A durability score would measure the garment. The durability number that exists measures the brand.

An information requirement and a performance requirement are not the same duty

The distinction is not ours. It is written into the framework, and the framework says which parts of it are settled and which are not.

Annex I of the Ecodesign for Sustainable Products Regulation lists twenty product parameters, and the first two are the ones this page is about. Point (a) is durability and reliability of the product or its components, expressed through the product's guaranteed lifetime, technical lifetime, mean time between failures, indication of real use information on the product, and resistance to stresses or ageing mechanisms. Point (b) is ease of repair and maintenance, expressed through a long list that begins with the characteristics, availability, delivery time and affordability of spare parts and runs through modularity, repair instructions, standard components and ease of non-destructive disassembly.

Reading that list is where most confident writing on this subject begins and ends, and the list settles nothing on its own. Annex I is a menu of parameters a requirement may be built on. It creates no duty, and it does not say which kind of duty will be built.

The two kinds are separated in the enacting terms, one article each, and they cost different amounts.

An information requirement, under Article 7, obliges a business to determine a value and disclose it. The cost is measurement, record-keeping and standing behind a published number. A product with a poor value may still be sold, and the market decides what to do with the information. Article 7 names the examples directly: information on the performance of the product in relation to one or more of the Annex I parameters, including a repairability score, a durability score, a carbon footprint or an environmental footprint.

A performance requirement, under Article 6, obliges the product itself to meet a threshold. Article 6 provides that performance requirements are based on the relevant Annex I parameters and may take the form of minimum or maximum levels for a parameter or a combination of them, or non-quantitative requirements aimed at improving performance. The cost is design, sourcing and, for anything that fails, withdrawal from the market. It is a different order of commitment, and it is what people are imagining when they read that durability requirements are coming.

One sentence in Article 7 settles the relationship between the two, and it is the single most useful line in the framework for anybody planning: an information requirement may be set for a specific product parameter irrespective of whether a performance requirement is set for that parameter. The two are independent. A duty to declare a durability score can arrive with no threshold attached to it at all, and on the preparatory evidence that is the more likely first move.

The preparatory work informing the textile decision has taken a position, and it is worth quoting rather than summarising. A performance requirement on robustness, it says, is not considered at this stage precisely because of reported uncertainties surrounding its applicability as a reliable measure of textile durability.

That one sentence does more work than any timeline in this category. It says the obstacle to a durability standard for clothing is metrological rather than political, which means it is not solved by anybody deciding to be stricter. It also means a business planning for a threshold is planning against something the evidence base does not currently support, while a business planning to be able to state a value is planning for what has actually been proposed.

What has been proposed, and what the five washes actually are

The proposal is a robustness score on a scale of nought to ten, produced from laboratory testing of the finished product rather than from a declaration. Three test families appear in the summary that was read: appearance after domestic washing and drying, spirality, and dimensional change. Base case values are given for each and they differ between woven and knitted construction.

Those figures are in the research record and are not transcribed here. A figure transcribed from memory is how a value gets separated from the construction and the test it belongs to, and that is the failure this page exists to describe in other people. What is published is the shape: three test families, values that differ by construction, and a score derived from them.

The five cleaning cycles are a pre-conditioning step

This is the correction the page earns its place with, because the misreading is now widespread and it inverts the meaning.

Commentary in this category reports the proposed durability threshold for clothing as five washes, usually with an observation that large retailers test to many times that number. Read at the summary itself, the sentence says something else. All tests must be performed on the product ready to be bought by the user, and all tests must be performed after five cleaning cycles according to the directions on the care label.

That is a specimen preparation instruction. The garment is washed five times and then it is tested. It is not a bar the garment has to clear, and there is no proposal anywhere in what was read that a garment must survive five washes. Anybody presenting it as a durability threshold has turned a pre-conditioning protocol into a standard, and the correction is available in the same sentence they took the number from.

The instruction is also a sensible one and worth understanding rather than merely correcting. A garment straight off the production line is not the garment a customer owns. Finishes relax, dimensions move and appearance changes in the first few cycles. Testing after five is testing something closer to the object in use, which is the point of measuring durability rather than measuring newness.

