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Avoiding overregulation: A pragmatic approach to Substances of Concern (SoCs) in the Ecodesign for Sustainable Products Regulation (ESPR) Delegated Act (DA) for Textiles

Position paper - Environment, Sustainability & Energy

1 July 2025

The Ecodesign for Sustainable Products Regulation (ESPR) Textile Delegated Act (DA) is expected to significantly influence the design, production, sale and disposal of textile consumer goods by 2027. It will introduce performance and information requirements on various features including substances of concern (SoCs) in finished textile products.

The implementation of ESPR must align with the EU Political Guidelines and the Commission’s competitiveness compass, ensuring a reduction in administrative burden and simplified regulatory frameworks.

Representing different key actors across the broad textile value chain, from chemical suppliers to textile manufacturers, apparel brands, retailers and textile services, the undersigned industry associations raise concerns related to the development of SoCs provisions and suggest recommendations for the European Commission and the JRC team which are currently developing ecodesign requirements for textiles.

The signatories submitted their comments individually to the JRC questionnaire on substances and substances of concern in textile apparel, under the 2nd Milestone consultation of the “Preparatory Study on Textile for product policy instruments”. This joint statement consolidates the concerns previously raised individually and calls for engaging in a continuous dialogue involving the different actors of the global textile value chain in the preparation of the DA for textiles.

Download (pdf - 316.77 KB)

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