Ecodesign for textiles without harmful chemicals

ClientEarth argues that the JRC's preparatory study for textile ecodesign criteria under the ESPR is insufficient. The organization advocates for full alignment with REACH for reporting Substances of Very High Concern (SVHCs), the inclusion of all substances with harmonised classification and labelling (CLH), and the removal of exemptions for process chemicals. It further contends that the JRC has failed to implement legal requirements to reduce 'significant risks' to health and the environment and has overlooked the need for performance restrictions based on circularity concerns, such as the use of phthalates.

• Information requirements for Substances of Concern (SoC) type (a) should include all Substances of Very High Concern (SVHCs) to ensure full alignment with the REACH Regulation and avoid complexities for duty holders.
• Reporting requirements for SoC type (b) should apply to all entries of Annex VI CLP for the specified hazard classes, rather than a limited list of substances identified by the regulator, to prevent the use of unregulated substitutes.
• Information requirements for SoC types (c) and (d) must be dynamic, triggering reports for all regulatory limitations that enter into force throughout a product's life cycle to support end-of-life actors like recyclers.
• The JRC's proposed exemption for chemicals not intentionally added to the final product (process chemicals) is flawed because most production occurs outside the EU, where the Industrial Emissions Directive (IED) does not apply.
• The proposed 8-year transition period for information requirements on substances classified under hazard classes recognized under CLP but not GHS is disproportionate, as these provisions will already be implemented by the time the ESPR delegated act is enforceable.
• The JRC working document fails to provide concrete implementation advice for the legal requirement under Article 6(3) ESPR to reduce 'significant risks' to human health or the environment.
• Performance requirements should be introduced to restrict chemicals based on circularity concerns, specifically citing phthalates as substances that contaminate recyclate and impede the recycling process.

APA

ClientEarth (2026). Ecodesign for textiles without harmful chemicals. https://www.clientearth.org/media/4lulbwwl/ecodesign-for-textiles-without-harmful-chemicals-ce-on-jrc-3rd-milestone.pdf

Chicago

ClientEarth. Ecodesign for textiles without harmful chemicals. 2026. https://www.clientearth.org/media/4lulbwwl/ecodesign-for-textiles-without-harmful-chemicals-ce-on-jrc-3rd-milestone.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Ecodesign for textiles without harmful chemicals |date=April 2026 |url=https://www.clientearth.org/media/4lulbwwl/ecodesign-for-textiles-without-harmful-chemicals-ce-on-jrc-3rd-milestone.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2026ecodesign, author = {{ClientEarth}}, title = {{Ecodesign for textiles without harmful chemicals}}, publisher = {ClientEarth}, year = {2026}, month = apr, url = {https://www.clientearth.org/media/4lulbwwl/ecodesign-for-textiles-without-harmful-chemicals-ce-on-jrc-3rd-milestone.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }