Although we firmly believe here at COSH! that all stakeholders (brands, stores, consumers) must work together to change the fashion and textile industry, we also believe governments have an important role to play by providing the appropriate regulatory framework. Wondering how the EU is doing this? We looked into this and put together the following blog to help you navigate the EU’s initiatives. Thanks to the Traceability workshop at Circular Textile Days which gave us a platform to discuss these with other experts in the fashion industry.

Design phase

As we all know, we need to change the way we produce clothes in order to reduce their impact on our planet. How is the EU working towards this?

By bringing in a set of design requirements, called Ecodesign, that will oblige manufacturers to make products more circular. These requirements will, for example, be linked to a product’s recycled content, recyclability and non-toxicity. In practice, this could translate to clothes needing to contain XX% recycled materials and limiting the use of certain materials to prevent the release of microplastics. This information should then be made readily available to everyone throughout the supply chain, likely via the introduction of Digital Passports for products. In theory, one could then read this passport to see how to repair or recycle (among other information) their item of clothing. The European Commission’s proposed legislation is currently being discussed by the European Parliament and EU countries. We don’t expect this to enter into force before the end of 2023, at the earliest.

An additional piece of legislation is also in the works to further tackle the unintentional release of microplastics (read our blog here about polyester and microplastics pollution). The European Commission is expected to present its ideas in this area by the end of 2022. So far, they have hinted at tackling this extremely harmful type of pollution through labelling, standardisation, certification and regulatory measures.

Did you read our piece about the use of PFAS, better known as “forever chemicals”, in the textile industry? If you did, you’ll be happy to know that the EU is trying to address this by restricting the use of all PFAS via the EU’s chemical regulations framework REACH. This would prevent manufacturers from being able to use all PFAS in non-essential settings, such as waterproof fashion jackets. Currently only some PFAS are restricted meaning the chemicals industry replaces them with non-regulated PFAS… A restriction on all PFAS is desperately needed and is expected to come into force in 2025.

What does this mean for retailers and brands?

This might create additional work for brands, depending on their involvement in the production chain, and increase prices slightly. However, it will also make it much easier to guarantee the composition of the products you’re buying, and for retailers, to verify the credentials of the brands you’re stocking.


Just as important as the environmental transition, the fashion industry must also make an ethical transition, ensuring that workers all along the supply chain are working in safe conditions and getting paid fair wages.

It’s well known that large corporations in the fashion industry (think H&M, Inditex, etc.) are able to sell their clothes for so cheap because they abuse their workers. The EU would like to tackle this by introducing a duty of due diligence for corporations. The European Commission’s proposed legislation means big brands will be held accountable for human rights and environmental abuses throughout their global value chains in European courts. This is slowly making its way through the European Parliament and EU countries so might come into force at the end of 2023, at the earliest. Although this is a step in the right direction, this is in no means a ban on the sale of products which have been produced in unacceptable conditions… These products will still be able to make their way into the EU so here at COSH! we would like to see more being done!

What does this mean for retailers and brands?

SMEs are not currently targeted in this proposal so it should not bring about any changes for small retailers and brands, other than new customers who have decided to move away from fast fashion.


Here, at COSH! we know how frustrating it is to see big fast fashion brands bring out collections they claim are sustainable, change their branding to use colours which suggest they are more environmentally-friendly than they are, etc… Greenwashing comes in many (destructive) forms, but the EU would like to put an end to this to protect consumers & ensure they are getting access to correct information!

One of the ways it plans to cut down on illegitimate “green claims” (as they call it) is by updating the Consumer Rights Directive, to obliger producers to provide information on the repairability and durability of their products, and an update also to the Unfair Commercial Practices Directive, to, for example, prevent producers from being able to make generic environmental claims. The European Commission’s proposal is being discussed by the European Parliament and EU countries. It’s expected that these changes will come into force, at the earliest, at the end of 2023.

The Digital Product Passports we mentioned above will also be extremely important here. Indeed, they’ll grant consumers access to precise info about a range of sustainability aspects, leaving no room for greenwashing. If you’re interested, these passports will likely follow the Product Environmental Footprint (PEF) methodology that they have been testing for a few years.

What does this mean for retailers and brands?

These measures will create some additional work for brands, but it’s all for a good cause! Plus, it will allow your eco-warrior brand to stand out even more because it will cut down on the amount of brands marketing themselves as green (when they are often not…). Nevertheless, here at COSH!, we will continue to double check brands performances to uncover any ethical or environmental issues.

End-of-life of the products

You’ve likely heard of the mountains of textile waste that now exist and of the scary statistic that only about 1% of textiles are recycled into textiles… It’s quite overwhelming when you think about it all. Luckily, by changing the way we design clothes and treat them at the end of their lives, we can tackle this.

The new Ecodesign requirements will be absolutely crucial to cutting down on textile waste that ends up in landfill. They will force producers to design clothes with their repairability and recyclability in mind. At COSH!, we hope these will include a limitation on blends of materials and fibres that textile manufacturers are allowed to use.

One big issue currently is the collection of waste, and of specific interest to us, the collection of textiles. Over the next couple of years, we will see a revision of the Waste Framework Directive which should lead to mandatory separate collection of textiles across the EU. This will “purify” the waste stream and make it easier for textile recyclers to do their jobs. The European Commission will make their proposal at the end of this year and the revision is set for 2023.

Another aspect to this revision will be the introduction of Extended Producer Responsibility (EPR) schemes to the textile industry. These schemes reinforce the polluter-pays principle (which underlies the EU’s environmental legislation) and provide producers with real incentives to extend the lifespan of their clothes. Read here about the Netherlands’ own national take on EPR schemes.

Did you know that every day 150-200 billion tonnes of textiles are shipped to African countries? Read Greenpeace’s report about it here. The shipment of our textile waste to countries that do not have the facilities to deal with it is an issue many are not aware of. It’s extremely detrimental to the health of local populations in those countries, as well as the environment. The EU needs to stop exporting its unwanted waste and the European Commission proposes to fight this by revising its Waste Shipment Regulation, to monitor much more closely these waste streams. For example, regarding textile waste, it could only be exported to non-OECD countries who have proved to the EU that they can deal with the waste. OECD countries would be able to import it more easily but if the EU sees that it is not being treated sustainably, then it will suspect exports. This revision will hopefully enter into force in 2023.

What does this mean for retailers and brands?

The Ecodesign requirements will obviously change how clothes are produced, having consequences therefore for brands and retailers (if brands put prices up). However, the measures targeting waste streams should make it easier to get access to suitable recycled content to be used in clothes production.