Apparel Exporter Compliance EU: CSRD, CSDDD, ESPR, DPP, EPR and PFAS in One Map

The apparel industry’s compliance rulebook is getting thicker by the year, and apparel exporters know it. That was the central message from Apparel Resources’ September 2026 interviews with representatives of FSC India, bluesign and UL Solutions — and the two months since have only added to the pile. The EU has narrowed its two biggest sustainability laws, voted on waste rules, and started applying new PFAS limits, all while the product passport that exporters have been preparing for still has no adopted timetable.

This article is a map, not a legal opinion. It sets out each major requirement, states plainly whether it is in force, narrowed, still in negotiation or not yet written, and explains what each one asks of a factory. Where a rule has changed since September, this article uses the November position.

This article provides general industry information, not legal or regulatory advice. Applicability depends on the product, customs classification, business role, destination market and relevant national implementation measures. Exporters should obtain a product-specific assessment before making compliance or market-access decisions.

The map at a glance

Legal status in this table uses five categories only: In force and applicable; In force but not yet applicable; Adopted legislation requiring national transposition; Legislative proposal under negotiation; Planned or anticipated secondary legislation. “In force” and “applicable” are not the same thing: a regulation can be in force while its main duties start on a later date, and a directive binds member states first and companies only once it is transposed into national law.

Each row also carries one of three labels. Direct statutory obligation means the law itself binds the actor named. Indirect value-chain information request means an in-scope customer asks a supplier for data or assurances — the supplier is not itself directly in scope. Voluntary or contractual buyer requirement means a buyer asks for something the law does not require, for example conformance to an industry standard. Being asked for information is not the same as being directly subject to a directive.

For this article, nine pages were checked on 9 November 2026 through two searches — “apparel exporter compliance EU” (four results) and “EU apparel compliance map 2026” (five results). Seven were read in full — three CBI pages, TLD Apparel, Seamdex, WISEPIM and Lappa — and two, OneAim and Gearplant, were assessed from their search summaries only. None of the seven pages read in full combines what this map does in one place: a single table that states each rule’s legal status in the same five categories and labels who it binds, a side-by-side separation of the REACH PFHxA 25 ppb finished-article limit from the ZDHC 25 µg/kg formulation limit so the two 25s are not read as one rule, and a CSRD–CSDDD comparison that sets out the different thresholds, dates and supplier protections.

CSRD and CSDDD after Omnibus I: narrower, later, still felt

The most important change since the Apparel Resources interviews is also the most misunderstood. On 26 February 2026 the EU published Directive (EU) 2026/470 — Omnibus I — in the Official Journal, and it entered into force on 18 March 2026. It rewrote both the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) before either had fully applied.

For the CSRD, mandatory sustainability reporting now applies only to EU companies employing, on average, more than 1,000 employees with net annual turnover above €450 million, and to non-EU parent companies only where two conditions are both met (Article 40a of Directive 2013/34/EU, as amended by Directive (EU) 2026/470): the group generated more than €450 million of net turnover in the EU in each of the last two consecutive financial years, and it has an EU subsidiary — or, where there is none, an EU branch — with net turnover above €200 million in the preceding financial year. In that case the non-EU parent reports at group level, with first reports for financial year 2028. The separate reporting standard for third-country groups (ESRS-40a) is still in draft — EFRAG published an exposure draft for consultation on 23 July 2026, the consultation closed on 31 October 2026 and EFRAG’s technical advice is expected in January 2027, and the Commission has not yet adopted it — so the content of that report may still change. Listed small and medium-sized enterprises are out of mandatory scope entirely. Member states must transpose the changes by 19 March 2027, and companies in scope report on financial year 2027 under revised European Sustainability Reporting Standards.

