Of all the product groups under the ESPR, textiles is the one moving fastest. The Commission has named it a priority category, and the delegated act that will set the rules for clothing, footwear and home textiles is expected to be among the first to take effect, around 2027. For the thousands of European apparel brands and manufacturers, that is not a lot of runway.

Why textiles is first

Textiles is a high-impact, high-volume sector with a long, opaque supply chain — exactly the kind of category the regulation was written for. It also has an unusually large share of small and medium businesses, many of whom have never produced a lifecycle figure in their lives. That combination is why textiles has been pushed to the front, and why it is being watched as the template for everything that follows.

What the delegated act is expected to require

The final text is still being drafted, but the direction of travel is clear from the ESPR framework and the Commission's preparatory work. A textile passport is expected to carry:

  • Material composition — fibre content by share, including recycled or secondary materials
  • Country of origin and key stages of manufacture
  • Environmental impact — carbon, water and energy across the lifecycle
  • Durability, repairability and recyclability information
  • Certifications such as GOTS, OEKO-TEX or GRS, where held
  • Presence of any substances of concern

The data problem for SMEs

Here is the uncomfortable part. Most of that data is not sitting in a system waiting to be exported. Fibre content might live in a PLM tool, or in a supplier email, or on a spreadsheet. Carbon and water figures usually don't exist at all, because no one measured them.

The deadline isn't really about a QR code. It's about producing verified data you've never had to produce before — for every product.

Enterprise tools exist for this, but they are priced and built for the likes of large global brands, not a knitwear company in Donegal or a workwear maker in Poland. That gap is precisely where most of the market sits.

How to get ready now

You don't need a sustainability team to start. Three practical steps help:

  • Find your data. Locate where composition, origin and supplier information already lives — even if it's just spreadsheets. That's a valid starting point.
  • Map your certifications. Note which schemes you hold, the certificate numbers, expiry dates, and whether you or your supplier holds them.
  • Plan for the gaps. Decide how you'll source the impact figures you don't measure — emission-factor databases and models can fill these without lab testing every product.

This is the model Luxima is built around: bring in what you already have, however messy, and let the platform compute and complete the rest. Textiles is our first vertical for the same reason it's the EU's — it's where the deadline bites first, and where the need is greatest.