The Joint Research Centre, a European governmental team that provides independent, evidence-based knowledge and science supporting EU policies, presented the Third Milestone Technical Report on Textiles in January 2026. This report is quite important for apparel and textiles companies selling in the E.U. because it forms the technical foundation for mandatory Digital Product Passport (DPP) requirements under the Ecodesign for Sustainable Products Regulation. This is the third milestone and there is one more milestone coming, but with this document we have the information available that shifts this effort from sustainability ambition to enforceable requirements for the apparel industry.

The report represents likely ecodesign requirements proposing design options for how requirements rather than finalized laws. This is especially interesting for apparel companies that recognize the best time to prepare for requirements is now, just as the content of the regulations is made available with the third milestone report. The milestones are described here:
1st milestone: Scope, market, user behaviour, current EU Ecolabel criteria, current EU Green Public Procurement criteria (23 February to 22 April 2024)
2nd milestone: Technologies, framework and data gaps of environmental and economic model, and a questionnaire about substances and substances of concern (14 November 2024 to 17 March 2025)
3rd milestone: Analysis of base case and design options 16 December 2025 to 23 March 2026
4th milestone: Policy scenarios, and elements to be included in the Digital Product Passport (TBD)
You can find the full text of the report’s working document, from December 2025, on the JRC website, here:

The study outlines several proposed “Design Options” (DOs) that would require apparel companies to report the following on product labels or packaging:

Products would need to display a robustness score ranging from 0 to 10. This score is based on a cumulative evaluation of key parameters including spirality, dimensional change, and visual inspection of color, fabric, seams, and non-textile parts. Some of these terms are not intuitive, although industry veterans would understand most of them. For the sake of clarity though, we’ll go into what these mean:

1. Spirality

Also known as “torque,” it refers to the lateral rotation that occurs between different panels of a garment. This is caused by the release of stresses within the woven or knitted fabric during laundering. An example of this is when a pair of denim jeans is worn and the side seam slowly twists around to the front of your leg after a few washes. This is sometimes called “leg twist,” and is a good example of spirality. This “spirality” is proposed to be measured quantitatively as a percentage using the ISO 16322-3 standard.

2. Dimensional Change

This  refers to how much a garment shrinks or stretches and is evaluated using the ISO 3759 standard. The details on those testing standards are more than we plan to get into with this article but you can find the documentation on the international standards site here: https://www.iso.org/standard/57309.html

Testing is meant to measure the percentage of change (represented as a ± percentage, such as ±3% or ±5%), ensuring a garment retains its intended size and fit even after laundering.

3. Visual Inspection

Visual inspection relies on the ISO 15487 (feel free to check the international standards site for details) standard to assess the physical degradation of the garment’s appearance. The overall performance level for this category is determined by the worst-performing sub-parameter. The visual inspection is broken down into four main areas:

• Color: The testers look for color change, staining, and the degradation of printing patterns.
  • Notable Exception: If an item is intentionally designed to change color over time (for example, denim dyed with indigo techniques to achieve a vintage look), it should not be penalized for color change, provided the brand clearly communicates this design choice to the user. It’s not yet clear if this kind of exception will be considered, based on the JRC report, but you’d like to think it would be taken into account. Push back from our colleagues in the denim industry would likely be successful, if it was necessary, based on anecdotal evidence.
• Fabric: The fabric is evaluated for smoothness, pilling (little balls of fiber), fuzzing, and matting.
• Seams: The structural seams of the garment are checked for smoothness and slippage or anywhere the fabric pulls away from the stitching.

Non-Textile Parts: This evaluates both the appearance and the proper functioning of hardware and embellishments. It includes items like buttons, slide fasteners (zippers), press fasteners, touch-and-close fasteners (like Velcro), labels, and embroidery.

A similar 0 to 10 scoring system is proposed to indicate a garment’s recyclability. A product will automatically receive a score of 0 and be labeled “Non-recyclable” if it contains elastane in proportions higher than 15% (or 20% for PA6-rich blends). Higher scores are awarded for facilitating pre-treatment (e.g., being mono-material, free of printings or coatings) and being compatible with operational recycling techniques.

Here is a chart that describes how points can be awarded for the recyclability score, according to the proposed design option:

One of the more interesting assessment criteria on the impact of a recyclability requirement for apparel is based on the assumption that an additional cost of labeling is estimated to be €0.02/unit. This number was arrived at as the smallest number in an analysis conducted by Marschinski, R. et. al. (2025) was chosen because apparel already has labels, meaning there shouldn’t be any need to create a new one and the information can be included in the existing label format. Between the lines, we can read that this means information can be provided by a URL or more conveniently a QR code.

