Commission, not a published act with an entry into force date.

Fourth, extended producer responsibility is sometimes confused with the product passport, with the result that a company thinks it has to comply with one obligation when it concerns two separate processes.

Fifth, there is uncertainty about which product categories already fall under the first tranche — for example accessories, workwear or interior textiles — because that question differs from the question of whether textiles in general fall under the ESPR. For those specific categories it is useful to look separately, such as at the product passport for shoes, bags and belts, company clothing and uniforms and household textiles such as curtains and bedding.

What you can record

• An internal overview of which product groups in the assortment fall under the first tranche of the work plan 2025-2030, separate from the question which fall under the broader textile strategy.
• A note on the distinction between ESPR obligations (product passport) and extended producer responsibility, so that both processes are not treated as one obligation.
• A log of publications by the Commission on the delegated act for textiles, so that changes in the planning are not missed.
• An overview of which product categories in your own assortment may be among the first to fall under the obligation, including samples and showroom models — see also whether a product passport is required for showroom samples that are not sold.
• A brief internal explanation, based on what a digital product passport for clothing and textiles contains, for colleagues in procurement and compliance who are not yet familiar with the distinction between strategy and legislation.