The Ecodesign Forum convened on 24th November to discuss the ongoing development of the methodology underpinning the Ecodesign for Sustainable Products Regulation (ESPR) and its early application in preparatory studies, most notably textiles. The meeting also covered progress on the destruction of unsold goods (DOUG) acts and updates on the Digital Product Passport (DPP). The meeting was very technical / academic. FESI will share presentations once available. The JRC will soon publish all the reports presented on their repository. FESI will share them with members and analyze them as well.

1. Textiles & Apparel under ESPR

Timeline and process

• Preparatory study for textiles/apparel launched: early 2023
• Planned finalisation: Q2 2026
• JRC methodology preparatory study – 3rd milestone and consultation on possible requirements:
  • Consultation launched in December 2025, open until late March 2026
• Stakeholder meeting: planned for Q1 2026 (exact date to be confirmed by JRC)
• Final stage of preparatory study and impact assessment will run in parallel
• Next Ecodesign Forum on textiles: indicative date Q2 2026
• Public consultation on the Commission’s “Have your say” portal: in 2026

Key takeways :

• The JRC presented methodologies for calculating the environmental performance. While different options were presented it seemed clear that a Full PEF (Product Environmental Footprint) will be required to assess performance requirements for textiles products.
• On labelling a dedicated study will determine whether there is a need for an ESPR label for textiles and how it should appear (on-pack, on-screen, in-store information, etc.).
• Priority is given to product-specific requirements; horizontal requirements apply to the remaining aspects.
• For footwear, no full preparatory study is planned at this stage. Instead, a lighter scoping study to be launched in 2026 will decide whether footwear should become a priority product in the next working plan.

Destruction of Unsold Goods (DOUG)

Delegated act on the destruction of unsold goods

State of play

• Draft discussed at the Ecodesign Forum on 20 February 2025
• Interservice consultation: 10–23 June 2025, after revision and approval by lead DGs and Cabinets
• “Have Your Say” consultation: 27 June – 19 July 2025
• Member States Expert Group consultation: 12 September 2025
• Next step: adoption by the Commission

Implementing act on disclosure of information on destruction of unsold consumer goods

State of play

• Draft discussed at Ecodesign Forum on 20 February 2025
• Interservice consultation: 16 April – 5 May 2025
• “Have Your Say” consultation: 3 June – 10 July 2025
• Consultation of Ecodesign Committee: 16 September 2025
• Approval by written procedure: 19 September 2025
• Next step: adoption by the Commission

When asked “When will the implementing and delegated acts on DOUG be published?”, the Commission replied that they are coming very fast but could not provide a more precise date.

Digital Product Passport (DPP)

• France asked whether the EU is planning communication on DPP. The Commission replied that DG GROW is working on it.
• In 2026, there will be a dedicated Ecodesign meeting to present the evolution and standardisation of DPP.

Two levels of work on DPP

• DPP system – horizontal framework (how the system is developed overall)
• DPP data – to be defined in product-specific delegated acts

Methodology, CN codes, label and ESPR review

• Questions were raised on CN codes in Article 2:
  • For certain products, the list uses 4-digit CN codes.
  • By default, 2-digit CN codes apply for all other products.
• A study will determine the need and design of an ESPR label (including possible digital-only formats).
• There will be a review of ESPR as a whole in 2030 to assess:
  • How the regulation worked in practice, and
  • How it contributed to the functioning of the internal market.
• Stakeholders stressed that the Commission should perform a “reality check” once the preparatory study is ready, comparing findings with economic reality and the complexity of implementation, especially against the backdrop of political discussions on simplification.

FESI intervention: PEF vs national schemes (e.g. French Eco-Score)

FESI (JP) asked about the prominence of PEF for textile products in the methodology presented by JRC and how this will interact with national initiatives and their respective PEFs, such as the French Eco-Score methodology / label.

Commission’s answer (key message)

• If something becomes a performance or information requirement under ESPR,
• Member States will not be allowed to maintain diverging national schemes on that same aspect, and will have to withdraw them.

In other words, once ESPR sets common EU rules (e.g. based on PEF for textiles), national systems like Eco-Score will have to be adjusted or phased out insofar as they overlap with ESPR requirements and could fragment the internal market.

Impact assessment & process clarifications

• The impact assessment will run in parallel with the final stage of the preparatory study.
• The impact assessment will test options that are based on the measures identified in the preparatory study.

Next steps & how to contribute

1. Publication of the JRC methodology report(s)

• Some reports are expected this week, others in the coming weeks.

• All will be available on the JRC repository:

• JRC Publications Repository: https://publications.jrc.ec.europa.eu/repository/

2. Use of the methodology in preparatory studies

• The methodology will be progressively integrated into ESPR preparatory studies, starting with textiles.

3. Stakeholder input

• Comments and feedback on the methodology can be sent to:

• JRC-ESPR-METHODOLOGY@ec.europa.eu

• There is no formal deadline; stakeholders are encouraged to “take their time”, but in practice, earlier input will better influence the ongoing work (2025–2026).

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