Position Papers
Internal Market
EU Single Market, free movement of goods and product-related sustainability
International Market Access
International trade, customs facilitation and global supply chains
Due Diligence
Human rights, social, and environmental impact in the textile sector
Sustainability
Circular economy, environmental requirements for textile products, consumer protection
EBCA Position on the JRC Preparatory Study for Textiles
The European Branded Clothing Association (EBCA) welcomes the JRC’s 3rd milestone of the Preparatory Study on Textile Products (PS). EBCA is committed to ensuring the ESPR Delegated Act for textiles supports a fair transition and sets clear, workable rules that protect competitiveness.
EBCA values the JRC’s engagement with industry stakeholders and welcomes the updates to the developing ecodesign approach on textiles. We invite the JRC and European Commission to consider our feedback and recommendations for a balanced and implementable textiles Delegated Act which both achieves tangible environmental outcomes and preserves the economic value of the European and global clothing industry.
Towards pragmatic and harmonised labelling in the EU: A joint call from manufacturers to prevent Single Market fragmentation and preserve competitiveness
EBCA, together with the undersigned organisations, urge the European Commission and Member States to adopt a pragmatic approach for the future harmonised packaging labels, in line with the EU’s agenda for the EU Single Market, simplification and competitiveness. The system should rely on text-free pictograms, available in achromatic or monochromatic versions matching the packaging palette, with the possibility of using digital labelling as a core element.
Joint call for a timely and targeted revision of the Textile Labelling Regulation (TLR)
EBCA, together with the undersigned organisations, call on the European Commission to proceed with the targeted and timely revision of the Textile Labelling Regulation (TLR). It is essential to update key elements of the current framework and ensure the TLR can support and complement the emerging requirements of different EU textiles policies.
The current TLR has played an important role in ensuring that consumers receive harmonised information on the fibre composition of textile products across the EU. This function remains essential and should be preserved. However, the TLR was developed in a context where product information was static and primarily provided through physical labels. Since its adoption in 2011, the EU legislative framework for textiles has advanced considerably, making several core elements of the TLR outdated as they no longer reflect market realities, technological progress, or the evolving EU policy framework for textiles.
A targeted revision is therefore timely and necessary. It provides an opportunity to modernise the framework while preserving its core purpose: ensuring consumers receive essential information in a reliable and harmonised manner and ensuring that upcoming key pieces of legislation are properly implemented. In this context, it is also important to ensure a clear distinction between different information and labelling tools, avoid duplication with other instruments and ensure that new requirements do not add unnecessary complexity.
It is essential that the TLR remains a technical and focused piece of legislation. In this context, the revision should focus on a limited number of “must-have” elements, which are necessary to ensure that the Regulation can function effectively in today’s broader policy environment.
The branded clothing sector urges caution on additional feedstock requirements
The European Branded Clothing Association (EBCA) recognises the important role that biotechnology and bio-based solutions can play in supporting industrial decarbonisation. However, EBCA is alarmed that the European Commission is considering including the textile
apparel sector as a potential “lead market” to create demand for bio-based feedstock or captured emissions (CCU) for end products in the Biotech Act II.
EBCA call to maintain authorised representatives in textiles Extended Producer Responsibility schemes
The European Branded Clothing Association (EBCA) supports the overarching objective of the Environmental Omnibus proposal to simplify and streamline EU legislation. EBCA recognises the value of reducing unnecessary administrative burdens and acknowledges the benefits for business competitiveness and economic growth. However, simplification must not come at the expense of effective regulatory enforcement, particularly within a cross-border internal market.
Therefore, EBCA considers that:
• The role of authorised representatives (ARs) remains essential for ensuring compliance in cross-border trade if they have the authority, capacity, and resources to meet national reporting requirements. Any consideration of reducing AR obligations should occur only once robust, EU-wide enforcement mechanisms have been fully implemented.
• Ensuring a level playing field among all economic operators making products available on the market of a Member State must remain a core priority. All producers, regardless of their size, geographic origin, or business model should continue to be required to appoint an authorised representative established within the EU.
