With so many regulations landing at once, it’s easy to lose track of what’s coming, when, and what it means for your daily work. In this article, we break down the ESPR working plan published by the European Commission, what it is, why textiles are in focus, and how it all connects back to your product data and Bill of Materials.
ESPR stands for Ecodesign for Sustainable Products Regulation. You’ve probably heard about it often in connection with the Digital Product Passport, which is one of the key elements of the regulation. But the ESPR as a whole is much broader than that. At its core, the regulation aims to promote sustainability across EU member states by improving transparency and supporting the transition to a more circular economy. Instead of laying out strict actions, the ESPR sets criteria that products need to meet in order to be considered sustainable. You can read more on the regulation itself here.
What makes it challenging right now is that we still don’t have the full picture. The actual criteria will be defined in industry-specific rules, known as delegated acts, which are still being developed. That’s where the working plan comes in. While it doesn’t give all the answers, it does offer an overview of what’s coming, including the expected timeline and which product groups will be prioritised first.
On April 16th 2025, the European Commission released the first working plan for the ESPR. And while it might sound a bit heavy at first glance, it’s basically a roadmap showing where the regulation is heading, and when.
The plan runs from 2025 to 2030 and lays out which product groups will be prioritised and what we can expect in terms of timing. The prioritisation is based on things like environmental impact, market size, and where there’s still a lack of regulation. And yes, textiles are right up there at the top of the list. Though while textiles remains a key focus, but interestingly, footwear is no longer prioritised in this round. That doesn’t mean it won’t be addressed later, but for now, the spotlight is firmly on textiles.
In other words, this is where it all begins, and now is the time to get familiar with what’s coming.
So, what’s in the plan when it comes to textiles? Quite a bit, actually. And if you’re in the textile industry, it’s worth paying attention, because this gives us a pretty solid hint about what’s next. First of all, the plan sets a clear year for when the delegated act for textiles is expected to be adopted: 2027. That means we’ve got some time, but not too much, to start preparing for what’s coming.
One detail that stands out is the mention of both the Digital Product Passport (DPP) and a new ESPR label, in the same section as the revision of the Textile Labelling Regulation. That’s a strong hint that these elements could end up being connected in the final setup.
And what might this label include? According to the plan, it should give clear and trustworthy information on things like carbon footprint, water consumption, durability, repairability and recyclability. It’s starting to look like a kind of rating or scoring system will be introduced, and that’s where the Product Environmental Footprint Category Rules (PEFCR) are likely to come in.
You probably know that little energy label we see when buying a light bulb, the one with the green-to-red scale, showing us straight away what’s efficient and what’s not. That kind of scoring system might be what we’re heading toward in fashion too. This is where the PEFCR for apparel and footwear comes into the picture. It’s a new, Cascale-developed method for measuring the environmental impact of clothing and shoes. The 3.1 version was released on April 29th 2025, and for now it is a voluntary tool, but it will likely become the standard for how environmental scores are calculated and compared across products.
So how does this connect to the ESPR? If the ESPR label is going to include information like carbon footprint, water use, durability and recyclability, the PEFCR will probably be the method used to measure it. That’s how we move from ambition to something concrete, something that can actually be shown to the customer in a simple, easy-to-understand way.
So why are we talking about all of this in the context of a PLM platform? Because in the end, your ability to comply with ESPR, whether it's filling out the Digital Product Passport or aiming for a strong environmental score, all comes down to how well you manage your product data. And that starts with your Bill of Materials.
The more detailed and structured your BOM is, the better your chances are of pulling together the data you’ll need later. From materials and weights to packaging and components, it’s all connected. If the product information isn’t there from the start, it becomes much harder to respond when new requirements come in. Read more about the importance of a detailed BOM here.
Every month, we host a webinar, often in collaboration with our IT solution partners and leading industry brands. The topics vary, but one thing remains the same: we aim to make the fashion industry’s challenges more manageable and share our take on practical, hands-on solutions.
Check out this month’s webinar by clicking the button below.