Pirmasens-based footwear technology and research institute  PFI has put together a guide to help shoe companies keep track of all the European Union sustainability regulations that could impact on the industry.

Sustainability first became popular in 1987, when United Nations (UN)-commissioned document the Brundtland Report, also called ‘Our Common Future’, was published. Since then, sustainability has been a major part of political and scientific discussions worldwide. In 2015, the Sustainable Development Goals (SDGs) were introduced as part the UN’s Agenda 2030. The SDGs consist of 17 goals targeting economic, social, and ecological aspects, and act as a guideline for sustainable entrepreneurship. Also in 2015, the UN Climate Change Conference took place near Paris, where most participants agreed to limit global warming to 1.5°C above pre-industrial levels in order to reduce the consequences of climate change.

In 2019, the European Commission presented the European Green Deal, aiming to make the European Union (EU) climate-neutral by 2050. The Green Deal’s various directives and regulations are designed to force economic actors in the EU to adopt more sustainable practices and, in turn, support the wider, ambitious goal.

The footwear and textile industries are, according to the EU, critical sectors, with highly negative social and ecological impacts, and are therefore significantly affected by the regulations. After the EU Green Deal was presented, the Commission realised that much of the required data could not yet be provided. As a result, the current Commission, which formed in December 2024, is addressing the challenges faced by manufacturers and has launched the Industrial Deal. Nevertheless, previously published regulations and the results of outstanding decisions must still be considered.

Forest focus

One of the most relevant of these is the European Deforestation Regulation (EUDR). It entered into force in June 2023, but will only come into application on December 30, 2025 for large and medium-sized operators, and on June 30, 2026 for small companies.

EUDR focuses on the protection of current forest lands. The aim is to prevent areas with natural forests from being transformed into agricultural landscapes for grazing cattle or cultivating raw materials such as cacao, soy, palm oil, coffee, rubber, and wood. It must be verified whether deforestation or forest degradation has occurred for these raw materials or certain products containing them. In addition to protecting natural forests, the regulation also obliges companies falling within its scope to comply with domestic regulations in the country of production.

As soon as any of the raw materials or products that are within the scope of EUDR is placed on the EU market, imported into the EU, or exported from the EU, companies must fulfil certain due diligence obligations to gain approval for trading those products. In this way, the EU aims to ensure that companies will maintain high levels of commitment to civil rights, labour rights and environmental protection.

Unsold products

Another piece of legislation that many companies are going to have to consider is the Ecodesign for Sustainable Product Regulation (ESPR). This entered into force in July 2024. ESPR prohibits the destruction of unsold products (including shoes and textiles) and will apply from July 2026 for large companies, and from July 2030 for medium-sized enterprises. Small enterprises will not be directly affected by ESPR.

This regulation’s aim is to prolong the lifespan of products. Exactly how it will be implemented is not yet clear. Further detail will be published in the coming months, but footwear will be one of industries to face early ESPR compliance.

Sustainability reports

The aim of the Corporate Sustainability Reporting Directive (CSRD) is to create a level playing field in the EU regarding sustainability reporting. It entered into force in January 2023 and the first sustainability reports to comply with CSRD will be published in the course of 2025.

Part of the thinking behind CSRD is to make it easier to compare one company’s progress against another’s, based on how they present that progress in corporate sustainability reports.

Under CSRD, the number of companies required to produce a sustainability report will increase significantly and their reports will have to be in keeping with EU reporting standards. These standards will specify how companies must report their achievements in a set series of environmental, social and corporate governance criteria. Reports must be audited by an external reviewer and published alongside a management report.

Expanding environmental responsibility to the supply chain, the EU also now has the Corporate Sustainability Due Diligence Directive (CSDDD). It entered into force in July 2024 and will apply to large companies from 2027. Companies that fall within its scope must take a closer look at social and environmental aspects within their supply chains. Additionally, they are required to report on their climate action plans.

The core of the CSDDD is its due diligence requirements, which companies must integrate into their processes to monitor, prevent, or resolve issues related to human rights or environmental pollution. Specifically, this includes risk analysis, preventive measures, complaint procedures, corrective action plans, efficiency checks, and reporting obligations. Topics already covered by the CSRD do not need to be reported again under the CSDDD.

Safety measures

The General Product Safety Regulation (GPSR) entered into force in 2023 and came into application in December 2024. This regulation ensures that consumer products, including products that people purchase online, pose no risk to consumers. Footwear products are among those covered by GPSR. As a result, companies must provide a risk analysis for their products and technical documentation demonstrating that risk mitigation measures have been implemented.

Furthermore, all products within the scope of the GPSR must be labelled with an electronic address for direct contact. The GPSR also provides clear instructions on how companies must recall their products from the market if a safety risk emerges.

Waste not

A newer initiative, the Packaging and Packaging Waste Regulation (PPWR), was scheduled to enter into force on February 11, 2025 and become applicable from August 12, 2026.

Its aim is to reduce packaging waste. One of the key elements in achieving this goal is to increase the recycling of materials and, by 2030, packaging materials should be affordably reusable or fully recyclable. Additionally, the empty space within packaging should be reduced to minimise weight and volume.

In future 

A new Forced Labour Regulation entered into force on December 13, 2024, but it will be December 2027 before it comes into application.

Products produced using forced labour will no longer be allowed in the EU.

Lastly, there is the Green Claims Directive, which is still in negotiation. Its aim is to protect customers from greenwashing. It establishes requirements for the communication and verifiability of product information, particularly claims related to products being good for the environment. This ensures that customers who wish to purchase more sustainable products can do so with greater confidence.

Conclusion

On the one hand, the ambitions and expectations associated with the EU Green Deal are a challenge for the EU and its industries and trade. On the other hand, they also present an opportunity for a shift towards a more sustainable and environmentally friendly lifestyle.

Since all EU member states must comply with the corresponding regulations, a level playing field will be created within the EU. In the future, sustainability will be considered when evaluating and rating companies, alongside shareholder value. Bank lenders and public tenders already, in some cases, require information on sustainable practices, and this will likely increase as the regulations and directives described here come into force. While SMEs generally have more time to prepare for the upcoming regulations, the additional obligations they will need to fulfil will still present a challenge.

Additionally, owing to the changing geopolitical situation, the EU recognises that the economic environment is evolving, and that industry needs more support to remain competitive in the future, which could lead to simplifications in due diligence reporting.

PFI offers support to companies in their efforts to comply with the upcoming regulations. The PFI Eco Label  is a tool to support a company’s journey towards more sustainable entrepreneurship. Owing to the large number of EU directives and regulations, and to the associated obligations and due diligence tasks, complying will be challenging for companies inside and outside the EU. The PFI Eco Label is a tool that efficiently helps companies act more sustainably and comply with upcoming restrictions.

It is a two-step process. First, companies must fill out a questionnaire that clearly guides them through the maze of EU sustainability regulations. In the second step, companies undergo an audit through a training interview based on the questionnaire. Upon successful completion of both steps, companies receive a PFI Eco Report and the PFI Eco Label, providing them with the opportunity to showcase their sustainability efforts to customers.

CREDIT: Fashion For Good/Marta Frigato

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