Why fashion is being regulated

Man-made cellulosic fibres including viscose, modal and lyocell are produced from wood pulp, and a share of that pulp has historically been sourced from ancient and endangered forests. Deforestation risk sits several tiers upstream of any brand that has never had direct contact with a pulp mill.

The EU Deforestation Regulation reaches fashion through wood, cattle and natural rubber: the pulp behind viscose, the hide behind leather, the sole of a shoe. Application was deferred a second time, to 30 December 2026 for medium and large operators and 30 June 2027 for micro and small operators. The 2026 updates narrowed the annex for some finished articles where leather is not the principal component, but raw and semi-finished hides remain in scope.

The response has been material innovation, much of it genuinely inventive: fibres derived from agricultural residue, citrus peel, banana stem and food waste streams, alongside mechanically and chemically recycled feedstock. Almost all of it remains at pilot volume against a market measured in tens of millions of tonnes.

Substitution is the intuitive answer and the slowest one. A fibre that does not yet exist at scale cannot decarbonise a range, and none of the deadlines are waiting for it.

The microplastics problem in fashion is, for the most part, a synthetic textiles problem. Polyester, nylon, acrylic and elastane are used in roughly 60% of clothing and 70% of household textiles. They shed across the whole life of the product: during manufacture, during wear, during every wash, and after disposal.

Microfibre release from synthetic textiles is now assessed as the fourth-largest source of microplastic pollution in the EU, behind paint, tyres and industrial pellets. Fragments have been found in food, in drinking water and in human tissue. The health evidence is still being assembled, and that is not a reason to wait for it.

The scale is still being revised upwards. A national survey led by the University of Portsmouth, using GB Row Challenge expeditions to sample coastal waters, found microplastic pollution around Britain's coastline could be double previous estimates. The research points to a wider distribution of smaller fragments than earlier studies captured, much of it originating from synthetic textile and plastic use.

It is also the least regulated of the harms on this page. The EU restriction on intentionally added microplastics covers glitter and microbeads. It does not reach fibre shedding from synthetic textiles, which is unintentional release and currently sits outside any binding threshold.

That is the gap the textiles delegated act is expected to close. Standardised test methods already exist in the ISO 4484 series, the product environmental footprint rules for apparel now require fibre fragment impacts to be reported for every fibre type including natural ones, and the evidence points at design as the largest single lever: tighter yarns, denser constructions, and industrial pre-washing with filtration before a garment is ever sold.

For a brand the implication is specific and uncomfortable. Recycled polyester answers a feedstock question and does not answer this one. A garment made from recovered bottles sheds in the same way as one made from virgin polymer, and the substitution that has carried most of the industry's synthetic sustainability messaging does not address the release at all.

Neither materials nor factories are the primary problem. The primary problem is that people buy more garments and pay less for each of them, and every efficiency gained per item is absorbed by the number of items.

This is not straightforwardly a failure. Clothing that was once expensive is now within reach of almost everyone, and the democratisation of fashion is a genuine social good. When Primark launches a collection at accessible prices it is answering real demand from customers for whom a sustainability premium is not a choice they can make.

That is the tension regulation has to resolve. Sustainability has been priced as an upgrade, sold at a green premium to the customers least exposed to the cost of the alternative. A system that only improves at the top of the market does not improve.

Underneath sits a linear product system: designed for volume, priced for turnover, and structurally uninterested in what happens after the sale. Circularity is not a material substitution. It is a different commercial model.

Almost every brand now publishes a sustainability report. It covers targets, emissions, materials volumes, supplier audits, and progress against commitments. It is useful — but it is about the organisation, not the product.

A Digital Product Passport is different. It sits on the individual item, style or batch, and it answers a different set of questions: what this garment is made of, where each component came from, who made it and under what conditions, what was applied to it, and what happens to it afterwards. Per item, structured, and auditable.

A report is written once for the company. A passport is written for every product that ships, and it must hold for that unit at every checkpoint. The evidence has to be captured at the point the fact becomes true — inside production, not after it. That is what changes now.