For the CSDDD, the narrowing is sharper still. It now applies only to EU companies with more than 5,000 employees and more than €1.5 billion in net worldwide turnover — and to ultimate parent companies of groups meeting those thresholds — or to non-EU companies generating more than €1.5 billion of turnover within the EU. A separate route into scope covers franchising and licensing (Article 2 of the CSDDD, as amended by Directive (EU) 2026/470): EU companies — and ultimate parent companies of groups — that entered into franchising or licensing agreements in the EU with independent third parties in return for royalties are in scope where those royalties exceeded €75 million in the last financial year and the company or group had net worldwide turnover above €275 million; for non-EU companies the same €75 million royalty test applies to royalties generated in the EU and the €275 million test to turnover generated in the EU. The thresholds must be met in two consecutive financial years. Member states must transpose the amendments by 26 July 2028, and the rules apply from 26 July 2029 — except that the annual statement on implementation (Article 16) applies for financial years starting on or after 1 January 2030 (Article 37(1) as replaced by Directive (EU) 2026/470). The obligation to adopt and put into effect a climate transition plan has been deleted (Article 22 of the CSDDD), although a company that has such a plan must still disclose it under the CSRD reporting rules. The harmonised EU civil liability regime has been removed (Article 29(1) deleted): whether a company is liable now depends on national law, with the Directive retaining only a rule that, where national law does impose liability, victims have a right to full compensation, and that full compensation must not lead to overcompensation, whether by means of punitive, multiple or other types of damages (Article 29(2) as amended). The maximum fine is now set at 3% of net worldwide turnover in the financial year preceding the decision to impose the fine — a uniform ceiling, where the original Directive required Member States to set the maximum at no less than 5% — or, for ultimate parent companies, 3% of net consolidated worldwide turnover calculated at the level of the ultimate parent company (Article 27(4), as replaced by Directive (EU) 2026/470).

CSRD and CSDDD are often described as if they worked the same way. They do not. One is a reporting duty; the other is a duty to act on risks.

Two consequences follow for factories. First, almost no garment manufacturer is directly in scope of either directive — the thresholds are set for the world’s largest companies. Second, many garment manufacturers may face indirect commercial and information requests from customers subject to sustainability reporting or due-diligence obligations. However, being a supplier does not automatically make a manufacturer directly subject to CSRD or CSDDD. The scope and proportionality of information requests depend on the applicable legal framework, the supplier’s characteristics and the customer’s specific obligations. The CSRD value-chain cap (Article 19a(3) of Directive 2013/34/EU, as amended by Directive (EU) 2026/470) protects a “protected undertaking”: one in the reporting undertaking’s value chain that does not exceed, on its balance-sheet date, an average of 1,000 employees during the preceding financial year. A reporting undertaking must not require sustainability information from a protected undertaking beyond the datapoints in Annex II to Delegated Regulation (EU) 2026/1560 (the voluntary sustainability reporting standard, adopted 3 July 2026), and any contract term requiring more is not binding. The reporting undertaking may rely on the supplier’s self-declaration of size, with no verification required unless it knows, or can reasonably be expected to know, that the declaration is manifestly incorrect. The cap covers CSRD sustainability-reporting requests only: it does not restrict requests needed to comply with other EU or national law, and it does not cover due-diligence requests. It applies from financial years starting on or after 1 January 2027. Due-diligence requests are governed instead by the CSDDD’s own limit in Article 8(2a): for the in-depth assessment, an in-scope company may ask a business partner for information only where it is necessary, and, where the partner has fewer than 5,000 employees, only where the information cannot reasonably be obtained by other means. The scoping exercise that precedes the in-depth assessment is based solely on reasonably available information (Article 8(2)(a)), which, as the Directive’s Recital 39 puts it, will as a general rule preclude asking business partners for information at that stage — a general rule, not an absolute bar, since companies retain flexibility in judging what information is reasonably available to them. Neither limit stops a buyer from asking for more on a voluntary or contractual basis — and in practice much of the information a customer needs can only come from the supplier itself, so the CSDDD limit is a proportionality test, not a right to refuse all questions. The Commission must adopt guidelines by 26 July 2027 on due-diligence processes, risk identification and model contractual clauses (Articles 18 and 19(3) of the CSDDD, as amended by Directive (EU) 2026/470). The practical effect is that a factory’s ability to answer questions about its workforce, wages, chemicals and subcontracting becomes a commercial asset, not merely a compliance exercise.

“No direct duty” needs one qualification. The CSDDD’s duties, penalties and liability attach to in-scope companies only, and Article 8(2a) is a limit on what those companies may ask of business partners — a protection for suppliers, not an obligation on them. But suppliers are not untouched by the Directive: where relevant, in-scope companies must seek contractual assurances from their direct business partners that the partner will comply with the company’s code of conduct and, as necessary, a prevention or corrective action plan, including by establishing corresponding assurances further down the chain (Articles 10(2)(b) and 11(3)(c)); they may request information subject to the Article 8(2a) limits; and, as a last resort where prevention or correction has failed, they must refrain from entering into new or extending existing relationships and, where the law governing the relationship so entitles them, suspend the relationship, alongside an enhanced prevention or corrective action plan (Articles 10(6) and 11(7)). Suspension is conditional: before suspending, the company must assess whether the adverse impacts of doing so can reasonably be expected to be manifestly more severe than the impact that could not be prevented or brought to an end. A supplier that itself meets the Article 2 thresholds is in scope in its own right.

