Which products in the clothing and textile industry fall under the ESPR?

Clothing and textiles fall under the ESPR, but without concrete requirements yet

Clothing and textile products fall within the scope of the ESPR (Regulation (EU) 2024/1781), because Article 1 of that regulation covers almost all physical products placed on the market or put into service in the European Union. Textiles and clothing are not excluded anywhere in Article 1, and therefore fall within the scope of the regulation in principle. However, this does not mean that concrete product requirements apply now. The ESPR is a framework regulation: it regulates how and according to which procedure requirements are established, but the requirements themselves only come per product group, via a separate delegated act. Such a delegated act does not yet exist for clothing and textiles.

Who this applies to, and what it does not

The broad definition in Article 1 covers clothing, footwear, bags and accessories, and also textiles for domestic use such as bedding and curtains: they are all physical goods placed on the market, and therefore products within the meaning of Article 2 of the ESPR. Outside the scope of the regulation fall categories that Article 1 explicitly names, such as food, animal feed, medicines and live plants, animals and micro-organisms, and vehicles that already fall under their own type-approval rules. For the textile sector, that list of exceptions is not relevant: clothing and textiles are not among the excluded categories.

More important than the question of whether something falls under the ESPR is the question of whether a concrete requirement already applies. For textiles, this is not currently the case. The work plan by which the European Commission indicates which product groups come first mentions clothing of which eighty percent or more of the weight consists of textile fibres as the first focus within the textile sector. This is an indication of the order in which delegated acts are prepared, not text from the ESPR itself. Other textile products, or clothing with a lower proportion of textile fibres, may come into focus at a later date, but nothing has been decided on this yet.

When the first requirements will be in place is still uncertain

No delegated act has yet been published that sets concrete ecodesign requirements for clothing or textiles. Until such a delegated act is in place, no mandatory requirements apply from the ESPR itself for this product group: no mandatory digital product passport, no mandatory information about repair or origin, no mandatory sustainability requirements. What does exist is a timetable in the Commission's work plan: a delegated act for textiles is foreseen in it, with clothing with a high proportion of textile fibres as the first component. A precise date on which obligations take effect cannot be determined on the basis of Article 1 and Article 2 of the ESPR, and is therefore not mentioned here. Once the delegated act for textiles has been published, that delegated act itself will determine the exact product description and entry-into-force date.

What this means for those working in the sector

For a clothing brand, importer or private label, this means in concrete terms: at this moment, the ESPR does not impose any obligation to already comply with specific requirements, simply because those requirements for textiles do not yet exist. The first step is therefore not action based on an obligation, but orientation: to determine whether your own assortment falls within the category that the work plan mentions first, namely clothing with a high proportion of textile fibres. The second step is preparation without urgency: to put in order data on material composition, origin, production process and any repair possibilities, so that this information is available as soon as a digital product passport becomes mandatory. The third step is to follow: the publication of the delegated act for textiles is the moment when it becomes clear which products exactly fall under the obligation, which data are mandatory and from when. Until that time, waiting and preparing is a more realistic approach than already making a passport mandatory that does not yet need to be legally required.

What this is based on: Article 1 and Article 2 of the ESPR

That clothing and textiles fall within the scope, follows from Article 1 of the ESPR (Regulation (EU) 2024/1781), which describes the scope of the regulation in broad terms and names the exceptions to it. That textile products are regarded as a "product" within the meaning of the regulation, follows from the definitions in Article 2 of the same regulation. That no concrete requirements yet apply to textiles, follows from the logic of the ESPR itself: the regulation establishes the framework in Article 1, but leaves the specification per product group to separate delegated acts that still need to be adopted.

Anyone wishing to check whether a specific product falls within the first intended category can already consult their own product records on the proportion of textile fibres in the product. Once the European Commission publishes the delegated act for textiles, this page will be updated with the exact product description and the date on which the obligation takes effect.

What this is based on

The regulation itself is available on EUR-Lex. We provide references for each statement; you do not need to take our word for it.

