The ESPR Textiles Delegated Act: What the Draft Is Expected to Require from Apparel Brands

Textiles are the product group fashion brands have been waiting on since ESPR entered into force, and the delegated act is still unwritten. That is exactly why now is the useful moment to read it: the preparatory evidence is public, the data-point debate is open, and a brand that understands the direction can shape its product and supplier data before the text is fixed. Everything below describes what is expected, not what is law. The act has not been proposed yet.

Where the timeline stands

According to Regen Studio's tracker, a Commission proposal is expected in late 2026, with adoption in late 2026 or early 2027. The compliance date will be set in the act itself. ESPR requires at least 18 months between adoption of a delegated act and its application, so apparel brands should plan on obligations biting no earlier than mid-2028 on current signals. Treat that as an estimate, because indicative Working Plan dates have slipped before.

Who is likely in scope

The preparatory work centres on garments: t-shirts, shirts, sweaters, jackets, trousers, dresses, underwear and socks, plus accessories. The expected exclusions are smart textiles, personal protective equipment, medical devices and raw materials. If you sell workwear with a protective function or sensor-enabled clothing, watch the final scope wording closely.

What the evidence points to

The Commission's Joint Research Centre (JRC) preparatory study shapes the likely requirements. Three findings stand out.

First, durability is the main lever. Raw materials and manufacturing account for roughly 81 to 90 percent of a garment's environmental impact, so making a garment last longer does more than any end-of-life measure. Expect minimum durability requirements covering things like seam strength, colour fastness and pilling resistance, though the exact parameters are unconfirmed.

Second, recyclability is hard because of blends. Mixed-fibre garments make up an estimated 48 to 60 percent of EU apparel, and current sorting and recycling systems struggle with them. This is where design-for-recycling rules and recycled-content requirements are most likely to collide with real commercial choices.

Third, reparability is being explored but faces practical hurdles for apparel, so expect it to be weaker than in electronics or appliances.

Microplastic release, water use and waste generation are named as reduction priorities in the EU's broader textiles strategy and may surface as information requirements rather than hard limits.

The passport data question

The act is expected to mandate a Digital Product Passport accessible by QR code, serving consumers, authorities and recyclers. The JRC published a candidate data-point evaluation in May 2026 for consultation, which is the best available preview of what fields will be required. Material composition, chemical inputs and test data are the areas most commonly expected, and all of them depend on supplier disclosure. The EU registry that will hold the passport identifiers is now operational, so the infrastructure side is further ahead than the content side.

How to prepare now

Map your fibre composition by style, not by season. Ask tier-one and tier-two suppliers which chemical and test data they can already provide in structured form. Review your top-selling blends against recyclability. And decide who in your organisation owns the passport data model, because textiles will sit alongside the unsold-goods destruction rules and the right-to-repair debate rather than replace them.

If you act on the draft requirements before they are published, you may over-invest; if you wait for the final text, the supplier data gap will be your bottleneck. The sensible middle is to build the data collection now and leave the thresholds for later.