Which document the proposals are actually in

Two limits bound everything in this section, and one of them is a finding rather than a caveat.

What is described here was read at the published summary of a preparatory milestone of December 2025, not in the later study on passport content dated May 2026. That later study truncated before its proposal sections on every route this estate attempted, so nothing here is attributed to it. Commentary across this category attributes the durability, repairability and recyclability proposals to the later document, and on the evidence available that attribution appears to be mistaken about which document it is quoting.

And the later study is not a published Commission report. Its catalogue number, its book number and its digital object identifier are all still placeholders, it has no record in the publisher's own repository, and it carries the standard disclaimer of an external study report: that its contents do not necessarily reflect the position or opinion of the Commission. It is a pre-publication draft of an external study, being cited across this category as though it were settled Commission guidance.

The durability number that exists today, and what it is made of

Set the proposals aside and look at what a European textile business can actually produce now. There is exactly one governed durability figure available to it, and it comes from the French environmental cost method rather than from anything European. It is a dimensionless coefficient. Its value varies between 0.67 and 1.45. It divides the impact total, so a higher coefficient produces a lower published environmental cost, and it separately multiplies the default number of use cycles, so a more durable product is modelled as worn and cleaned more often across a longer life.

Then look at what goes into it. The order of 6 September 2025 sets two criteria, each weighted fifty per cent. One is the breadth of the brand's range, defined as the maximum number of references the brand offers on the market segment of the product concerned. The other is the incentive to repair, defined as the relationship between the average repair cost and the reference selling price, together with whether a repair service is offered at all.

That is the whole of it. No pilling. No seam strength. No abrasion. No colour fastness. No dimensional stability. The official methodological notice states the position itself: at this stage, only non-physical durability is taken into account.

The consequence is not an edge case. Two garments made in the same factory, from the same cloth, to the same specification, sold by two brands with different catalogue sizes and different repair pricing, receive different durability coefficients and therefore different published environmental costs. Nothing about the cloth enters the calculation.

We are not saying the design is wrong. It is a deliberate policy instrument aimed at business models rather than at fabrics, it is stated openly in the government's own notice, and a large catalogue turning over quickly is a real environmental phenomenon that no fabric test would catch. What we are saying is narrower, and it is a naming problem. The field is called durability, the number is used as a durability coefficient, and a reader meeting it in a product record will take it for a property of the product. It is not one.

One thing this estate could not obtain, and it matters if you are trying to move the number: how either criterion is scored. The order renders its scale as an image rather than as text, and the section of the methodological notice that would carry the sub-formulas is beyond what could be read. So the criteria and the weighting are established and the arithmetic inside each criterion is not.

That is also why this estate publishes the coefficient as a modelled figure with the calculator named and the version pinned, and why, where our own coefficient disagrees with the one the calculator itself divided by, the adjusted result is withheld and the calculator's undivided figure is published instead. Where this attribute sits among the rest, and how hard each one is to evidence, is on the field guide.

Repairability is two proposals wearing one word

The second place where this category's vocabulary does real damage, and the two things being confused sit in two different workstreams.

A horizontal repairability requirement, including a scoring system, is indicated in the Commission's working plan, with an indicative adoption year. Indicative is doing real work in that sentence: a working plan is a programming document rather than an adopted instrument, and this estate did not establish whether that horizontal requirement is scoped to reach apparel. So a repairability score exists as a signalled intention in a plan, and whether it lands on clothing is not established by us.

The textile preparatory work proposes something considerably smaller. In the summary that was read, the information requirement would focus on repair services directly offered by the brand, if any, including their details and contact information, delivered through the passport. The same passage proposes that this requirement be voluntary and that it apply only where the service is provided by the retailer.

A voluntary disclosure of a contact detail and a mandatory score computed from a product's design are not two versions of one requirement. They are different objects, and a business planning against the wrong one buys a testing programme it does not need or builds a service offer it does not need.

The estate's own attribute for this resolves for nobody on the test catalogue we run, and the reason is instructive rather than technical. A repair route is a commercial arrangement a business either has or has not made. There is nothing upstream to ask, no document to obtain and no laboratory that settles it. It is the one attribute in the set where the answer is entirely within the brand's own gift and is usually absent anyway.