A consistent and risk-based market surveillance strategy
The revision of the Market Surveillance Regulation should support a level playing field by ensuring that all market operators placing products on the EU market face the same level of liability and accountability, regardless of their size, geographic origin, or business model. This requires action in two key areas:
- Ensuring that the designated responsible entity genuinely has the authority, capacity, and resources to be held liable, thereby avoiding the use of empty-shell intermediaries that cannot adequately ensure compliance.
- Focusing on more effective and better-coordinated market surveillance and, focusing on the most problematic and risk-prone actors rather than imposing additional documentation requirements, which would only burden compliant operators without improving enforcement outcomes.
Position paper on the Circular Economy Act
EBCA welcomes the European Commission’s initiative for a Circular Economy Act (CEA) to further stimulate circularity and address competitiveness gaps. The upcoming CEA is an unique opportunity to reinforce sector-specific textile policies with strong, horizontal measures and to support the sector’s transition to a fair and competitive circular economy.
To close the regulatory gaps and update outdated legal definitions and frameworks to solve market’s constraints hampering the development of secondary materials, the CEA should aim to:
- Ensure harmonisation and consistency across EU legislation to support the Single Market
- Enable access to economic instruments to scale up circular business models
- Update outdated definition with circularity in mind
- Adopt a global value chain approach to achieve textile circularity in the EU and in the whole textile supply chain
This document outlines targeted recommendations for integrating existing EU legislative frameworks and initiatives into the upcoming CEA.
Why risk-based approach matters for due diligence
EBCA recommends that due diligence requirements be grounded in a risk -based approach aligned with international standards. Such approach enables companies to prioritise the more severe and likely risks across the value chain rather than undertaking due diligence of tier-1 suppliers. In addition, it recognises the dynamic nature of a due diligence processes, allowing for efficiency, flexibility and adaptability.
EBCA’s proposal to simplify administrative burdens in environmental legislation
EBCA supports the Environmental Omnibus proposal’s overarching goal of simplifying and streamlining EU legislation recognizing efforts to enhance business competitiveness and foster economic growth
Legal analysis supports the legitimacy of employing a portfolio approach to meet recycled content targets within the ESPR.
While the EU Commission is contemplating the setting of eco-design requirements on a product or product group level under the ESPR, this document outlines how specifically eco-design requirements for recycled content on the so-called portfolio brand approach is compatible with the ESPR.
EBCA calls for proportional and impact-driven ESPR requirements
EBCA highly welcomes the Ecodesign for Sustainable Products Regulation (ESPR) and Delegated Act (DA) for Apparel Textiles as a critical regulatory framework aimed at improving the environmental performance of apparel and empowering consumers to make more informed purchasing decisions. To ensure its effectiveness, it is critical that the ESPR creates a level playing field for the whole industry, ensures policy coherence with other EU legislation and avoids fragmentation on the Single Market.
Joint position for a pragmatic approach to Substances of Concerns in ESPR
EBCA joins forces to call for engaging in a continuous dialogue involving the different actors of the global textile value chain in the preparation of the DA for textiles including substances of concerns in finished textile products.
Simplified Reporting Requirements : Strengthening EU Competitiviness
EBCA suggests some amendments to the European Commission’s proposal on simplified sustainability reporting requirement (Omnibus). The EU institutions call to rationalise reporting requirements should not reduce the EU’s sustainability ambition. Read our position below.
EBCA feedback to reporting overlaps
The European Branded Clothing Association welcomes the EU institutions’ call to rationalise reporting requirements without reducing the EU’s policy ambition. In our views, reporting requirements can support business’ corporate sustainability strategies by assessing their material impact and contributing to non-financial decisions. Furthermore, while global standards are EBCA’s preferred options, we see the benefits of EU alignment and leadership in this area. EU reporting requirement shall prevent the multiplication of national requests for information that have little impact on improving business operations.
