Summary

Up until now, the types of apparel and footwear products that can be brought to the EU market have been largely unregulated (outside of chemical management and product safety). This is changing, and this will become a regulated sector. New EU and national laws define guardrails for what products can be made from, how they must perform, and what physical and digital information needs to accompany them onto the market.

"As designers and product developers, we need to stay ahead of consumer trends and protect margins, but never have we had to build compliance into the product development process."

Despite increasing commercial pressure to respond to shorter lead times and improved margins, teams also need to consider:

Products- All textile products will have minimum recycled content and durability thresholds…but also incentives for better-performing products.

Sourcing- All products must prove they are free of forced labour, and many leather products must prove they come from deforestation-free sources.

Product Information- More physical and digital transparency on materials manufacturing, care, repair and disposal

This mentality shift will impact all apparel brands and manufacturers and could fundamentally change the types of products brought to market. While the products evolve, the hard work will be in producing and sharing product data through supply chains to retailers, consumers and regulators. As part of a broader effort to digitise the EU single market, all products will need a Digital Product Passport, which carries all of the relevant information for consumers to make informed choices and for regulators to verify compliance.

• Internal Upskilling – Staying innovative and profitable in a more regulated world will take creativity. Bring your teams together early.
• External Engagement – Legislation will not wait for innovation. Upskill your suppliers and manufacturers so they can evolve with your compliance efforts.
• Data Landscape – Traditional Bill-of-Material tools and spreadsheets may not be enough to manage your product data.

Legislations concerning Product Design

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ESPR will ban products that fail to meet sustainability and durability standards. EUDR will restrict imports of materials linked to deforestation.

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EPR eco-modulation schemes will reward sustainable design and penalise wasteful practices.

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Brands should align with Product Environmental Footprint (PEF) methodologies and prepare for Digital Product Passports (DPPs).

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Author

Bente Bauer

Founder & Director 2BPolicy

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What Should you be doing?

Brands

To stay compliant and competitive, brands need to integrate sustainability into product development and supply chain management. Here’s how:

1. Understand the regulations
2. Assess product & material risks – Conduct gap analyses to identify non-compliant materials, production methods, and reporting gaps.
3. Strengthen traceability & data collection – Work with suppliers to document material origins, carbon impact, and product durability.
4. Adapt product design – Ensure durability, recyclability, and repairability to comply with Ecodesign requirements and reduce EPR fees.
5. Set up compliance monitoring – Build internal processes to track legislative updates, ensure accurate reporting, and avoid regulatory risks.

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Manufacturers

Manufacturers play a key role in enabling compliance for brands. To stay ahead of regulations:

• Material Producers – Ensure raw materials meet EUDR deforestation-free requirements and third-party sustainability certifications.
• Manufacturers – Prepare for product durability and repairability standards under ESPR. Upgrade data systems to track environmental impact.
• Suppliers – Provide verified supply chain data to support brand compliance. Work towards DPP-readiness by digitising material and impact records.

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Key Dates for Product Design Legislation

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