Recyclability, the elastane threshold, and one figure that is not a requirement

The same preparatory summary proposes a recyclability score, also on a scale of nought to ten, and it contains the one hard threshold in the package. A product would be non-recyclable, and score nought, where it contains elastane in proportions higher than fifteen per cent, with that threshold rising to twenty per cent for blends that are rich in one particular polyamide.

Two things follow. The qualifier is routinely dropped in commentary, and the qualifier is the part a technical team needs, because it decides which blends fall on which side of the line. And the threshold reveals who the score is for. A recyclability score built around what defeats a recycling process is an instrument for the people operating that process, not a signal to a shopper. What a sorting line actually receives, and why a record about a garment usually does not reach it at all, is on what a recycler can actually use.

A figure also circulates in this territory as a minimum recycled content requirement, usually reported as five per cent. Read at the summary, five per cent belongs to nylon, and it appears alongside twenty per cent for the cotton in denim, ten per cent for wool and fifteen per cent for polyester in knitted and other woven products. More importantly, those proportions are described as the levels at which impacts were determined, which makes them modelling assumptions in an impact analysis rather than an adopted minimum. Reporting one of them as a requirement is wrong twice: wrong about the fibre, and wrong about the kind of thing it is.

What a recycled content claim can actually carry, and why the chain of custody model is part of the claim rather than a footnote to it, is on recycled content.

How a test result becomes a value a passport could carry

Everything above is about what may be required. This section is the part that will still be true whatever is required, and it is where the work actually is.

A test report is evidence about a specimen. It records what one laboratory measured, on the article it was sent, prepared in a stated way, by a named method, on a date. That is a precise and useful object, and it is not yet a product attribute. Three moves separate the two, and each of them is a decision somebody has to take and record.

From the specimen to the model. A report describes the garments submitted. A published value describes every unit of the model. That step is an inference, and its strength depends on how representative the specimen was and on whether anything changed in production afterwards. Nothing in a test report makes that inference for you, and none of the schemas this estate has looked at carries the rule that would.

From the method to the meaning. A result is only interpretable with its method, its preparation and its conditions attached. Five cleaning cycles before testing is exactly such a condition, and a dimensional change figure measured after five washes is a different quantity from one measured on unwashed cloth. Two values produced under different preparations are not two measurements of the same thing, and setting them side by side and calling the difference an error assumes they were.

From the value to the sentence. A declared value survives if the words published beside it do not reach further than the report. What each kind of document establishes before you ask it to support anything is on certificates, declarations and test reports, and the test a published claim has to survive is on what a passport field can and cannot prove.

The practical consequence is unglamorous and worth money. Many apparel businesses of any size already commission physical testing, for their own quality programme or because a buyer requires it. Those reports contain results that would populate a score of the kind being proposed, and they are commonly filed as a pass or a fail against somebody else's specification rather than as values. Capturing the value, with its method and its preparation, alongside the verdict is far cheaper at the point the report arrives than reconstructing it later, and for older seasons it may not be reconstructable at all.

What a business can do now that survives every outcome

Keep the value, not just the verdict. As above. It is the cheapest thing on this page, and the one whose cost rises fastest the longer it is left.

Record what is attached to the fabric. The elastane fraction, the trims, the coatings and the laminates. None of it is required today, all of it is known at the point of design, and it is the material a recyclability score of the proposed shape turns on. It is also what a brand has usually forgotten within a season.

Keep care information as what you advise rather than as what the fabric tolerates. Those are two different facts. A test establishes what a fabric survives. A care instruction is a decision the brand made, and it is the input to a durability protocol that conditions specimens according to the care label.

Do not buy against a threshold that has not been proposed. A testing programme scoped to prove that a garment clears a durability bar is scoped against a performance requirement the preparatory work has explicitly declined to propose. A programme scoped to produce stated values with named methods survives both outcomes, because a value is what an information requirement asks for and it is also what you would need if a threshold ever arrived.

Do not publish a score of your own devising. No agreed method for scoring textile durability or recyclability exists yet, and a score published without one is an opinion wearing a number.

