So, the Ecodesign for Sustainable Products is one of the main pillars of the EU strategy for sustainable and circular textiles. How would you describe it in only three words?

“I would say, in three words, it would be normalizing sustainable products. Basically, I would say normalizing because we set ecodesign requirements that are the norm. So, if you want to set products on the market that are covered by a requirement, you have to comply with the norms that we set. And these norms are, of course, about product sustainability.”

Could you also share with us what is the current status of its implementation and what steps are upcoming?

“I think one thing that’s important to know is that the Ecodesign for Sustainable Products Regulation is a framework regulation. So, the requirements that we set on products don’t come from the regulation itself, but rather through secondary legislation. We have the empowerment through the regulation to set that secondary legislation—what we call delegated acts. These will be applied to priority products, and those will be selected in a working plan. So, the first thing that the Commission will have to do is adopt a working plan, which will specify what kinds of products will be regulated first. This working plan has to be adopted by mid-April 2025. Before we adopt it, there will be some consultation with the Ecodesign Forum. Another thing that’s to happen after 2024 is the establishment of the Ecodesign Forum in the coming weeks, actually, in combination also with a call for application for members of this forum. That will be largely industry representatives, but also Member States, civil society groups, and environmental NGOs to ensure that there’s proper consultation on the working plan, but also later when we are working on individual products. Once the working plan is established, then we start rolling out the regulation; it’s up to us to prepare ecodesign requirements per product group, including also for textiles.”

How do you think everything you just mentioned will affect businesses?

“Well, again, as I mentioned, it’s a framework legislation, so that means that the direct impact in terms of ecodesign requirements is not known yet because we of course need the ecodesign requirements first. We do make sure that any impact that occurs is proportionate. We always have an impact assessment to substantiate all the requirements that we set and to balance the objective of having a very positive environmental impact with also the ability and practical ease of implementation, the cost, and the administrative burden that is associated with complying with these requirements. But these requirements don’t necessarily have to be negative; of course, there can be some cost in changing your production process or changing the design of products, but they can also be very positive. We set harmonized rules across the European Union, which means that we ensure that there is no market fragmentation. If there’s different types of national legislation, then EU legislation takes precedence, which can actually mean that you have a lower administrative burden as a company. But it also means that it can be very good for companies that are frontrunners. If you, as a company, are already producing, for instance, very sustainable textile products, then you could have a competitive advantage once the rules kick in because you have been working on that on a voluntary basis for a longer time already. So, overall, yes, of course there can be a cost, but we make sure it’s proportionate. For many, it can also be very beneficial.”

And I imagine it will be the same for consumers.

“Yeah, for consumers it can be—I mean, yes, there can be a cost implication, but the legal text does require us that any requirement that we set does not have a very negative effect on product affordability. We also have to take care that what we require has this balance between having a product that is more sustainable, but people need to be able to still buy that product as well. But we do also look at the whole life cycle of a product. A product that breaks very quickly or does not last very long means that that product needs to be replaced much earlier, which has a negative financial consequence for the consumer. While the requirements that we set could mean that the product is, for instance, more repairable or, with textiles, for instance, that the product is more durable and therefore it lasts longer and therefore you don’t necessarily have to replace it as quickly. So, it can also in the end actually have a cost reduction effect for a consumer. I think another thing that is very relevant for consumers is information. Consumers in the EU are quite willing and interested in buying products that are more sustainable, but it is often very difficult to get the right information to do so. A key instrument that we have is the introduction of information requirements on product sustainability characteristics. So that means that we can provide that necessary information for consumers to make sustainable choices.”

Transparency is one of the EU’s key principles, as we know. In the context of the EU strategy for sustainable and circular textiles, it is driven by two main initiatives: the amendment of the Textile Labelling Regulation and the implementation of a Digital Product Passport. Would you mind sharing more details with us about it?

“Yes, although you also mentioned the Textile Labelling Regulation, I think both are kind of relevant in this context. The EU Textile Strategy makes a commitment on the one hand side on the introduction of a Digital Product Passport under ecodesign, but it also makes a commitment to introduce what is called digital labelling, which is then considered in the revision of the Textile Labelling Regulation. In the end, we try and aim to kind of integrate these two concepts. A Digital Product Passport, in terms of what could it actually practically look like if you have a product in your hands, could be a QR code. If that would be a QR code, then we would also want this digital label to be the same QR code. So it would be the same access point to the same repository of information, including what is required under the Textile Labelling Regulation, such as the fiber composition or other types of labelling domains, but also all other information that is required under the Digital Product Passport. That could be, for instance, all the sustainability and circularity information that we will set through our ecodesign requirements. What will be in the Digital Product Passport, I can’t say yet because that is to be determined through the ecodesign requirements. But it can, for instance, include relevant information about the amount of recycled materials that are in the products, but also relevant information for product repair, relevant information for textile recyclers to facilitate their operations or in sorting. It’s in that sense a very wide tool, and we can fit into that tool whatever is relevant for the product that we regulate.”