Our detailed guide to the amended due-diligence rules sets out the thresholds, dates and supplier effects: CSDDD After the Omnibus: Scope, Dates and What It Means for Apparel Suppliers

ESPR and the digital product passport: what exists and what does not

The Ecodesign for Sustainable Products Regulation (ESPR) is in force, but the delegated act that would set product-specific requirements for textiles has not been adopted. Textiles is a top-priority product group under the ESPR working plan adopted on 16 April 2025, and the indicative year given for adoption is 2027; Commission planning pages narrow this to the fourth quarter of 2027, with obligations expected to follow after a transition period — under ESPR Article 4(4), a delegated act’s date of application shall not be earlier than 18 months after its entry into force, except in duly justified cases (for the whole act or for specific requirements) or for partial repeal or amendment of delegated acts, so 18 months is the default lead time, not a guaranteed one. Both of those are Commission planning assumptions, not law, and should be treated as such. There is no adopted fibre-composition publication requirement, no repairability score obligation and no mandatory passport for a jacket today.

What does exist is the ban on the destruction of unsold apparel, clothing accessories and footwear listed in Annex VII of Regulation (EU) 2024/1781, which has applied to large companies since 19 July 2026. Annex VII is a closed list drawn by customs code: it covers apparel, clothing accessories and footwear — not all textile products, so home textiles and other textile goods outside the listed codes are not covered, although the Commission may add further product groups by delegated act. Micro and small enterprises are exempt, and the ban extends to medium-sized enterprises from 19 July 2030. Derogations are no longer only a possibility: the Commission has adopted Delegated Regulation (EU) 2026/296, which sets out ten derogations — covering, among others, dangerous products, products that cannot lawfully be sold, and products refused for donation — each subject to documentation. That is already binding, and it is the most immediate ESPR effect on the apparel sector.

The digital product passport itself remains a preparation exercise: the data that a passport would carry — fibre composition, chemical information, repair and recycling data — is the same data that buyers are already asking for under other rules. Our guide to the passport explains what suppliers should be gathering now: Digital Product Passport for Textiles: What Apparel Suppliers Need to Know in 2026

EPR: the 20 October vote, precisely

A directive binds member states first: the producer duties described in this section arise only once each member state has transposed Directive (EU) 2025/1892 and established its scheme, so until then they are duties the law will impose, not duties already owed.

On 20 October 2026 the European Parliament adopted its first-reading position on a directive that would suspend one specific EPR duty — appointing an authorised representative in every member state where a producer sells — for producers established in the EU that qualify as micro or small enterprises (fewer than 50 employees and annual turnover and/or annual balance-sheet total not exceeding EUR 10 million). The vote was 612 in favour, 8 against and 39 abstentions. The suspension would run until 1 January 2035 or until a future Circular Economy Act applies, whichever is earlier. The adopted text (P10_TA(2026)0344) covers textiles, footwear, electrical and electronic equipment and specified single-use plastic products; a companion regulation covering batteries and packaging was adopted 616 in favour, 9 against and 39 abstentions. Parliament also wrote in an explicit clause excluding companies that split or artificially restructure their business to qualify, and referred the file back to committee for interinstitutional negotiation — the position is a negotiating text, not law. The Council has not adopted a position on this directive; its 21 October 2026 negotiating mandate covers packaging only (an exemption where a producer places less than one tonne of packaging per year on a member state’s market, until 1 January 2032, with a Commission review by 31 December 2030).

Three qualifications are essential, and they are the ones most often dropped from summaries. First, this is a first-reading position, not a final act: the Council has not adopted its position on this directive, and the file now goes to interinstitutional negotiation. The relief is not law. Second, it does not reach producers established outside the EU — a Bangladeshi, Indian or Chinese producer selling into Europe gets no benefit from it. Whether such a producer needs an authorised representative depends on the member state concerned (see below); the Parliament’s relief does not change that. Third, it suspends only the representative appointment; registration, reporting and fee obligations are untouched.

