While the JRC’s third milestone report offers the most detailed modelling to date on how the ESPR could reshape textile products, it also underlines how some of the scenarios reveal critical gaps between theoretical potential and operational feasibility. A major area of concern arises from the scarcity of data highlighted within the study. The ESPR’s ambition relies on granular data about durability, fibre composition, chemical substances, production processes, recycled content, and end‑of‑life pathways. However, available information is often fragmented, inconsistent, or simply lacking. This creates tension, as the scenarios modelled are based on assumptions of data availability that do not reflect the way information is managed across the supply chain.

The third milestone report analysis focuses on three representative product categories: knitted products, denim products, and other nondenim woven products. For each category the JRC has measured the environmental impact in a base case which represent the average technology and processes for the product category on the market. 

In the” Assessment of the design options” section, the report proposes 4 eco design requirements: 

• Increased Robustness (D01)
• Recyclability (D02)
• Recycled Content (D03)
• Environmental Footprint Reduction (D04)

An interesting and debated point is the JRC's decision to evaluate robustness and recyclability using a 1-to-10 scoring system, which can also be utilized for product claims. The system is intended to function similarly to the EU Energy Label for appliances. While the implementation of this concept would be a major step forward in the transparency of product sustainability performance, the differing contexts make implementation significantly more challenging for textiles than it has been for appliances. This is particularly true for robustness, which is not the sole factor determining a garment's actual service life.

Have your say in the peer‑to‑peer discussion on these issues active in the Sustainable Business workspace and Certification and Communication workspaces.