The most significant product legislation in fashion's history. And most brands are not ready.

The EU Ecodesign for Sustainable Products Regulation entered into force in July 2024. It replaces the old Ecodesign Directive, which applied only to energy-related products. ESPR is categorically different in scope.

ESPR applies to almost all physical products sold in the EU market, including textiles, apparel, footwear, and accessories. It is not a reporting standard, a voluntary framework, or an industry initiative. It is binding legislation with enforcement mechanisms, market surveillance powers, and the ability to block non-compliant products from sale.

Under ESPR, every product sold in the EU will eventually require a Digital Product Passport, a machine-readable, publicly accessible data record carrying verified information about the product's materials, origin, carbon footprint, circularity, and supply chain.

ESPR is the anchor — the regulation every fashion business selling into the EU must prepare for first. But it doesn't arrive alone. We track 50 fashion and textile regulations across 14 jurisdictions — PFAS bans, EPR schemes, green claims enforcement, forced labour rules, waste export controls — so our clients see the whole board, not just the biggest piece.

The UK is not subject to ESPR as domestic law. The UK has its own parallel legislation, the Product Regulation and Metrology Act 2025, which is expected to introduce equivalent Digital Product Passport requirements for the UK market. But for any UK brand selling into the EU, ESPR applies in full.

UK brands selling into the EU, directly, through a retailer, via a marketplace, or through a distributor, are treated as third-country operators. That triggers a question most brands have never answered: who is your responsible economic operator inside the EU?

Under ESPR the obligation sits with whoever places the product on the EU market — an EU-based importer, or an Authorised Representative appointed in writing by the manufacturer. If you sell through a distributor, that duty may already sit with them, and they may not know they are carrying it. Under the General Product Safety Regulation, in force since 13 December 2024, a product placed on the EU market by a non-EU manufacturer must have a responsible person established in the Union.

Appointing an Authorised Representative is not a fix. Under ESPR, drawing up the technical documentation is explicitly excluded from their mandate. They are the accountable contact for regulators, not the author of your compliance evidence. Only you can produce that.