RREUSE provided feedback on the 3rd milestone report for the preparatory study on ecodesign for textile apparel under the Ecodesign for Sustainable Products Regulation (ESPR). The study, carried out by the EU Joint Research Centre (JRC), aims to propose potential ecodesign measures to make textile apparel products sold in the EU sustainable and circular by design.
In our feedback, we provide suggestions on the current draft proposal, focusing on how reusability can be better integrated as an objective across all potential measures. We also propose a more granular classification system of garments and fibre types to set more appropriate requirements. Regarding the measures proposed by the JRC, we express concerns about the predominance of information requirements over performance requirements, particularly regarding aspects such as physical durability and recyclability. Ecodesign should focus on making sustainable products the norm by design, and performance requirements are essential to achieve this. We also advocate for the inclusion of repairability as a crucial product aspect to address through ecodesign requirements. Our feedback also stresses the need to integrate the emotional durability of textiles into ecodesign measures and provides suggestions on how to link these to future criteria for the ecomodulation of extended producer responsibility (EPR) fees for textiles.
