EU Compliance Updates: Autumn 2025
What’s changing for textile and fashion brands – from EUDR delays to upcoming EPR requirements
Hi everyone,
It’s been a big summer and start of autumn for compliance in Europe. From the withdrawal of the EU Green Claims Directive to escalating fines for Shein, the regulatory landscape is shifting fast, and we’re here to help you stay ahead.
Here’s what you need to know:
News Updates
EU Green Claims Directive Withdrawn
Originally proposed to fight greenwashing by requiring brands to scientifically substantiate and third-party verify environmental claims, the Green Claims Directive was withdrawn in June 2025.
Why? The EU Parliament found it too complex and costly, especially for SMEs. But the withdrawal doesn’t mean brands can relax; claims still fall under the Unfair Commercial Practices Directive (UCPD) and the Empowering Consumers Directive (see below).
Shein’s Summer of Fines
Shein faced multiple sanctions this summer:
France: €1.1M fine under AGEC law for omitting mandatory microplastic disclosure
Italy: €1M fine for misleading environmental claims
France (Competition & Anti-Fraud Office): €40M fine for deceptive price reductions
France’s Anti-Fast Fashion Bill
In June, the French Senate passed a bill targeting ultra-fast fashion, expected to be validated in the coming months. Key requirements for brands include:
A definition of ultra-fast fashion and escalating penalties (up to 50% of product price by 2030)
A ban on advertising ultra-fast fashion or a mandatory promotion of second-hand alternatives
Disclose the environmental impact of products
Disclose country of origin next to the price, in the same font size as the price – applies to all brands, not just ultra-fast fashion
EU Per- and polyfluoroalkyl substances (PFAS) Restriction Expands
The European Chemicals Agency (ECHA) has now completed its evaluation of scientific and technical comments (over 5,600 comments) from third parties during the consultations. As a result, the scope of the proposed PFAS restriction has been expanded to cover additional sectors, including technical textiles.
There is currently no confirmed compliance date, as the proposal is still under development - implementation could potentially be expected around 2028, though this remains uncertain.
Circular Economy Act in Motion
The EU Commission has launched its first public consultation for the Circular Economy Act. The goal is to accelerate the transition to a circular economy by creating a stronger single market for secondary raw materials, simplifying and harmonising Extended Producer Responsibility (EPR) schemes, and expanding EPR to new product groups, among other things.
The proposal is expected in Q4 2026, with adoption anticipated between 2027–2028.
EU Deforestation Regulation (EUDR) Delay
On 23 September 2025, Environment Commissioner Jessika Roswall signalled her intention in a letter to postpone the EUDR by one year. The reason given is technical issues with the TRACES IT platform used to manage compliance data, though political and trade pressures have also played a role.
For now, nothing has changed: the delay is only a letter, not an official EU proposal. A delay would only take effect if the Commission puts forward a formal proposal and it is approved by both the European Parliament and Council.
Waste Framework Directive (WFD) Revision and Textile Extended Producer Responsibility (EPR)
On 9 September 2025, the European Parliament approved the revised Waste Framework Directive, now published in the Official Journal of the EU.
Entry into force: mid-October 2025
Member States have 20 months to include provisions into their own national law, including rules for Extended Producer Responsibility (EPR) for textiles, ensuring businesses fund and manage end-of-life garment collection and treatment
A key element of the revision is the introduction of mandatory Extended Producer Responsibility (EPR) for textiles, requiring producers to finance and manage the collection, sorting, reuse, and recycling of discarded garments and footwear. What this means for brands:
EPR will apply to apparel, home textiles, and footwear (but not bags or leather)
Producers must register in every market they sell to
Reporting requirements still to be defined (not harmonised EU-wide)
Implementation of textile EPR schemes is expected by Q1 2028
Denmark Takes Over EU Presidency
Denmark now holds the rotating presidency of the Council of the EU, signalling a more ambitious environmental agenda in upcoming negotiations.
Key Laws to Have on Your Radar
Unfair Commercial Practices Directive (UCPD)
Already in force - the goal of this law is to protect consumers. It applies to all B2C commercial practices (before, during, and after purchase), and brands must ensure:
All claims are clear, specific, and truthful
Evidence is ready to substantiate claims
No vague terms like “eco,” “green,” “sustainable” without proof
No fake or weak labels
Empowering Consumers Directive
This is essentially an update to the UCPD, coming into force September 27, 2026. It adds:
More prohibitions, including misleading sustainability claims
Obligations to inform consumers on product repairability and durability
Each member state will set penalties and define what counts as sufficient evidence
Other Notables:
Footwear Labelling Directive: specifies what info must be included on labels for footwear components
French Eco-Score: From 1 October 2026, anyone can calculate any brand’s eco-score using publicly available methods. While France cannot make the system mandatory under EU law, brands may choose to calculate their own score, which is the only way to challenge scores calculated by others
Takeaway
The compliance landscape for fashion and textiles is becoming more fragmented and more demanding, particularly in France and at the EU level. The focus is clear: transparency, traceability, and truthful communication.
If there was anything in this briefing you didn’t fully understand, or if you’d like support navigating these changes, interpreting the laws for your market, or reviewing your product claims, our team can help.
Contact our Compliance Expert Emma: emma (at) bergstrand.co
General Enquiries: info (at) bergstrand.co