As part of the EU Green Deal, in 2009, the European Commission adopted the Ecodesign Framework Directive which sets a legislative framework with the aim of regulating the performance of energy-related products. In 2019 the European Product Database for Energy Labeling came into force and is what is known today as the EPREL. The policy has been deemed very successful and the EU is now looking to expand the scope of the regulation to encompass any physical goods placed on the market (with exceptions made for food, medicinal and veterinary products).

Yes, this then would imply that all goods placed on the market by the fashion industry would be under the new scope of the EPREL. As part of the EU Strategy for Sustainable and Circular Textiles, eco-design will be a requirement for the industry and it will have to adapt to several requirements that will have a real impact across its value chain, including product design, labels, waste management, and more. This article aims at shedding some light on some of the requirements that will have a big impact on the industry (yet there are several more within the document and there will surely be more to come in the future . 

What does it mean for fashion?

Simply put, the aim of this regulation is to ensure that the fashion industry is on its way toward circularity. Closing the loop on the value chain is one of the most challenging issues that companies face and the goal of this regulation is to even the playing field so that all companies will have to do so. As a result, the industry as a whole will have to change the way in which they produce, distribute, and dispose of their products. 

I.ECODESIGN

Products put in the EU market will have to comply with industry-specific requirements. These will aim at improving:

• Product durability, and reliability, 

• Product reusability,

• Product upgradability, reparability, maintenance, and refurbishment

• Presence of dangerous substance

• Product energy and resource efficiency

• Recycled content

• Product remanufacturing and recycling

• Product’s carbon and environmental footprints

• Product’s expected generation of waste materials

II.PERFORMANCE

In turn, performance information will be required to analyze the efficiency of the product aspects and shall relate to specific parameters for each of the categories mentioned. Some of the parameters include how the product is designed and how easy and accessible it is for customers to repair it if necessary, or recycle it at end-of-life. Other requirements include the analysis of packaging, the incorporation of recycled materials, and the environmental footprint (carbon emissions, microplastics, emissions to air, water, or soil, water use, and waste management).

III. INFORMATION

This performance should be disclosed for the consumers to have easy access to it, along with information regarding how to install, use, maintain, and repair the products, and information for treatment facilities on disassembly, recycling, or disposal. We do not know yet how this information shall be disclosed but several options are available such as on the product’s packaging, on the product itself, on the product passport, on a label, or through a digital platform.

IV. PRODUCT PASSPORT

The aim of this is to improve the traceability of products along the value chain and ensure that actors along the value chain can access product information relevant to them. A product passport will be required for products to be inserted into the European market. This product passport can be used to include the information mentioned before, and it will also have to provide information about manufacturers, importers, distributors, dealers, repairers, remanufacturers, and recyclers. Private or public actors may introduce information to update the passport so that the product contains the latest information on its whereabouts. Furthermore, the passport will have to be fully interoperable with other product passports and will have to be designed to ensure the highest level of security and privacy to avoid fraud.

V. DESTRUCTION OF UNSOLD GOODS

While the destruction of unsold goods has already been implemented in different countries within the EU, this would be the first union-wide regulation to deal with the management of these goods. Companies that discard unsold consumer products would be subject to transparency requirements including:

• Number of unsold consumer products discarded per year, differentiated per category

• The reason why these products were discarded

• The delivery of the discarded products to prepare them for re-use, remanufacturing, recycling, and disposal operations

While there are other requirements that will impact the fashion industry, they will not impact brands directly, but rather through their suppliers, importers, distributors, and retailers.

Ecodesign working plans 2022-2024

The regulation is not yet enforced for the textile and fashion industry, as the current legislation needs to be adapted to industry-specific requirements. As a result, the Ecodesign and energy label working plan 2022-2024 has set out to create requirements on material efficiency and product-related aspects to further improve circularity and overall reduction of environmental impacts.

We look forward to seeing how the implementation of this regulation will impact the industry as the legislative requirements will truly be a turning point for the industry. To know more about the regulation do not hesitate to reach out, or look into the Proposal for a regulation of the European Parliament and of the council establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC - always a fun read!

Note: this is not an exhaustive article on the requirements set out by the proposal on ecodesign requirements and should not be taken as such. The aim of this article is to introduce the topic and the basic framework for the upcoming legislation.