Insights on the evolving regulatory landscape in textiles and fashion
The past few years have seen a flurry of legislative activity aimed at steering the textile and fashion sectors toward greater sustainability, transparency and human-rights safeguards. From the European Union’s ambitious Ecodesign for Sustainable Products Regulation (ESPR) to California’s pioneering Responsible Textile Act or the French Environmental Labelling scheme (‘Affichage environnemental’), the rules are tightening and diversifying, across jurisdictions. This article distils the key developments in the EU, the US and France, segmenting by thematic area, before offering practical guidance on “who, when and how” to comply, as well as a critical look at implementation challenges for SMEs.
1. Eco-Design & Circularity
Source : carbonfact | On 16 April 2025, the European Commission adopted its Ecodesign Working Plan under the new ESPR (Ecodesign for Sustainable Products Regulation), placing textiles and apparel (including footwear) at the top of its priority list. Anticipated requirements, such as enhanced durability, reparability and recyclability, will align with the upcoming revision of the EU Textile Labelling Regulation, with draft rules expected in 2027. Meanwhile, the Waste Framework Directive mandates that Member States by 1 January 2025 establish separate collection systems for used textiles to boost end‑of‑life recovery. |
EU: Extended Producer Responsibility (EPR) for Textiles
In February 2025, the EU co‑legislators reached a provisional agreement to introduce mandatory Extended Producer Responsibility (EPR) for textiles at EU level, obliging producers to finance collection and recycling, with with eco-modulated fees based on product circularity criteria (such as recycled content or durability). Micro-enterprises will benefit from a 3.5‑year transition period following the Directive’s entry into force. Formal adoption is expected imminently, after which Member States will have 20 months to transpose the provisions into national law.
2. Digital Product Passports (DPP), Environmental Footprint (EF) & Traceability
Under the ESPR, Digital Product Passports will be mandatory for high‑impact products. On 9 April 2025, the Commission launched a public consultation (closing 1 July 2025) to shape rules on data governance, hosting and certification schemes. Once established, DPPs will digitalise records of composition, environmental footprints and durability—enhancing regulatory oversight and consumer access. THE DDP includes Environmental Footprint Data, which can be calculated by PEFCR (Product Environmental Footprint Category Rules).
"These are high-level modelling rules for any sector, including 16 impact categories, strict data requirements (notably the use of EF datasets), and a robust verification process. They offer a cost-effective, lower-complexity approach to LCA, particularly suited to SMEs."
Once updated to match the updated EF method & the next generation of EF databases, the PEFCR helps compliance, as for the ESPR, it can be used to calculate product environmental footprints, repairability, intrinsic durability and other indicators (the precise role will be determined by the Delegated Act for textiles) but also for the Corporate Sustainability Reporting Directive as it is the methodology used to support impact reporting.
Beyond legislative compliance, this method is useful for internal purposes, like product eco-design and development, better supply chain management, or for a successful sustainability strategy. It also applies to external use too, like improving investor and corporate stakeholder communication, supporting ESG reporting, or in terms of general communication (communicating environmental priorities and targets responsibly, without greenwashing). And most importantly, it enables a real supply chain collaboration by standardising environmental data needs to drive collaboration with suppliers as business partners.
This would imply a systemic shift from top-down order-giving to genuine supplier collaboration and, at the government level, an understanding of the financial challenges to enable that change, and whom it should go to. Possibly for brands, the first step is to identify their unknown black outs, investing in support and setting up a precise strategy, with priorities on which Data is the most crucial to gather in regard to LCA (Life Cycle Analysis) Assessment. Most of all, because if the Data (e.g. the GHG emissions of its transportation) is non-existant, the score will default to the most unfavourable rating. |
A final note on these calculations : while their aim is laudable, and a huge amount of work has been (and will still be) done, it seems essential always to keep a critical eye and never to lose a common good sense when looking at comparative results, not blindly following them. One way or another, these regulations require to gather the (most robust, qualitative and quantitative..) Data of the maximum steps of the value chain as soon as possible. It starts to be urgent for the industry to digitise in order to be able to respond to the requirements and stay in competition, but most importantly also for brands, to get into the details of their products, and investigate their value chain, take control and responsibility on it.
To help the industry players, the EU launched the EU Textiles Ecosystem Platform on 16 May 2025, as a centralised portal that connects industry and public authorities on circularity and digitalisation topics.
Traceability
In order to take control and responsibility over the value chain, traceability, and thus transparence is key. There exist many different methods and tools, if you want to dive deeper, see these articles:
- Digital tools : https://www.premierevision.com/en/articles/2b3f1a08-7bfa-ef11-90cb-00224888722c
- Physical traceability : https://www.premierevision.com/en/articles/e8ff80f5-7afa-ef11-90cb-00224888722c
- Traceability in wool : https://www.premierevision.com/en/articles/e23754d9-75fa-ef11-90cb-00224888722c
- Traceability in leathers : https://www.premierevision.com/en/articles/410850d3-75fa-ef11-90cb-00224888722c
Latest industry tools updates include TextileGenesis v2.0 (March 2024), which adds blockchain‑based fibre tracking; eTrackit (November 2023) that certifies recycled/organic fibres and the Odith platform (2025) which aggregates supply‑chain data for compliance.
