ESPR Delegated Act for Textiles: Requirements, Timeline, and Compliance

What Is the ESPR Delegated Act for Textiles?

The ESPR delegated act for textiles is a secondary legislative act that the European Commission will adopt under the authority granted by Regulation (EU) 2024/1781 (ESPR). ESPR itself is a framework regulation — it establishes the legal structure but does not set product-specific requirements. The product-specific requirements for each product category, including textiles, are set through delegated acts adopted by the Commission.

The textile delegated act will specify the ecodesign requirements that textile products must meet to be placed on the EU market, the data that must be included in the Digital Product Passport for each textile product, the conformity assessment procedures manufacturers must follow, and the transition period between adoption of the act and the mandatory compliance date. Until the delegated act is formally adopted and published in the Official Journal of the European Union, no textile-specific ESPR requirements are legally binding. The ESPR Working Plan 2025–2030, adopted on 16 April 2025, confirms textiles as a second-priority category with delegated act adoption expected in 2027.

Expected Requirements: What the Textile Delegated Act Will Cover

The Commission's preparatory study for the textile delegated act, published in 2023, identified the following as the most likely mandatory requirements. These are not yet legally binding but represent the current direction of the Commission's technical work.

The Commission is expected to publish a draft delegated act for stakeholder consultation before formal adoption. The consultation period typically lasts three to six months and allows manufacturers, importers, and industry associations to submit comments. The final requirements may differ from the preparatory study recommendations based on the outcome of the consultation.

The Textile Digital Product Passport: What Data Must Be Disclosed

The Digital Product Passport for textiles will be a machine-readable data record linked to each product via a QR code or NFC tag affixed to the product or its label. The DPP must be accessible to consumers, businesses, and regulatory authorities throughout the product's lifecycle. Based on ESPR Annex III and the preparatory study, the textile DPP is expected to contain the following data fields.

The DPP must remain accessible for the full lifecycle of the product — from the date it is placed on the EU market until at least ten years after the last unit of that model is placed on the market. The registry holding the DPP data must meet the technical requirements specified in the ESPR implementing acts on DPP registries, including data availability, interoperability, and security standards.

Who Is Affected by the ESPR Textile Delegated Act?

The ESPR textile delegated act will apply to any manufacturer, importer, or authorised representative placing textile products on the EU market. The obligations differ depending on the role of the economic operator in the supply chain.

EU manufacturers bear the primary compliance obligation. They must ensure their products meet the ecodesign requirements, compile the technical documentation, issue the EU Declaration of Conformity, affix CE marking (where required), and create and maintain the Digital Product Passport. EU manufacturers are directly responsible to national market surveillance authorities.

Non-EU manufacturers — including manufacturers in Bangladesh, India, Vietnam, China, Turkey, Morocco, Ethiopia, and South Africa — must appoint an EU Authorised Representative before placing products on the EU market. The Authorised Representative acts as the legal point of contact for EU market surveillance authorities and holds the technical documentation on behalf of the non-EU manufacturer. The non-EU manufacturer remains responsible for ensuring the product meets the ecodesign requirements and for providing the data required for the DPP.

EU importers have an independent obligation to verify that the products they import comply with the delegated act before placing them on the EU market. An importer who places a non-compliant product on the market can be held liable alongside the manufacturer. Importers must retain a copy of the EU Declaration of Conformity for ten years and must cooperate with market surveillance authorities.

EU distributors must verify that products carry the required CE marking and DPP data carrier before making them available on the market. Distributors who modify a product in a way that affects its compliance become responsible as manufacturers.

Timeline: When Does the Textile Delegated Act Apply?

The ESPR Working Plan 2025–2030 schedules the textile delegated act for adoption in 2027. The compliance date — the date by which all textile products placed on the EU market must comply — will be set in the delegated act itself, typically 18 to 24 months after adoption. This means the most likely compliance date for the textile delegated act is late 2028 to early 2029.

One obligation is already confirmed and does not require the delegated act: Article 25 of ESPR prohibits large enterprises from destroying unsold textiles and footwear from 19 July 2026. This applies to any large enterprise (as defined by EU accounting law) placing textiles or footwear on the EU market. SMEs receive a transitional period. This obligation is directly applicable under the ESPR framework regulation and is already in force.

How the Textile Delegated Act Differs from Existing EU Textile Rules

The EU already has several pieces of legislation affecting textile products, and the ESPR textile delegated act will sit alongside — and in some cases supersede — these existing rules.

The EU Textile Regulation (EU) 1007/2011 currently requires fibre composition labelling on textile products. The ESPR textile delegated act will expand on this by requiring full supply chain transparency, carbon footprint disclosure, and chemical substance declarations that go far beyond what the current labelling regulation requires. The Commission is expected to amend Regulation 1007/2011 to align it with the DPP requirements.

The EU REACH Regulation (EC) 1907/2006 already restricts certain hazardous substances in textile products. The ESPR textile delegated act will not replace REACH but will require manufacturers to actively disclose which REACH substances of concern are present in their products, rather than simply ensuring they are below permitted limits. This disclosure obligation in the DPP is a new and more demanding requirement than current REACH compliance.

The EU Extended Producer Responsibility (EPR) framework, which is being implemented in member states for textiles from 2025, creates financial obligations for producers to fund textile waste collection and recycling. EPR and ESPR are complementary — ESPR sets design requirements that make products easier to recycle, while EPR creates the financial infrastructure for collection and recycling at end of life.

Preparing for the Textile Delegated Act: A Compliance Roadmap

Manufacturers and importers who begin preparation now will be in a significantly stronger position than those who wait for the delegated act to be formally published. The preparation work required — supply chain mapping, carbon footprint calculation, chemical substance auditing, and DPP infrastructure setup — each takes several months for a manufacturer doing them for the first time.

The recommended preparation sequence is as follows. In the first phase (now through 2025), manufacturers should map their supply chains to identify all production stages and their locations, begin collecting carbon footprint data for their production processes, and audit their chemical use against the REACH substances of concern list. In the second phase (2025–2026), manufacturers should obtain a GS1 Company Prefix and assign GTINs to their products, select a DPP registry service, and begin compiling technical documentation. In the third phase (2026–2027, after the draft delegated act is published), manufacturers should finalise their DPP data sets to match the confirmed requirements, complete conformity assessment, and issue EU Declarations of Conformity. In the fourth phase (before the compliance date), manufacturers should mint DPPs for each SKU, affix QR codes or NFC tags to products and packaging, and brief EU buyers and importers.

Impact on Non-EU Textile Exporters

The ESPR textile delegated act will have significant implications for textile exporters from countries that supply large volumes of textile products to the EU market. Bangladesh, India, Vietnam, Turkey, Morocco, Ethiopia, and South Africa collectively account for a substantial share of EU textile imports. For manufacturers in these countries, the delegated act creates both a compliance obligation and a market access condition: products without a valid DPP will not be able to clear EU customs once the compliance date passes.

The data collection challenge for non-EU manufacturers is particularly acute. Many manufacturers in export-oriented textile industries do not currently track carbon footprint per production stage, water consumption in wet processing, or chemical substance use at the level of detail the DPP will require. Building the data collection infrastructure — and the supplier relationships needed to gather data from upstream suppliers — takes time and investment. Manufacturers who treat this as a 2028 problem will find themselves unable to comply on time.

EU buyers — retailers, brands, and importers — will increasingly require their suppliers to provide DPP-ready data as a condition of purchase orders. Manufacturers who can demonstrate DPP readiness ahead of the compliance date will have a competitive advantage in the EU market. Those who cannot will face the risk of losing EU contracts to competitors who are ready.