What would change this page

A draft or adopted textile act, at which point everything described here as proposed either becomes a requirement or stops being relevant.

The May 2026 study on passport content obtained in full, which would let these proposals be checked against the current document rather than against the earlier milestone summary. This is now the largest single gap on the page, because the framework side of it has been closed.

A horizontal repairability instrument whose scope is legible, which would settle whether the scoring workstream reaches apparel at all.

Any published method for scoring textile durability or recyclability that carries authority behind it, which is the missing piece underneath every score described on this page.

Sources

• Joint Research Centre, textile preparatory study, third milestone, published summary, 12 December 2025
  Pre-decisional researchPublisher's own summary read, the document itself not

  Pre-decisional. Published summary read at source. Full study not read. Five propositions rest on it: that a robustness score on a nought to ten scale is proposed; that a performance requirement on robustness is not considered at this stage because of reported uncertainties surrounding its applicability as a reliable measure of textile durability; that all tests are to be performed on the product as it would be bought and after five cleaning cycles following the care label; that the repairability information requirement is proposed as a voluntary disclosure of brand repair service details applying only where the retailer provides the service; and that the recyclability score treats a product as non-recyclable above fifteen per cent elastane, rising to twenty per cent for blends rich in one polyamide. The recycled content proportions quoted are described in the same document as the levels at which impacts were determined. It is pre-decisional by design and it is never cited here as law.

• Joint Research Centre, study on DPP content for textile apparel products under ESPR, 13 May 2026
  Pre-decisional researchCover and contents read, the substance not reachable

  Pre-decisional, and pre-publication. Address confirmed and the document opened. Its proposal sections were not reachable and were not read. Registered so that a reader knows the document exists and knows this page does not rest on it. Its front matter and contents were read: the extraction stops around page 31, and sections 7 to 10 are unreachable. Three separate retrieval attempts produced fluent quotations attributed to sections beyond that point and all were discarded. What the front matter does establish is that the catalogue number, book number and digital object identifier are all placeholders, that it has no record in the publisher's own repository, and that it carries the disclaimer of an external study report whose contents do not necessarily reflect the position or opinion of the Commission.

• Ecodesign for Sustainable Products Regulation (EU) 2024/1781, consolidated text
  In forceRelevant provisions reviewed

  CELEX 32024R1781. In force. Read in full at the Official Journal HTML rendering, 28 August 2026, including Annex I. Four propositions rest on it. That Annex I point (a) is the durability and reliability parameter and point (b) the ease of repair and maintenance parameter, both quoted here in the terms the annex uses. That Article 6 makes performance requirements rest on those parameters and take the form of levels or non-quantitative requirements. That Article 7 makes information requirements able to cover performance in relation to those parameters, naming a repairability score and a durability score among the examples. And that Article 7 provides in terms that an information requirement may be set for a parameter irrespective of whether a performance requirement is set for it. What the annex does not establish is any duty at all: it is a menu of parameters, and only a delegated act creates an obligation from it. No such act exists for textiles.

  View official source

• Commission working plan COM(2025) 187
  IndicativeRelevant provisions reviewed

  Indicative. Relevant provisions reviewed. Named for one thing: a horizontal repairability requirement including a scoring system is indicated in it, with an indicative adoption year. Whether that requirement is scoped to reach apparel was not established by this pass, and the page says so rather than assuming it either way. The year belongs to the status tracker and is not stated here.

  View official source

• Order of 6 September 2025 on the signage and methodology for calculating the environmental cost of textile clothing products, and the official methodological notice published alongside it
  Government modelRead in a public body's copy rather than in the official gazette

  National instrument and official notice. The order's text read at a French state regulatory database. The notice read at its own address. The order was not read at the official legal gazette, which refused automated retrieval. Four propositions rest on them: that the durability coefficient is computed from two criteria each weighted fifty per cent, the breadth of the brand's range and the incentive to repair, with the definitions those instruments give; that its value varies between 0.67 and 1.45; that it divides the impact total and separately multiplies the default number of use cycles; and that only non-physical durability is taken into account at this stage. How each criterion is scored was not obtained: the order renders its scale as an image rather than as text, and the relevant section of the notice is beyond what could be read.