New EU Ecodesign Regulation: focus on textiles too

01.10.2025

On June 28, 2024, a new EU regulation was published: the Ecodesign Regulation (EU) 2024/1781, which lays the foundation for uniform rules on the sustainable design of products throughout Europe.

Unlike the previous directive from 2009 (2009/125/EC), which only focused on energy-related products such as household appliances, the new regulation can now regulate almost all physical products - from furniture to clothing and electronics. The regulation is a so-called framework regulation. This means that it sets out the general framework, but the specific requirements for individual product groups will only be defined later in additional, specific legal acts ("implementing acts").

When the framework regulation was published (Article 18) and the Ecodesign Working Plan published by the EU Commission on 25.04.2025, textiles, in particular clothing and footwear, were already defined as one of the product groups to be prioritized. According to the working plan, an implementing act for the definition of ecodesign requirements for textiles will be adopted in 2027. According to Article 4 of the Ecodesign Regulation, the date of application of such an implementing act should be at the earliest 18 months after its entry into force, i.e. newly defined ecodesign requirements for textiles are not expected to come into force until the second half of 2028 at the earliest.

ATTENTION - Destruction ban on unsold end consumer textiles for large companies from 2026 - disclosure obligation already now!

Notwithstanding the above-mentioned provisions, Chapter VI (Articles 23-26) of the Ecodesign Regulation contains provisions to reduce the destruction of unsold consumer products that are not linked to a product-specific implementing act and some of which already apply now. Information on this can also be found in BAM's FAQs.

Article 24 stipulates that economic operators who dispose of unsold consumer products or have them disposed of - regardless of their type - must disclose the number and weight of unsold consumer products disposed of and the reasons for their disposal online from their first full financial year after the entry into force of the Ecodesign Regulation (i.e. full financial years from 18.07.2024). However, this requirement does not apply to micro and small enterprises (definition according to Recommendation 2003/361/EC: fewer than 50 employees and annual turnover or annual balance sheet not exceeding EUR 10 million) and to medium-sized enterprises (fewer than 250 employees and either annual turnover not exceeding EUR 50 million or annual balance sheet total not exceeding EUR 43 million) until 19.07.2030. As a result of this obligation, large companies must already collect data on the destruction of unsold consumer products and disclose this at the end of their first full financial year starting after 18.07.2024.

The reporting format should be announced in an additional implementing act, which was originally due to be adopted by 19.07.2025. The current draft, which has not yet been finally adopted, provides for a simple tabular presentation and product categorization using the two digits of the Combined Nomenclature (CN) of Annex I to Regulation (EEC) No. 2658/87.

Even if the implementing act has not yet been adopted, large companies covered by the above-mentioned reporting obligation should already collect detailed data on the quantities and types of consumer products destroyed and prepare them in such a way that they can be easily disclosed on an "easily accessible page of their website" in accordance with the wording of Article 24 of the Ecodesign Regulation. For companies that are obliged under Article 19a or 29a of Directive 2013/34/EU to also publish sustainability reporting as part of their annual financial statements, publication in the sustainability report is also an option, although this is not mandatory. According to the FAQs of the EU Commission, publication on the company website is mandatory in any case.

The measures against the destruction of unsold consumer products also include a binding ban on unsold consumer products listed in Annex VII of the Ecodesign Regulation for large companies from 19.07.2026, mainly clothing and footwear - further information on this ban formulated in Article 25 will follow shortly in the news section. This requirement also does not apply to small and micro-enterprises, and for medium-sized enterprises only at the same time as the aforementioned start of the reporting obligation on destroyed consumer products on 19.07.2030.