The prep study indicates that companies would be required to report secondary material used in their products, by weight. In this regard, the prep study reports that a threshold of 20% recycled cotton should be proposed for denim products, with a study by Maud Kuppen (2024) describing that adding up to 30% pre-consumer recycled textiles doesn’t have any noteable negative effect on the quality or processability of the final product. For nylon that would be 5%, for wool it’s 10%, and for polyester in knitted and other woven items, it’s 15%. The study goes into why a higher percentage of recovered cotton has a higher societal benefit relative to other materials. That’s interesting from two perspectives: first companies planning their production should consider the thresholds to be expected, based on the prep study. Second, regardless of what the planned production ratios for materials are for a company, reporting ratios will be a requirement.

Finally, cost of certification is also discussed, with the estimated cost being set at €0.13/unit.

The information requirement could also mandate reporting the origin of waste material, distinguishing between post-consumer and post-industrial waste, or between fiber-to-fiber recycling and open-loop recycling (like PET bottles). So long as the DPP scheme a producer chooses to implement can accommodate that information, there’s no big problem to consider there.

Instead of a mandatory footprint declaration, the study proposes a voluntary “excellence” label. Manufacturers can calculate their manufacturing footprint according to specific rules and, if their product performs better than the industry benchmark, they can display this on the label (e.g., indicating by what percentage they beat the average). If a company chooses to report this, they must explicitly state whether they used primary or secondary data.

That said, the proposal for calculation of the environmental or carbon footprint indicator is that the rules are defined in the PEFCR for apparel and footwear. You can learn more about that at https://pefapparelandfootwear.eu/ though in short, the point is to establish a framework for the whole industry to discuss environmental impact using the same terminology and methods.

The study tried to estimate administrative costs associated with this design option based on the impact assessment of Regulation (EU) 2023/1542. The keen eyed among you readers will notice that this is the so-called battery regulation. Considering the differences between the supply chains for batteries and textiles, it seems a little odd that this is what the team preparing this study proposed, but the fact that textiles are expected to require similar calculation and verification of indicators was deemed as more important. For companies, you can expect that a carbon footprint calculation, similar to the carbon lifecycle formula described in the battery regulation for how to calculate the carbon emission score for a battery, will be required.

Substances of concern are a serious topic, but perhaps most because both the incredible quantity of them is staggering and the difficulty in determining which ones are present in the final apparel product is difficult if not impossible to determine with certainty. Largely due to those reasons, the prep study more or less shows that the research on how to establish information requirements for this category resulted in the team throwing their hands up. Per the study, which exhaustively initiatives and lists or label schemes that are concerned with restricted substances, or substances of concern, it appears that ultimately anyone placing apparel for sale in the E.U. needs to make “reasonable efforts” to use the DPP to report presence of any concerning substances. So what are those substances? Regulation (EC) No 1907/2006 includes an Article 59(1) that lays out how to identify those substances. The ESPR calls these “SoCs type (a)”. The criteria from Article 59(1) includes:

• CMR Substances: Substances classified as carcinogenic, mutagenic, or toxic for reproduction (Categories 1 or 2).
• PBT Substances: Substances that are persistent, bioaccumulative, and toxic.
• vPvB Substances: Substances that are very persistent and very bioaccumulative.
• Endocrine Disruptors: Substances with endocrine disrupting properties that may have serious effects on human health or the environment.

If any of these substances are present in your company’s apparel, well you have bigger problems then simply knowing that you are expected to report them, but it’s clearly helpful for any apparel company that is eager to get into compliance.

While mandating the provision of repair instructions across the board is considered an “unwarranted administrative burden”, the JRC study suggests using the Digital Product Passport for voluntary repair reporting for companies that will offer that directly to their customers.

The most likely scenario for requirements, considering the complexity of the topic and how it is addressed in the JRC report is that many of the brands associated with durability, such as Patagonia, will continue to offer repair options alongside the apparel DPP. Here is the text from the report:

“Additionally, mandating the provision of repair instructions appears unwarranted…in the view of the Preparatory Study team do not justify the administrative burden for manufacturers to produce them across the board, as a general requirement. Moreover, the analysis of user behaviour does not identify the lack of information as a barrier to repair versus discard or replacement decisions. Instead, factors like emotional attachment, fashion trends, and repair costs are highlighted, none of which are addressed by the considered requirements.

…Instead, information requirements could rather focus on repair services directly offered by the brand (if any), including their details and contact information, via the Digital Product Passport. This requirement is proposed to be voluntary and to only apply when the service is provided by the retailer...”