One point of terminology matters here. In EPR law the obligated actor is the “producer”, defined in Article 3(4b) of the Waste Framework Directive as amended — and the definition turns on who first makes the product available on a member state’s market, not on who sewed it. Four cases count: an EU-established manufacturer supplying under its own name or trademark; an EU-established reseller supplying under its own name products made by others whose name does not appear; an EU-established person supplying for the first time in that member state products brought in from another member state or a third country; and a distance seller, established in another member state or a third country, selling directly to end-users in a member state. One exclusion matters for the second-hand trade: the definition does not cover persons supplying used textile, textile-related or footwear products assessed as fit for re-use, or products derived from those used or waste products or their parts, or self-employed tailors producing customised products (Article 3(4b)). Whether a given seller falls inside the definition is therefore a case-by-case question — a reseller of used garments is not a producer, and neither is a tailor making bespoke garments. Micro-enterprises, by contrast, are not excluded from the definition — they are covered, but only from 17 April 2029 (see above). In practice that means an overseas garment factory making goods for an EU brand or importer is generally not the producer — the EU importer or brand that first places the goods on that market is (the third case). A non-EU company is a producer mainly in the fourth case, distance selling direct to EU end-users. The authorised-representative mechanism follows the same split: a distance seller established in another member state must appoint an authorised representative in each member state of sale, while for a distance seller established in a third country each member state may — but is not required to — impose that duty (Article 22a(3)). A producer may also have a producer responsibility organisation meet the obligations on its behalf by written mandate (Article 22a(4)). “Exporter” is not the term the directive uses, and whether a non-EU seller needs a representative in a given market depends on that member state’s choice, not on a single EU-wide rule.

Meanwhile the underlying obligation is fixed: under Directive (EU) 2025/1892, which amends the Waste Framework Directive, member states must transpose the textile EPR rules by 17 June 2027 and establish textile EPR schemes by 17 April 2028; micro-enterprises are covered only from 17 April 2029. National schemes are already live in some member states, so a brand selling across several markets faces several different regimes. Our coverage of the Parliament vote explains the detail: EU Textile EPR: Parliament Vote and What Exporters Must Prepare

PFAS: two numbers, two systems

PFAS compliance now comes in two systems that must not be confused. The first is the REACH restriction on PFHxA, its salts and PFHxA-related substances (Annex XVII, entry 79), a direct statutory obligation. From 10 October 2026, textiles, leather, furs and hides in clothing and related accessories for the general public, and footwear for the general public, placed on the EU market must not contain 25 ppb or more of PFHxA and its salts, or 1,000 ppb or more of PFHxA-related substances, measured in homogeneous material (REACH Annex XVII, entry 79, added by Commission Regulation (EU) 2024/2462). The same thresholds extend to other textiles, leather, furs and hides for the general public from 10 October 2027. Products placed on the market before the applicable date are covered by transitional provisions. Category III personal protective equipment, medical devices and construction textiles are among the exclusions. France has gone further: since 1 January 2026, its Environmental Code (Article L.524-1, introduced by Loi n° 2025-188) has prohibited PFAS in consumer clothing textiles and footwear, waterproofing agents for them, cosmetics and ski wax, above residual thresholds set by Décret n° 2025-1376 (Article D.525-4) of 25 ppb for any single PFAS, 250 ppb for the sum of PFAS and 50 ppm for PFAS including polymers (French-law thresholds for finished consumer products), with exemptions for personal protective equipment — for the 2026 phase, PPE under Regulation (EU) 2016/425, PPE and firefighter equipment for the armed forces, internal security and civil security forces, and waterproofing agents for re-waterproofing them (Article D.525-2); for the 2030 phase, industrial technical textiles and, only where no substitution solution exists, PPE and related equipment and sanitary textiles for medical uses (Article D.525-3) — and for clothing and footwear containing at least 20% post-consumer recycled material (with PFAS only in the recycled share, in proportion to that share), and a twelve-month clearance period — until 31 December 2026 — for listed products manufactured before 1 January 2026. The French ban extends to all textiles from 1 January 2030. That extension is subject to the exemptions in Article D.525-3: industrial technical textiles, and — only where no substitution solution exists — PPE and related equipment, combat-system equipment and equipment for operations against nuclear, radiological, biological or chemical threats, and sanitary textiles for medical uses.

