Textiles Q&A: Your Guide to ESPR, DPPs and the Ban on Destruction
The Ecodesign for Sustainable Products Regulation (ESPR) is one of the most far-reaching sustainability regulations ever implemented, and textiles are among the priority sectors. Last week, our textiles experts led one of our most attended webinars on “Preparing for Ecodesign for Sustainable Products Regulation ESPR & the Future of Sustainable Textiles”.
- Group 1: ESPR Scope, Roles & Key Obligations – Who is affected? What obligations apply? Which dates matter?
- Group 2: Ban on Destruction of Unsold Goods – What exactly is banned? Who is affected? What are the exceptions? How is it enforced?
- Group 3: Digital Product Passport (DPP) – How will the system work? What data is needed? How should brands prepare?
Group 1: ESPR Scope, Roles & Key Obligations
Who is affected? What obligations apply? Which dates matter?
1. Does the ESPR impose any disposal or waste‑management requirements on end‑users, or are obligations limited to economic operators?
Under ESPR, the primary obligations sit with economic operators (producers, importers, distributors, online platforms) rather than end‑users. The regulation does not create direct duties for consumers, but it does require clearer information on durability, repair, and end‑of‑life options, and works alongside textile EPR rules that will give consumers access to separate collection and reuse/recycling routes.
2. Does the obligation to report destroyed unsold textiles start this year, with a standardized reporting format required from 2027?
ESPR introduces an information‑disclosure duty on the destruction of unsold goods, and the detailed content and format are specified in implementing measures.
The reporting obligation for large companies already applies; these companies must report for the first full financial year after the directive came into force, which is 18 July 2024.
The Implementing Act, introduced in February 2026, established a standardized format that takes effect in February 2027, giving large companies time to prepare. For medium-sized companies, the standardized format will apply from 2030.
3. How can non-EU manufacturers proactively prepare for ESPR and the ban on destruction of unsold goods?
Non‑EU manufacturers can already prepare by:
- Designing products for durability, reuse, and recyclability, so they are less likely to become unsellable stock.
- Improving forecasting and production planning with EU customers to reduce over‑ordering and returns.
- Building reuse, repair and resale options into contracts (e.g. take‑back or refurbishment channels) so destruction is never the default outcome.
- Starting to collect basic product data (materials, composition, care instructions) that will later feed into DPP and facilitate reuse/recycling.
4. Does this mean producers must not only provide the data on their own website and to authorities, but also make it available to the marketplaces where they sell their products?
Yes. ESPR makes clear that obligations also apply where products are sold via online platforms. Producers must ensure the required information is accessible to consumers and authorities wherever the product is offered, in practice meaning they must provide data to marketplaces and ensure it is displayed correctly on those channels.
Group 2: Ban on Destruction of Unsold Goods
What exactly is banned? Who is affected? What are the exceptions? How is it enforced?
5. When does the ban on destruction of unsold goods come into effect?
For textiles, the ban starts to apply to large enterprises from July 2026, covering unsold apparel, clothing accessories, and footwear.
From July 2030, it extends to medium‑sized companies.
Micro- and small enterprises are exempt.
6. Is it correct that damaged, recalled, and defective goods also cannot be destroyed?
Destruction is still allowed in specific, tightly defined cases.
A delegated act adopted in February 2026 sets out derogations, including for products that:
- are dangerous or non‑compliant with safety rules
- infringe intellectual property rights
- are clearly unfit for reuse or remanufacturing
Companies must justify and document these cases for five years.
7. Will the ban on destruction be introduced for product types other than textiles?
Textiles (apparel, clothing, accessories, and footwear) are the first product group covered by the ban.
ESPR allows the Commission to extend the prohibition to other product categories in the future, based on impact assessments and data from the disclosure obligation, but additional groups have not yet been confirmed.
8. Does Annex I of the destruction ban apply only to economic operators, or are recyclers also subject to obligations?
The obligations under the ban on destruction apply to the company that discards the product, i.e., the economic operator deciding to dispose of unsold goods, not to the downstream waste operator that treats the waste.
9. If the destruction ban applies from 2026 but reporting only from 2027, how will the EU Commission prevent large companies from destroying products in the interim?
The prohibition itself applies from July 2026 for large enterprises, regardless of whether the standardized digital reporting template is already in use.
Enforcement will rely on national market‑surveillance authorities, who can draw on inspections, company records, audit trails, and other evidence to verify compliance even before the harmonized reporting format becomes mandatory in 2027.
10. Is recycling considered destruction under ESPR?
Under ESPR, destruction includes any intentional action that turns a usable product into waste, including sending it directly to recycling, recovery or disposal.
However, once the product is classified as waste, subsequent waste‑treatment steps (such as high‑quality recycling) are governed by waste legislation rather than the destruction ban.
Key Principle: Reuse and preparation for reuse must always be prioritized over recycling.
11. What happens to the 5 billion articles already in circulation or in consumers’ households?
ESPR mainly applies to products placed on the EU market after its rules and the relevant delegated acts take effect. Existing stock and items already in consumers’ wardrobes are not retroactively subject to DPP or design requirements.
However, they will still be affected by waste‑side rules (e.g. textile EPR) once they enter end‑of‑life streams.
Brands are encouraged to integrate them into reuse, repair and take‑back schemes wherever possible.
Group 3: Digital Product Passport (DPP)
How will the system work? What data is needed? How should brands prepare?
12. DPP under ESPR: How do brands meet requirements if up to 20% of textile labels are worn off or lost?
ESPR recognizes that on‑product labels can be removed or become illegible, which is one reason it leans toward digital, scannable identifiers such as QR codes or RFID that link to the Digital Product Passport (DPP).
Brands can reduce risk by:
- using durable and redundantly placed identifiers (e.g. multiple codes, woven labels, embedded tags)
- ensuring DPP data is accessible via purchase records or online portals, not only through a physical label
13. Is it correct that the DPP granularity is still undefined and could end up being product‑, batch‑ or item‑level, or a combination of these?
Correct. The granularity and technical specifications for textile DPPs will be defined in the upcoming delegated acts.
Options under discussion include:
- Product‑type
- Batch‑level
- Item‑level
- or a combination)
The final decision will likely depend on risk, use‑case, and feasibility assessments.
14. When can we expect the delegated acts defining the DPP criteria?
According to the ESPR work plan and current Commission communications, the delegated act for textiles is expected in 2027, with preparatory work already underway. Exact adoption and application dates will depend on the legislative process, but brands should plan several years of lead‑time between adoption and full applicability.
15. How can retailers or other businesses prepare for the DPP even before the delegated acts are finalized?
Even without final technical rules, there are several “no‑regrets” steps:
- Map your current product data: what you already collect (materials, suppliers, weights) and where the gaps are.
- Move toward consistent, machine‑readable identifiers (e.g. QR codes) that can later link to DPP data.
- Improve internal governance for product information so it can be trusted and shared across design, sourcing, compliance and end‑of‑life partners.
- Pilot collaboration with recyclers and sorters to understand which data they actually need to enable higher‑value recycling, so your future DPP fields serve real operational use‑cases.
How RLG Can Support You
Whether you are an apparel brand, part of a sustainability team, or overseeing supply chains: RLG helps you prepare your textiles business for ESPR. With the insights from the webinar, we hope many regulatory questions have become clearer.
Reach out to us anytime to explore your business-specific needs and secure future-proof compliance.