As we mentioned in the design option sections earlier in this article, the study estimates that the cost of adding new information requirements to products will be minimal, around €0.02 per unit. This assumes that the required scores and data can simply be incorporated into the existing hang tags already present at the point of sale, avoiding the need to create entirely new physical labels. That cost leaves out the “digital” part of a digital product passport though, especially if companies are taking the opportunity to add new functionality, such as unit to lot associations for traceability or commercial purposes and other features. Remember also that certification costs may need to be calculated on a per unit basis. Using a printed QR code to deliver information is already being piloted by companies looking to get ahead of reporting requirements in a cost-efficient way though. The following is our advisory for companies that want to create a pilot apparel DPP.

To prepare for the upcoming mandatory Digital Product Passport (DPP) requirements under the Ecodesign for Sustainable Products Regulation (ESPR), apparel companies should transition from theoretical understanding to practical application.

Based on the JRC 3rd Milestone Technical Report (January 2026), the following guide outlines how to structure a DPP pilot project to ensure regulatory readiness and operational alignment.

A DPP pilot enables your organization to test key hypotheses in a controlled environment, validate workflows under real-world conditions, and identify gaps or optimization opportunities early. It also allows for clearer specification of custom development requirements, ensuring future investments are targeted, efficient, and aligned with actual business needs.
By introducing a pilot phase, apparel companies gain early visibility into the compliance process, align internal stakeholder expectations, and increase confidence before full deployment—timing the transition to coincide with the release of the final delegated acts.

To be effective, your DPP infrastructure must include these core features at a minimum:

• Administrative Control: At least a single user administrator account for the online management environment.
• Dynamic Connectivity: Campaign URLs with the option to redirect URLs for products and the ability to use custom domain names identifying your brand.
• Content Management: A mobile landing page template where products can be updated with environmental claims, traceability info, and mandatory particulars (e.g., Robustness Scores or Spirality).
• Data Structure: Availability of supply chain fields (Production Date, Batch Number, Country of Origin) and features for bulk upload of product data across multiple SKUs.
• Serialization: The ability to generate and associate serialized QR codes with specific products.
• Technical Scalability: API access for programmatic updates and access to dedicated technical support or a help center.

Phase 1: Project Kickoff & Gap Assessment

• Objectives: Establish governance and define the scope.
• Actions: Conduct a workshop with stakeholders to share latest JRC guidance; assess current product, supplier, and sustainability data against expected requirements.
• Deliverables: Gap analysis report, basic project plan, and defined pilot objectives.

Phase 2: Data Model & Traceability Framework

• Objectives: Map the information flow.
• Actions: Define the data model (identifiers, material composition, supplier origins, repair/recycling info); develop protocols for collecting data from suppliers.
• Deliverables: DPP attribute list, supplier data collection SOPs, and populated data templates.

Phase 3: Technology Implementation

• Objectives: Build the digital-to-physical link.
• Actions: Generate QR codes for pilot products; configure the management platform to store/manage data at the SKU or batch level; enable product landing pages.
• Deliverables: Live pilot environment, physical QR codes applied to products/packaging, and a dashboard with analytics.

Phase 4: Consumer & Retailer Pilot

• Objectives: Test real-world engagement.
• Actions: Deploy enabled products in retail and e-commerce; monitor scan behavior and collect feedback from retail staff and consumers.
• Deliverables: Consumer experience surveys and an analytics report on engagement rates.

Phase 5: Pilot Summary & Scaling

• Objectives: Evaluate performance and plan for the future.
• Actions: Benchmark outputs against ESPR requirements; identify missing data or process bottlenecks; develop a roadmap for full rollout (2026–2030).
• Deliverables: Final compliance assessment and a scalability roadmap for the entire product portfolio.

Beyond simple compliance, the pilot should aim to:

1. Map the Framework: Establish a traceability model aligned with EU ESPR requirements.
2. Test Durability Reporting: Validate the ability to report on “Robustness” (ISO 16322-3 for spirality and ISO 3759 for dimensional change).
3. Evaluate Recyclability: Implement the 0–10 scoring system, specifically identifying high-elastane “non-recyclable” items.
4. Validate Disclosures: Practice reporting secondary material mass and the distinction between post-consumer and post-industrial waste.

It’s possible that the fourth and last design option that marks the final requirements for textiles and apparel won’t be available until Q2 2027. Despite that, we have a very strong indication of what is required and pilot programs like CIRPASS2 are already establishing technical requirements that are common to all industries so that companies that want to get ahead of the requirements can absolutely do that starting well ahead of the requirements being delivered. Many companies are already doing just that.