ONE PAGER TRADE
The European Branded Clothing Association (EBCA) guiding principles and policy recommendations supporting free rules-based international trade.
ONE PAGER SUSTAINABILITY
The European Branded Clothing Association (EBCA) guiding principles and policy recommendations supporting ambitious sustainability policy.
RATIONALISED REPORTING REQUIREMENTS
The European Branded Clothing Association (EBCA) welcomes the EU institutions’ call to rationalise reporting requirements without reducing the EU’s policy ambition.
UNION CUSTOMS CODES
The European Branded Clothing Association (EBCA) welcomes the UCC reform proposal and view it as an important contribution to ensuring a harmonised approach towards protecting the Single Market from unfair competition and promoting trade.
EBCA POSITION ON UNSOLD GOODS
The European Branded Clothing Association (EBCA) contribution on the derogation to the prohibition of destruction of unsold goods under the ESPR.
EBCA POSITION ON TEXTILE LABELLING REGULATION
The European Branded Clothing Alliance (EBCA) supports the European Commission’s initiative to evaluate and revise the EU Textile Labelling Regulation (TLR). The revision presents an important opportunity to enhance legal certainty, ensure policy coherence and leverage opportunities to harmonise, digitise and support innovation. EBCA would like to take the opportunity to further explain and elaborate on our position with five key recommendations.
EBCA position on the Union Customs Code Revision
EBCA welcomes the UCC reform proposal and view it as an important contribution to ensuring a harmonised approach towards protecting the Single Market from unfair competition and promoting trade. We welcome the goal of the proposal to streamline customs procedures by increasing digitisationm to eliminate unnecessary administrative burdens and to contribute to the smooth functioning of the Single Market.
EBCA position on the targeted revision of the Waste Framework Directive (WFD)
The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a targeted revision of the Waste Framework Directive (WFD).
EBCA position paper on the Textile Labelling Regulation revision (TLR)
The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a legislative initiative on the Textile Labelling Regulation (TLR) and is in favour of this revision, as it represents a significant step towards harmonisation.
Joint statement on the destruction of unsold goods
The signatories of this statement would like to highlight several concerns regarding the Council’s general approach (adopted on the 22nd of May) and the European Parliament’s Position (adopted on the 12th of July) on Article 20 of the proposed ESPR Framework.
EBCA position on the Green Claims Directive
The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a legislative initiative on the substantiation and communication of explicit environmental claims (also known as the Green Claims Directive).
EBCA Position Paper on the EU – India FTA
The European Branded Clothing Alliance (EBCA) welcomes the reopening of free trade negotiations between the European Union and India. EBCA believes that trade and investment relations between the EU and India can – and should – improve significantly.
Advocacy Statement on the Revision of the EU Generalized Scheme of Preferences
The EU GSP scheme and the presence of international brands have been key to ensuring Bangladesh’s international competitiveness in the textiles sector.
EBCA Position Paper on the Forced Labour Regulation
The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a Regulation aimed at prohibiting products made with forced labour on the EU market. We support the ambition of the Commission to effectively address human rights concerns along supply chains.
EBCA Position Paper on the Corporate Sustainability Due Diligence Directive (CSDDD)
The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a Corporate Sustainability Due Diligence Directive (CSDDD). EBCA supports the adoption of mandatory horizontal and risk-based due diligence criteria at the EU level. This shall provide a level-playing field between EU and non-EU companies and legal certainty, as well as provide clearer information for consumers.
EBCA Position Paper on the Revision of the Union Customs Code (UCC)
The European Branded Clothing Alliance (EBCA) welcomes the opportunity to contribute to the European Commission’s Call for Evidence and public consultation on the Revision of the Union Customs Code. EBCA represents the most important retail clothing brands with a global commercial presence which process transactions and shipment volumes across customs points worldwide.
EBCA Position Paper on the Anti-Coercion Instrument (ACI)
The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a Regulation on the Anti-Coercion Instrument (ACI) that is aimed at deterring and counteracting third country economic coercion actions against EU Member States and economic actors.