Forthcoming EU rules on textile ecodesign should set mandatory performance thresholds for durability, recyclability and recycled content rather than rely on information and labelling measures alone, according to the Ellen MacArthur Foundation.

In a new white paper published this week (9 July), the organisation says the current proposals from the EU's Joint Research Centre - which is preparing the technical groundwork for the Ecodesign for Sustainable Products Regulation (ESPR) Delegated Act on textiles - treat three of the four proposed ecodesign criteria primarily as information requirements. Only recycled content carries a mandatory performance threshold, set at an initial minimum of 5 per cent.

The Foundation recommends the Delegated Act convert robustness from an information requirement to a binding market access standard, strengthen the recyclability scoring system, prioritise post-consumer fibre-to-fibre recycled content with targets that increase over time, and work toward a mandatory product-level repairability requirement in a future revision. Information can prompt change, the Foundation argues, but performance requirements are needed to move it at scale.

Measuring robustness

Under the JRC's current proposal, a garment needs to survive just five washes to pass the robustness assessment. Major brands already exceed that threshold several times over. Primark tests products to between 23 and 32 washes depending on tier, with 77 per cent of denim and jersey lines tested in 2024/25 meeting or exceeding the higher standard. H&M Group tests core materials for up to 50 washes. The Jeans Redesign guidelines, developed with input from 80 experts across industry, academia and NGOs, set 30 home laundries as a minimum.

The proposed assessment also measures appearance rather than function, so a garment that resists fading could score higher than one whose seams remain intact. ISO standards for dimensional stability, seam strength, pilling resistance and abrasion resistance are already widely used across the industry. The Foundation argues the next step is harmonising methods and agreeing binding thresholds, not building new frameworks from scratch.

Extending the active lifespan of apparel by just nine months would reduce carbon, water and waste footprints by 27 per cent, 33 per cent and 22 per cent respectively, according to research cited in the paper.

Recyclability challenges

Most textile recycling technologies can process only 3-5 per cent elastane, according to H&M Group's own recycling survey. Yet the JRC's current proposal sets the non-recyclable threshold at 15 per cent - well above the point at which mechanical recycling is affected, which evidence puts at around 10 per cent. The Jeans Redesign went further still, advocating participants limit elastane to 2 per cent by weight.

A separate concern is the proposed consumer-facing recyclability score. Whether a garment is actually recycled depends on collection, sorting and processing infrastructure that varies widely across Member States - a high score on a label tells a consumer nothing about whether the systems exist in their country to act on it. The Foundation recommends directing recyclability data toward sorters and recyclers through the Digital Product Passport's machine-readable data layer, where it can inform practical decisions about material flows rather than function as a consumer guarantee.

Fibre-to-fibre mechanical polyester recycling is now available at scale in some markets, and chemical recycling technologies for cellulosic and synthetic fibres are advancing. The Foundation recommends a structured review mechanism that raises thresholds at defined intervals as capacity grows, giving businesses visibility on the direction of travel.

Recycled content and feedstock priorities

Recycled content is the one criterion where the JRC already proposes a mandatory performance threshold, but the initial minimum of 5 per cent sits far below what industry has shown is possible. Participants in The Jeans Redesign achieved up to 87 per cent post-consumer recycled content at commercial scale while still meeting durability requirements.

Where the recycled content comes is also significant. Diverting PET bottles into textiles pulls feedstock away from the packaging sector's established collection and recycling systems, and the resulting fibre often cannot be recycled again. With over 80 per cent of textile waste arising at the post-consumer stage, the Foundation argues the Delegated Act should prioritise fibre-to-fibre sources that keep material in closed-loop circulation. It says open-loop feedstock could be accommodated during a transition period, subject to a phase-out as closed-loop alternatives scale up.

Repairability and continuous improvement

France's textile Repair Bonus facilitated over 826,000 repairs in its first year, but practitioners found repair remained unviable where components were inaccessible or of poor quality. Subsidies cannot compensate for a design problem - and the JRC's current proposal, which simply asks brands to list repair services on the Digital Product Passport, does nothing to address the upstream choices that determine whether a garment can be repaired at all.

The JRC has acknowledged it is currently impractical to measure clothing repairability objectively, and the Foundation accepts further standardisation work is needed. But repairability should be a priority for a future revision of the Delegated Act and linked to the Right to Repair Directive's Annex II mechanism, the paper argues, rather than deferred indefinitely.

The white paper also recommends the Delegated Act include review clauses that raise thresholds at defined intervals, giving businesses lead time to adapt. The Jeans Redesign offers a precedent: when its minimum bar was raised mid-project in 2021, participants continued to meet it.

Hundreds of millions of euros have already been committed to textile recycling in Europe. H&M’s partnership with Syre accounts for EUR 550 million (around £465 million), Inditex has invested EUR 100 million (around £85 million) with Infinited Fiber, and Ambercycle has raised over EUR 70 million (around £59 million). Without mandatory performance requirements across the market, the companies behind those investments compete against products held to no equivalent standard - a dynamic that penalises the businesses that have already moved, the Foundation argues.

The white paper is available to download from the Ellen MacArthur Foundation website.