The second system is the ZDHC MRSL Version 4.0, launched on 29 October 2026 — a voluntary or contractual buyer requirement, not EU law. ZDHC MRSL V4.0 prohibits intentional PFAS use in covered chemical formulations and specifies formulation limits of 25 µg/kg for individual PFAS, 250 µg/kg for the sum of PFAS and 50 mg/kg for total fluorine (ZDHC MRSL V4.0, section 1N — all three limits are ZDHC limits for unintentional contamination in chemical formulations, not EU-law limits for finished articles). These limits apply to unintentional contamination in chemical formulations used in manufacturing. They are contamination allowances, not a permitted-use threshold: intentional PFAS use is prohibited outright, so a formulation cannot “comply” by keeping intentional PFAS below 25 µg/kg. The number 25 appears in both systems, but they are different rules: REACH restricts a specific substance family in finished articles on the market; ZDHC limits contamination in manufacturing inputs. A formulation can satisfy one and fail the other. Total fluorine is a screening indicator, not a substance limit: under ZDHC MRSL V4.0 section 1N, formulations identified as high risk are tested for total fluorine and targeted PFAS analysis together, while formulations identified as low risk are tested for total fluorine first, and only where total fluorine exceeds 50 ppm (50 mg/kg) should a target PFAS analysis be conducted, together with document review and investigation with the formulator. For a high-risk formulation, where total fluorine exceeds 50 ppm but targeted PFAS are below the MRSL limits, the certifier initiates a further investigation to confirm the source of fluorine and conformance to the OECD definition of PFAS before certifying the formulation as conformant. Above the 50 mg/kg threshold, disclosure of the declaration and source of fluorine to the solution provider is mandatory (MRSL V4.0 Change Log, section 1N, item 5). A total-fluorine result on its own cannot prove compliance with the REACH PFHxA thresholds. Three different roles must therefore be kept apart: the screening indicator (total fluorine, 50 mg/kg), the declaration and disclosure trigger (above that threshold, the fluorine source must be declared and disclosed to the solution provider), and the substance limits (25 µg/kg for an individual PFAS and 250 µg/kg for the sum of PFAS) — all three are ZDHC formulation rules, distinct from the finished-article limits under REACH and French law. Three sets of numbers circulate under similar figures — REACH (25/1,000 ppb, finished articles), France (25/250 ppb and 50 ppm, finished consumer products) and ZDHC (25/250 µg/kg and 50 mg/kg, chemical formulations) — and they must not be read as one rule. Buyers should ask suppliers which system a test result belongs to before accepting it as evidence — one PFAS test result does not prove compliance with both systems, and MRSL conformance does not by itself make a finished article lawful.

The transition to ZDHC MRSL V4.0 began on 1 November 2026 and is to be fully executed by 1 June 2028, when the supply-chain implementation period ends. Speakers at the ZDHC Global Circularity Summit in Lisbon described missing chemical data as a major barrier to scaling textile-to-textile recycling — a finding that connects PFAS control directly to the recyclability of the product. California’s textile EPR law, SB 707, adds a third jurisdiction to the same picture: California Textile EPR (SB 707): A Practical Guide for Apparel Brands and Suppliers

EUDR and green claims in one paragraph

Two further rules complete the map. The EU Deforestation Regulation is in force but its main obligations do not yet apply: they begin on 30 December 2026 for large and medium-sized operators and traders, and on 30 June 2027 for natural persons or micro- or small undertakings established as such by 31 December 2024, except for products covered by the Annex to Regulation (EU) No 995/2010 (EU Timber Regulation), which follow the earlier date (Article 38(2)–(3)). EUDR applicability depends on the commodity and product codes listed in Annex I, not simply on whether a material originates from forests. The seven relevant commodities are cattle, cocoa, coffee, oil palm, rubber, soya and wood. Viscose, modal and lyocell fibre, yarn and fabric are not listed in Annex I and are not themselves covered. What is covered, under the wood entry, is pulp and paper: as amended by Delegated Regulation (EU) 2026/2102, Annex I lists “ex 47 Pulp of wood” and “ex 48 Paper and Paperboard: articles of paper pulp, of paper or of paperboard”, excluding used and second-hand products, recovered (waste and scrap) products and products derived from them, waste, packing used only to support, protect or carry another product, and correspondence and marketing material. Dissolving wood pulp (chemical wood pulp, dissolving grades, HS 4702) — the feedstock for viscose, modal and lyocell — is one item within the ex 47 entry, not the whole of it. Cattle hides, skins and leather (ex 4101, ex 4104, ex 4107) were removed from Annex I by Delegated Regulation (EU) 2026/2102, in force since 18 September 2026; hides, skins and leather of other animals were never listed in Annex I. Live cattle, beef and edible offal remain listed, and re-inclusion of cattle hides, skins and leather is to be considered in the Regulation’s 2030 general review. Certain rubber products remain listed — including articles of apparel and clothing accessories of vulcanised rubber (ex 4015); conveyor belts (ex 4010) and other articles of vulcanised rubber (ex 4016) were removed by the same act. Apparel businesses should assess relevant wood products and rubber goods against the Regulation’s specific product scope and check the customs classification of each product rather than assume coverage from the fibre name. Our guide to the regulation’s apparel scope is here: EUDR and Apparel: Scope, Leather and Rubber, and What Suppliers Must Document. And Directive (EU) 2024/825, the Empowering Consumers Directive, has applied since 27 September 2026 — it amends EU consumer-protection rules on environmental claims and sustainability labels, rather than creating a general environmental certification scheme — changing what a brand may say about a garment in marketing, a more immediate operational constraint for many brands than the ESPR timetable. Note that the separate Green Claims Directive proposal was never adopted and is not law. Our guide to the Empowering Consumers Directive sets out its current status: EU Green Claims Directive and Apparel: Current Status in 2026

The three pain points, with fixes

The organisations interviewed by Apparel Resources identified the same three problems, and each now has a clearer remedy than it did in September.

