ESPR Explained: The EU Ecodesign Law for Garment Suppliers
The Ecodesign for Sustainable Products Regulation is the law behind the EU Digital Product Passport. This page explains what it does, how it reaches clothing, and what it means for a factory that exports to the EU.
Written by the DPPLive Team · Last updated: 9 November 2026
| Detail | |
|---|---|
| Legal act | Regulation (EU) 2024/1781, published in the Official Journal on 28 June 2024 |
| In force | 18 July 2024; applies directly in every Member State |
| How rules arrive | Delegated acts per product group (Art. 4), based on the product aspects in Art. 5 |
| Earliest application | Not earlier than 18 months after a delegated act enters into force, except in duly justified cases (Art. 4(4)) |
| Textiles | Priority group in the Commission's 2025–2030 Working Plan (April 2025); apparel delegated act expected 2027 |
| Digital Product Passport | Articles 9–14; EU registry set up under Art. 13 (deadline 19 July 2026), live since 20 July 2026 |
| Unsold goods | Art. 24 disclosure; Art. 25 ban on destroying unsold clothing and footwear from 19 July 2026 (medium-sized firms from 19 July 2030; micro and small firms exempt) |
| Penalties | Set by each Member State; must be effective, proportionate and dissuasive (Art. 74) |
A Framework That Sets Product Rules
ESPR replaced the old Ecodesign Directive, which covered mainly energy-related products, with a regulation that can cover almost any physical product sold in the EU. It does not list requirements for clothing itself. Instead, Article 5 names the product aspects the Commission may regulate, including:
- durability, reliability, reusability and repairability;
- the presence of substances of concern;
- energy, water and resource use and efficiency;
- recycled content, recyclability and remanufacturing;
- carbon and environmental footprint, and expected waste generation.
Under Article 3, products covered by a delegated act may only be placed on the EU market if they meet its requirements.
How ESPR Reaches Garments: the Delegated Act
Each product group gets its own delegated act. The Commission's 2025–2030 Working Plan, adopted in April 2025, put textiles and apparel first among final products. Preparatory work presented by the Commission's Joint Research Centre focuses the act on apparel, including clothing accessories; footwear is to be looked at again in the Working Plan's mid-term review.
The act is expected in 2027. It will set the performance rules, the information that must be shared, and the passport's content and granularity (model, batch or item). Under Art. 4(4) it can apply no earlier than 18 months after entering into force, so obligations for clothing are unlikely before 2028–2029. See the DPP timeline and deadlines by sector.
The Digital Product Passport Part of ESPR
Articles 9–14 create the Digital Product Passport: a product-level data record reached through a data carrier such as a QR code (Art. 10), linked to a unique product identifier, and registered in the EU DPP registry (Art. 13). The registry has been live since 20 July 2026; the brand or importer registers the passport, not the factory.
Article 7(5) also requires information on substances of concern to be tracked through the product's life cycle. For garments that means declarations from dye houses and fabric suppliers. See What is a Digital Product Passport?
The Ban on Destroying Unsold Clothing
Some ESPR rules apply without a delegated act. Since 19 July 2026, large companies may not destroy unsold clothing, clothing accessories and footwear listed in Annex VII (Art. 25). Medium-sized companies follow from 19 July 2030; micro and small companies are exempt. Companies that discard unsold products must also disclose how many and why (Art. 24). See the unsold clothing ban.
What ESPR Means for a Bangladeshi Factory
ESPR's legal duties fall on the economic operators that place products on the EU market: the manufacturer (under ESPR, usually the brand that sells under its own name), the importer or an authorised representative. A factory in Bangladesh is rarely the legally responsible party, but it holds most of the data: fibre composition, origin, chemicals, care, production facility. Buyers will pass those data requests down the chain. See who is responsible for the DPP.
Quick Answers
Go Deeper
- Regulation (EU) 2024/1781 (ESPR) — full text on EUR-Lex — Articles 3, 4, 5, 7, 9–14, 24, 25, 74, 80
- European Commission — Ecodesign for Sustainable Products Regulation — Working Plan 2025–2030
- JRC — textiles preparatory study, 3rd milestone (January 2026) — scope focused on apparel
One Law. Many Data Requests.
ESPR names the brand, but the questions land at the factory. A factory that can answer them per style — fibre, origin, chemicals, care — is the supplier buyers keep when the apparel rules arrive.