What you must do concretely

What is expected of you

The ESPR (Regulation (EU) 2024/1781) is not a textile law. It is a framework regulation that applies to almost all physical products placed on the European market, and that establishes the basis for requirements that will later be developed per product group. Article 1 of the ESPR describes the subject matter and scope: the regulation establishes a framework for ecodesign, with the aim of making products more sustainable, reusable, repairable and information-rich. Clothing and textiles are not named as a separate chapter — they fall under the general definition of products, unless a delegated act specifically designates them. What that means in practice can be broken down in a few expected steps.

Check whether your own product falls under "textiles" as the regulation means it

Article 2 of the ESPR provides definitions of concepts such as product, model and value chain, but the precise scope of "textile products" will only come with the delegated act for this sector. For a company with 10 to 100 employees, this means that the first question is not "do I have to do something", but "which part of my assortment falls under the definition that will ultimately be established". Clothing and most clothing accessories are straightforward; for borderline cases such as footwear, bags or belts, that is less obvious. Anyone in doubt whether a particular item counts reads what is precisely known on the page about the product passport also applies to shoes, bags and belts.

Make a distinction between the ESPR as a framework and the textile-specific implementation

The ESPR itself does not impose a passport requirement on a specific garment. It makes it legally possible for the European Commission to do so via a delegated act. For business operations, it is practical to keep this distinction clear: the regulation is the framework, the act is the implementation that actually establishes obligations per product group. What a delegated act is precisely and why it determines what a company is asked to do is explained on the page what is a delegated act and why does it determine what I have to do. Without that act for textiles, there is no concrete obligation yet; as soon as it exists, this target group will be named as one of the first sectors.

Map out your own product categories, including the less obvious ones

A brand or importer often does not sell only clothing in the conventional sense. Work clothing, uniforms, curtains, bedding and promotional textile articles often form part of the same assortment or the same enterprise, but whether they fall under the same rules is not automatically established. For occupational clothing, that is a separate question, which is addressed on do I also need to create a product passport for workwear and uniforms; for interior textiles on the product passport also applies to household textiles such as curtains and bed linens. An assortment list in which these categories are listed separately makes it easier to quickly determine later which part of the collection comes into focus.

Keep track of when and for which product group the obligation actually takes effect

Because the date of the delegated act is not yet fixed, it is practically not so much an obligation to implement something now, but to monitor when that changes. The work plan names clothing with a high percentage of textile fibres as the first category, but that is an expectation, not an established date. An overview of what is known about this can be found on when does the product passport become mandatory for clothing and textiles.

Where things go wrong in practice

A common situation is that a company confuses the ESPR with the broader European textile strategy and thinks that all announced measures — from producer responsibility to a ban on the destruction of unsold clothing — run through one and the same regulation. This leads to confusion about which obligation comes from which rule.

A second situation: an importer assumes that only "clothing" in the strict sense counts, and forgets that accessories, footwear or bags may be included in the same delegated act or are deliberately treated separately.

A third situation is that companies with a small team think that the size of the business determines whether the product passport will apply. The ESPR links the obligation to the product and the product group, not primarily to business size, although there may be other considerations for smaller market participants.

A fourth situation: samples, showroom models and unsold trial collections are sometimes lumped together with the rest of the assortment, while the question of whether such items fall under the rules may differ from products that are actually brought to market.

A fifth situation is that a brand waits with all preparation until the delegated act is in place, and then discovers on the first mentioned date that its own product category breakdown does not align with the categories used by the act.

What you can record

An overview of the company's own product categories (clothing, accessories, workwear, interior textiles, samples) with a note for each category on whether it is expected to fall under the ESPR's textile definition.
A brief note on the difference between the ESPR as a framework and the delegated act as its implementation, so that new staff do not have to work out this distinction each time.
A reference or reading list to the pages on what the ESPR changes for the clothing and textile industry and on what is the difference between the ESPR and the European textile strategy, so that everyone internally uses the same source.
A standing agreement on who follows the Commission's work plan and when an update is shared within the company.
A note on samples and showroom models on the question of whether and when these are included in the company's own preparation, with a link to the explanation on samples and showroom models.
For companies unsure whether their size makes a difference: a reference to the page does the product passport also apply to small businesses in the company's own knowledge file.

This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.

Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections are given priority.