Fragmentation. Different brands set different requirements, and a factory serving ten customers can face ten questionnaires. The remedy is convergence on common standards: manage chemical inputs to one recognised system (such as bluesign or ZDHC MRSL conformance) and keep the data in one place, so that the same evidence answers most buyers. As Barbara Oswald Bader, chief commercial officer at bluesign, put it: “Traceability will become more digital and more connected. Information that today lives in separate documents will increasingly travel with the product.” (Apparel Resources, 11 September 2026)

Limited visibility into chemical inputs. The remedy is input control rather than finished-product testing: assess chemical formulations against risk-based criteria before production, with primary data reviewed by experts and confirmed on site. bluesign works at that upstream stage for precisely this reason.

The need for evidence at every stage. The remedy is chain-of-custody documentation. Laboratory testing can help assess fibre composition and material characteristics, but it cannot independently establish the complete provenance and recycled-content chain of custody. Reliable recycled-content claims therefore require documentary traceability and appropriate verification. Charan Singh, director and regional general manager for emerging markets at UL Solutions, made the point for recycled content: the only way to validate recycled material is through chain-of-custody validation. UL Solutions offers that validation as part of its Environmental Claims Validation programme, and has adapted its ECVP 2884 procedure to validate that a product has no detectable PFAS. UL’s own description of that validation is precise: an environmental claim validation to UL 2884 “validates that products do not contain detectable levels of defined PFAS chemicals”. Three claims must not be confused: “not detected by the specified method” is what the validation certifies; “the product contains no PFAS” is a stronger, absolute claim that the validation does not make; and “compliant with a PFAS regulation” is a separate legal test that the validation does not certify. (Apparel Resources, 11 September 2026) The same logic applies across compliance: the evidence is the record of the chain, not a single test certificate.

Anuj Sharma, deputy country director at FSC India, described the same shift for forest-based materials: new technologies are moving traceability from paper-based declarations to verified digital data, with FSC Trace enabling certified material to be tracked from forest to shelf. (Apparel Resources, 11 September 2026)

What to do first

For a factory or exporter that has not yet systematised compliance, work in order of urgency — by deadline, not by topic:

1. Now — PFHxA limits and green claims. The REACH PFHxA limits for clothing and footwear have applied since 10 October 2026, France’s PFAS ban since 1 January 2026, and the Empowering Consumers Directive’s national measures since 27 September 2026. Check finished-article test evidence against the REACH thresholds (not the ZDHC formulation limits), and audit consumer-facing environmental claims and labels for substantiation before they are published.
2. Before 30 December 2026 — EUDR assessment. Map every product against Annex I by customs code, confirm whether dissolving pulp, other pulp or paper products, or listed rubber goods are involved, and confirm who in the chain holds the due-diligence duty. Viscose garments themselves are not listed, but the pulp behind them may be.
3. 2027–2028 — textile EPR and customer due-diligence requests. Confirm who is the producer for each market, track national EPR schemes as member states transpose Directive (EU) 2025/1892, and build the evidence file customers will ask for under CSRD and CSDDD — remembering that the CSRD value-chain cap does not cover due-diligence requests, which are governed instead by the CSDDD’s own necessity limit in Article 8(2a).
4. Longer term — ESPR textiles delegated act and the digital product passport. Keep gathering the passport data (fibre composition, chemical information, repair and recycling data) without treating the indicative 2027 adoption year as a deadline; the delegated act has not been adopted, and obligations would normally follow no earlier than 18 months after it enters into force (ESPR Article 4(4), subject to duly justified exceptions).

Compliance is no longer a department that answers questionnaires after the order is placed. It is becoming part of how a product is specified, costed and sold — and the exporters who treat it that way will find it a selling point rather than a burden.

Key claim–source check

The table below maps each key claim in this article to the source it was checked against. Only claims verified against the sources listed under Sources appear here.

Sources

Sources read on 9 November 2026. Primary EU texts first; industry sources only for the interview record, the ZDHC documents and the summit report.

