European Union Ecodesign for Sustainable Products Regulation: Summary of inconsistencies and potential deficiencies


In March 2022 the European Commission proposed the Ecodesign for Sustainable Products Regulation (ESPR). Under the ESPR, ecodesign requirements may be set for specific product categories to improve their circularity, energy performance, resource efficiency, and other environmental sustainability attributes.

The Joint Research Centre (JRC) was commissioned to produce a report to suggest a number of product groups and horizontal measures as suitable candidates for prioritisation under ESPR once it enters into force. That report, “Ecodesign for Sustainable Products Regulation - preliminary study on new product priorities” was published in January 2023. Textiles and Footwear was one of 19 product groups assessed by the JRC, and the category was included in the final short-list of 12 end-use products. Potential measures under the ESPR for each product were also proposed.

This white paper, by authors Veronica Bates Kassatly and Terry Townsend, assesses the draft JRC Report’s ‘potential measures’ for Textiles and Footwear as the lead product group prioritised for action under the ESPR. Getting the analysis and recommendations for Textiles and Footwear right is imperative as performance requirements on pesticide, fertiliser, water, land use etc decided for this sector will presumably determine those of all others.

This paper is not intended to be a criticism, but rather a call for the EU Commission and EU organisations wanting to address climate change with climate justice, to work more collaboratively toward the sustainability outcomes shared by the greatest number of people.