UBA study recommends eco-design requirements for textiles

The new Ecodesign for Sustainable Products Regulation: an opportunity for sustainable textiles

The Ecodesign for Sustainable Products Regulation ((EU) 2024/1781), which came into force in 2024, establishes a framework for setting ecodesign requirements for sustainable products and makes it possible for the first time to develop binding requirements for textile products. The aim is to make sustainable textile products the standard in the EU. The ecodesign requirements for textiles to be developed are also part of the EU Strategy for Sustainable and Circular Textiles. 

UBA study examines possible requirements

The study ‘Ecodesign for Sustainable Products Reulation: requirements for the ecodesign of textiles and the possible transfer to an ecodesign label’, carried out on behalf of the UBA, supports the European process from a German perspective and provides scientifically sound proposals for possible ecodesign requirements for textile products. The aim was to derive specific requirements and information obligations for textiles. Another focus was on how these requirements could be transferred to a label and thus made visible to consumers. 

Five product aspects are essential for a sustainable textile product

The study identified five possible product aspects that are priorities for the sustainability of a textile product: durability, reparability, recyclability, recycled content and substances of concern (SoCs). Through literature research, expert surveys, market analysis and stakeholder workshops, possible requirements for three product examples relevant to the market – T-shirts, jeans and functional jackets – were derived. A distinction was made between performance requirements that must be met and information requirements that must be declared.

The study identified durability as the key criterion for the environmental sustainability of clothing. Specific and measurable requirements were defined for the product examples examined in order to evaluate them. For T-shirts, for example, the requirements include dimensional stability to washing, Bursting resistance and colourfastness. Some of these requirements also apply to jeans. However, the tensile strength and elongation of the fabric and its resistance to abrasion are particularly relevant. These and other aspects can be determined using existing test methods.

For the product aspect of repairability, the study recommends minimum requirements such as the availability of spare parts, repair manuals and cooperation with repair services. For more complex products such as functional jackets, product-specific requirements are also meaningful. 

With regard to recyclability, the study suggests limiting material mixtures to a maximum of two different materials processed in the fabric layer, for example. The use of elastane should also be limited to 5 to 10 per cent in order to ensure on the one hand the (spectroscopic) detection of the elastane content (at least 5 per cent), and on the other hand to guarantee high-quality recycling in both the mechanical and chemical areas (maximum 10 per cent). 

Specific requirements for a minimum proportion of recycled materials have also been derived. However, these are specifically intended for T-shirts and jeans and require further framework conditions. For example, it must be defined whether the recycled content should be determined at product level or batch level, where the recycled material for fibre-to-fibre recycling should come from, and which certification systems are recognised.

With regard to substances of concern (SoCs), the UBA study proposes two minimum information requirements: 

1. Information about effect chemicals intentionally present in the product (e.g. water-repellent substances) by including them in the product specifications and passing them on along the supply chain. The aim is to improve transparency regarding these chemicals over time.
2. The information requirements for SVHC (Substances of Very High Concern), i.e. the SVHC information requirements will be integrated into the publicly accessible part of the Digital Product Passport (DPP). The aim behind this is to make this information accessible to end users. 

However, the study did not examine the aforementioned product aspects individually, but rather brought them together and highlighted potential conflicts of interest. 

A new ecodesign label for textiles?

The study concludes that it is generally possible to transfer such ecodesign requirements into an ecodesign label that provides consumers with a quick overview of how sustainable a textile product is when making a purchase. Durability could be identified as the most important product aspect, possibly by specifying the number of wash-dry cycles. Performance classes are conceivable for the product aspects of reparability and recyclability, while specific percentages could be used for the product aspect of recycled content. Information on SoCs is considered too extensive for a label on the product and could instead be included in the DPP referred to on the label. 

Background information on the study 

The study provides a comprehensive knowledge base for deriving sustainable product aspects for textiles – for science and industry. It supports the European process from a German perspective and provides scientifically sound proposals for possible ecodesign requirements for textile products. In addition, the study results will be taken into account into the comments on the European preparatory study by the Joint Research Centre (JRC) of the European Commission. The UBA is playing a key role in the commenting process. Thus, the research project supports the EU's goal of developing a delegated act for textiles.

The study was conducted by the Öko-Institut in collaboration with the Niederrhein University of Applied Sciences and the Hof University of Applied Sciences.