• Directive (EU) 2026/470 (Omnibus I), OJ L, 26 February 2026, in force 18 March 2026 — CSRD/CSDDD scope, value-chain cap, CSDDD Article 8(2a) information-request limit, deletion of Article 22 (climate transition plan), Article 27(4) 3% penalty ceiling, Article 29 civil liability amendments, transposition dates. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0470
• Commission Recommendation 2003/361/EC of 6 May 2003 concerning the definition of micro, small and medium-sized enterprises, Annex, Article 2(2) — a small enterprise employs fewer than 50 persons and has an annual turnover and/or annual balance sheet total not exceeding EUR 10 million. https://eur-lex.europa.eu/eli/reco/2003/361/oj/eng
• Commission, Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030, COM(2025) 187 final, 16 April 2025 — textiles as priority product group, indicative adoption year 2027. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52025DC0187
• Commission Delegated Regulation (EU) 2026/296 of 9 February 2026, OJ L, 22 April 2026 — derogations from the ESPR destruction ban (Article 25(5)). https://eur-lex.europa.eu/eli/reg_del/2026/296/oj/eng
• Regulation (EU) 2023/1115 (EUDR), consolidated text of 26 December 2025, as amended by Regulation (EU) 2025/2650 — application dates (Article 38(2)–(3)), Annex I scope. Note: this consolidated version predates Delegated Regulation (EU) 2026/2102; the leather and rubber changes rest on the delegated regulation below, and the pulp and paper entry now reads as amended by that regulation, item (ww) — “ex 47 Pulp of wood” and “ex 48 Paper and Paperboard: articles of paper pulp, of paper or of paperboard”, with the exclusions set out in the article text. https://eur-lex.europa.eu/eli/reg/2023/1115/2025-12-26/eng
• Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026, OJ L, 17 September 2026, in force 18 September 2026 — removal of cattle hides, skins and leather (ex 4101, ex 4104, ex 4107) from EUDR Annex I; removal of ex 4010 and ex 4016; ex 4015 rubber apparel retained. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202602102
• Regulation (EU) 2024/1781 (ESPR), OJ L, 28 June 2024 — Article 25 destruction ban, Annex VII, Article 4(4) transition rule. https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
• Directive (EU) 2025/1892 amending the Waste Framework Directive, OJ L, 26 September 2025 — textile EPR, transposition by 17 June 2027, schemes by 17 April 2028, micro-enterprises from 17 April 2029. https://eur-lex.europa.eu/eli/dir/2025/1892/oj/eng
• Commission Regulation (EU) 2024/2462 adding REACH Annex XVII entry 79 (PFHxA), OJ L, 19 September 2024 — 25 ppb / 1,000 ppb limits, dates, exemptions, transitional provisions. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202402462
• Directive (EU) 2024/825 (Empowering Consumers for the Green Transition), OJ L, 6 March 2024 — national measures apply from 27 September 2026. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ%3AL_202400825
• ZDHC Foundation, “ZDHC Launches MRSL V4.0”, 29 October 2026 (launch announcement: “16 new substances”; lower limits “including … chlorinated paraffins”). https://www.roadmaptozero.com/post/zdhc-launches-mrsl-v4-0
• ZDHC MRSL Version 4.0, October 2026 — PFAS intentional-use ban, formulation limits (section 1N), total-fluorine screening. https://downloads.roadmaptozero.com/ZDHC_MRSL_V4.0
• ZDHC, “ZDHC’s position on PFAS”, Version 1, October 2026 (section 2.2, risk-based conformance: high-risk formulations tested for total fluorine and targeted PFAS together; low-risk formulations tested for total fluorine, with a target PFAS analysis where total fluorine exceeds 50 ppm). https://downloads.roadmaptozero.com/ZDHC_PFAS_Position_Paper
• ZDHC MRSL V4.0 Industry Implementation Approach, October 2026 — transition from 1 November 2026, fully executed by 1 June 2028. https://downloads.roadmaptozero.com/ZDHC_MRSL_V4.0_Implementation_Approach
• Apparel Resources, “The Compliance Bar is Rising for Apparel Exporters”, 11 September 2026 (interviews with FSC India, bluesign and UL Solutions; quotations verified against the published text). https://apparelresources.com/business-news/sustainability/compliance-bar-rising-apparel-exporters/
• Ecotextile News, “ZDHC summit: data holds back circularity”, 5 November 2026. https://www.ecotextile.com/2026110567085/news/dyes-chemicals/zdhc-summit-data-holds-back-circularity/