3. Corporate Due Diligence, Reporting
EU Corporate Sustainability Due Diligence Directive (CSDDD)
Also postponed under the Omnibus, the second and third reporting waves shift by two years (Financial Year (FY) 2025 data due in 2028; FY 2026 in 2029). First‑wave reporters (FY 2024) remain on track. France has mirrored this timeline in its national law (Law No. 2025‑617 of 30 Apr il 2025).
4. Forced Labour regulations
US Uyghur Forced Labor Prevention Act (UFLPA)
Since 15 January 2025, any imports linked to listed Xinjiang entities face an automatic forced‑labour presumption and ban. Cotton and textile goods from 39 newly added companies are affected, demanding rigorous supply‑chain scrutiny from importers.
EU Forced Labour RegulationIn force from 13 December 2024, this directly applicable EU law prohibits all goods made with forced labour. Enforcement begins end 2027 (14 December), requiring downstream due diligence for all importers. UK Modern Slavery Act GuidanceOn 24 March 2025, the UK Home Office overhauled its Transparency in Supply Chains guidance under Section 54 of the Modern Slavery Act, introducing tiered disclosure levels, practical examples and an expectation of proactive supplier mapping, though the guidance remains non‑binding. |
5. Deforestation regulations
EU Deforestation Regulation (EUDR)
Delayed by one year in December 2024, the EUDR now applies from 30 December 2025 for large/medium operators (and 30 June 2026 for micro/small businesses). Operators placing cattle, cocoa, coffee, palm oil, soy, rubber or wood products on the EU market must declare due‑diligence statements via the new EU Deforestation Regulation Information System.
UK Forest Risk Commodity (FRC) Regime
Under the Environment Act 2021, the FRC regulation awaits secondary legislation. A March 2025 Defra survey on soy, palm, rubber and other commodities signalled progress. Large businesses (turnover ≥ £50 M; annual use > 500 t) will face due diligence and reporting obligations, with likely enforcement in late 2025/2026.
6. Chemicals & Human health
EU REACH Updates
On the 3 June 2025, DMAC (Dimethylacetamide) and NEP (N-Ethylpyrrolidone), industrial solvents commonly used in textile and fibre production, especially in the manufacture of synthetic fibres like polyamide, elastane or polyurethane coatings, were added to REACH. From 23 December 2026, most uses of DMAC and NEP (≥ 0.3%) will be prohibited across the EU.
However, a temporary derogation has been granted until 2029 for specific uses in man-made/synthetic fibre production, acknowledging the time needed for manufacturers to find and validate safer alternatives. Nevertheless, to be granted the exemption until 2029, companies must demonstrate that substitution is not technically or economically feasible at this stage, implement strict worker protection measures, and notify national authorities or the European Chemicals Agency (ECHA) if required by local enforcement systems.
EU Chemicals Strategy for Sustainability (CSS)
In May 2025, the Commission pledged a near‑total PFAS phase‑out in consumer products, with an upcoming Chemicals Industry Action Plan (2 July 2025) to streamline REACH and detail PFAS restrictions.
US TSCA & PFASEPA’s interim rule (May 2025) extends PFAS reporting deadlines to 13 October 2026 (with small‐importer relief to 13 April 2027). The roadmap includes risk evaluations and future bans under TSCA §6. State‑Level PFAS Bans
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7. US: Responsible Textile Act (California SB‑707)
Adopted in September 2024, this pioneering EPR law obliges textile producers to join a Producer Responsibility Organization and submit stewardship plans by July 2028, under penalty of significant fines, mirroring California’s packaging regime SB‑54.
8. France: Pioneering National Measures
Eco‑Score for Textiles
Under the 2021 Climate & Resilience Law, France’s “Environmental Cost” score (Eco-score, formerly « affichage environnemental ») covering GHG emissions, water use and biodiversity, was approved on 15 May 2025. The decree setting the final rules was published in May 2025, which means the mandatory phase is expected by mid-2026, requiring producers/importers to calculate and display an aggregated impact score. All producers, importers or distributors of clothing and home textiles sold in France, regardless of whether they are French or foreign companies, including importers and white-label manufacturers supplying textiles for resale in France.
In the context of the Eco-score, ECOINVENT is used as a core reference source to model the environmental impacts of materials and processes in a consistent and scientifically robust way. This ensures that Eco-scores are grounded in internationally validated data and that results are comparable across brands. Eco-score calculations may be run through approved digital tools or platforms (some developed in partnership with ADEME) that incorporate ECOINVENT datasets into their algorithms, allowing brands and manufacturers to input product-specific data (e.g. weight, material, origin) and receive a verified environmental score. |
Anti‑Fast Fashion Law
On 10 June 2025, the Senate approved measures to curb “ultra fast‑fashion” platforms (e.g. Shein, Temu), introducing, (besides a legal definition of “ultra fast‑fashion”, linked to volumes produced, product lifespan, speed of renewal..) :
1. An eco‑penalty (€5 per item from 2025 rising to €10 by 2030; capped at 50% of pre‑tax price).
2. A ban on advertising for ultra fast‑fashion
3. Enhanced consumer information requirements on environmental impacts.
The law still awaits final EU‑notification and Senate‑Assembly reconciliation before enactment, expected to be end of 2025.
To stay up-to-date with the latest eco-innovations, (re)watch the Innovation and Technology webinar (also on Linkedin).
And don’t miss the eco-innovation talks at the Première Vision show in September!
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