• SGS, “France Publishes Updated PFAS Regulation for Consumer Products”, January 2026 (Loi n° 2025-188; Décret n° 2025-1376). https://www.sgs.com/en-us/news/2026/01/safeguards-00626-france-publishes-updated-pfas-regulation-for-consumer-products
• Intertek, “France – Update on Prohibition of Clothing Textile Products, and Footwear Containing PFAS”, 6 January 2026. https://www.intertek.com/products-retail/insight-bulletins/2026/1512-france-pfas-ban-clothing-footwear/
• European Parliament Legislative Train, “Omnibus VIII – environment – authorised representative for EPR (ii)”, information updated 25 October 2026 (2025/0396(COD); plenary vote 612–8–39 on 20 October 2026). https://www.europarl.europa.eu/legislative-train/theme-a-new-plan-for-europe-s-sustainable-properity-and-competitiveness/file-omnibus-viii-environment-authorised-representative-for-epr-(ii)
• European Parliament, adopted text P10_TA(2026)0344, 20 October 2026 (Omnibus VIII: scope — textiles, footwear, electrical and electronic equipment and specified single-use plastic products; anti-splitting clause; file referred back to committee for interinstitutional negotiation; companion batteries and packaging regulation adopted 616–9–39; Council negotiating mandate of 21 October 2026 covers packaging only — under one tonne per year, until 1 January 2032, Commission review by 31 December 2030). Official PDF, verified 9 November 2026 (HTTP 200, application/pdf, 14 pages; header “TEXTS ADOPTED — P10_TA(2026)0344”, amendments adopted 20 October 2026, ordinary legislative procedure: first reading, referred back for interinstitutional negotiations): https://data.europarl.europa.eu/distribution/doc/TA-10-2026-0344_en.pdf. The doceo HTML page for the same document returned an empty response (HTTP 202) in the rev5 and rev6 checks; the PDF above is the verified direct link. The European Parliament Legislative Observatory procedure file for 2025/0396(COD) is a supplementary procedural record: https://oeil.europarl.europa.eu/oeil/sl/procedure-file?reference=2025/0396(COD)
• Commission Delegated Regulation (EU) 2026/1560 of 3 July 2026, OJ L, 21 September 2026, in force 24 September 2026 (voluntary sustainability reporting standard for undertakings; Annex II datapoints for protected undertakings under CSRD Article 19a(3)). Cited by OJ reference; no URL invented.
• UL Solutions, “PFAS Identification, Testing and Management Services” (environmental claim validation to UL 2884 “validates that products do not contain detectable levels of defined PFAS chemicals”). https://www.ul.com/services/pfas-identification-testing-and-management-services
• Weil, “The EU Omnibus I Directive – Now in Force”, March 2026 (CSRD third-country test: €450 million EU turnover in each of the last two financial years and an EU subsidiary or branch above €200 million; first reports for financial year 2028). https://weil.com/-/media/files/pdfs/2026/march/the-omnibus-i-directive-now-in-force.pdf
• Bird & Bird, “Omnibus I Directive entered into force – A first overview of the amended CSRD and CSDDD”, March 2026 (value-chain cap: protected undertakings up to 1,000 employees; cap does not affect due-diligence requests). https://www.twobirds.com/en/insights/2026/germany/omnibus-i-directive-entered-into-force-%E2%80%93-a-first-overview-of-the-amended-csrd-and-csddd
• TrustTrace, “Common Questions Fashion and Textile Brands Ask About EUDR – Part 2”, updated 16 January 2026 (viscose, modal and lyocell fibre/yarn/fabric not in Annex I; dissolving wood pulp in scope). https://trustrace.com/knowledge-hub/common-questions-fashion-textile-brands-are-asking-about-eudr-part-2
• TÜV Rheinland, “Regulation (EU) 2024/2462 – Restriction on PFHxA … under REACH Annex XVII, Entry 79” (scope, thresholds, exemptions). https://www.tuv.com/regulations-and-standards/en/europe-regulation-eu-2024-2462-restriction-on-pfhxa-its-salts-and-related-substances-under-reach-annex-xvii-entry-79.html
• Code de l’environnement, Article L.524-1 (introduced by Loi n° 2025-188 of 27 February 2025) — French PFAS ban: product list and dates (consumer clothing textiles, footwear, waterproofing agents, cosmetics, ski wax from 1 January 2026; all textiles from 1 January 2030). Promulgated text on Légifrance: https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000051266190/2025-04-15
• Décret n° 2025-1376 of 28 December 2025, Articles D.525-2 to D.525-4, Légifrance — PFAS residual thresholds (25 ppb / 250 ppb / 50 ppm), exemptions, twelve-month clearance for products manufactured before 1 January 2026. https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053201526