EU Ecolabel extended to 2028: why the Commission is waiting for the ESPR textile delegated act (Decision 2026/66)

Decision (EU) 2026/66 extends the EU Ecolabel criteria for textiles and footwear until 31 Dec 2028, pending the ESPR delegated act. Critical reading of the Ecolabel↔ESPR convergence.

• Commission Decision (EU) 2026/66 (23 Dec 2025, OJEU 6 Jan 2026) extends the validity of the EU Ecolabel criteria: textiles and footwear until 31 Dec 2028, furniture and floor coverings until 2029, mattresses until 2030 [recital 10]. Legal basis: Art. 8.2 of Regulation (EC) 66/2010.
• Textiles receive different treatment: unlike the other categories —deferred because they remain up to date— their revision is tied to the publication of the ESPR delegated act of Regulation (EU) 2024/1781 [recital 8].
• Recital 8 contemplates that the Ecolabel may serve as evidence of compliance with the ecodesign requirements "to the extent that they are covered by the criteria". Art. 41.4 of the ESPR enshrines that presumption of conformity, conditional and not universal.
• The Ecolabel is a voluntary scheme of excellence (market-pull); the ESPR is mandatory for market access (market-push). Obtaining the Ecolabel does not exempt from deploying the ESPR Digital Product Passport.

What Decision 2026/66 does

Decision (EU) 2026/66 operates as an instrument of legal continuity and internal-market stabilisation for the operators adhering to the voluntary EU Ecolabel system. Adopted on 23 December 2025 and formally published in the Official Journal of the European Union on 6 January 2026, the rule intervenes directly on five pre-existing decisions. The primary objective consists in avoiding the regulatory lapse of the ecological criteria which, in the case of textile products (Decision 2014/350/EU) and footwear (Decision (EU) 2016/1349), were imminently expiring on 31 December 2025 [recital 2]. Lacking new finalised criteria to replace them, inaction would have generated a vacuum that would deprive Ecolabel licence holders of their certification framework.

The legal basis that enables this intervention is found in Regulation (EC) No 66/2010 on the EU Ecolabel, specifically in its Article 8(2), which empowers the Commission to establish specific Ecolabel criteria for each product category. Exercising this power, and after consulting the European Union Ecolabelling Board, the Commission consolidates a new stratified temporal horizon. Recital 10 underpins the technical decision to group categories and stagger expiries to provide sufficient time for the revision processes and to guarantee licence holders continuity in the market.

The articles execute the extension surgically. The criteria for textile products and footwear will be valid until 31 December 2028; those for furniture and coverings based on wood, cork and bamboo, until 31 December 2029; and those for mattresses, until 31 December 2030 [recital 10]. The simultaneous extension of five categories in a single legal act reflects an effort by the Commission to consolidate the administrative management of the scheme and to grant legal certainty to the operators who base their environmental claims on these official technical criteria.

This temporal stratification is not arbitrary; it responds to the prior evaluation under the REFIT programme (fitness check), mentioned in recital 7, which confirmed the pertinence of maintaining the system. It prevents the fragmentation of isolated revisions and allows operators to plan ecodesign and certification investments in the medium term without the risk of their licences becoming obsolete due to regulatory expiry.

Why textiles are treated differently

The exegesis of the preamble reveals a deliberate asymmetry in the justification of the extensions. While the deferral of the revisions for mattresses, furniture, footwear and floor coverings is justified by technical sufficiency, textiles obey a subordination to the calendar of a superior regulatory framework under development. For the other categories, recital 8 states that the evaluations "showed that [...] the criteria remained up to date and would probably remain so in the near future": their revision is deferred for procedural economy.

The approach to the textile sector changes paradigm. The same recital 8 introduces a precedence condition: "In the case of textile products, the ongoing revision should be completed after the publication of the related delegated act under Regulation (EU) 2024/1781 of the European Parliament and of the Council". The provision subordinates the revision calendar of the textile Ecolabel to the deployment of the Ecodesign for Sustainable Products Regulation (ESPR). The Commission intentionally freezes the update of the criteria (Decision 2014/350/EU) to avoid a regulatory collision with the future mandatory ecodesign requirements.

The legal justification is anchored in the principle of coherence of the acquis. Recital 8 specifies that the wait operates "in order to ensure coherence between the requirements set out in that delegated act and the criteria of the EU Ecolabel". Modifying the textile Ecolabel without knowing the parameters of durability, recyclability, recycled content and information (Digital Product Passport) that the ESPR delegated act will impose would have generated regulatory risk: a voluntary "excellence" criterion could turn out, in practice, to be inferior or contradictory against a mandatory minimum requirement imposed later.

This pause evidences the complexity of textiles within the European industrial ecosystem. Identified as a high-environmental-impact category and a priority in the ESPR Working Plan, textiles require an assembled regulatory architecture. By conditioning the revision of the Ecolabel to the prior publication of the delegated act, the Commission ensures that the future voluntary scheme is built above the new mandatory legal floor, recalibrating its requirements to continue rewarding, indicatively, the segment of products with the best environmental performance on the market.

The Ecolabel as possible evidence of ESPR compliance

The core of greatest significance for compliance professionals lies in the last proposition of recital 8: coherence is pursued "taking into account the possibility that the EU Ecolabel may be used in the future as evidence of compliance with the ecodesign requirements [...] to the extent that those requirements are covered by the criteria of the EU Ecolabel". The density of this formulation requires a restrictive interpretation, avoiding any unfounded commercial extrapolation.

In the first place, the rule speaks of a "possibility", not of a consolidated automatism. The ESPR Regulation (2024/1781) contemplates in its Article 41(4) that products awarded the EU Ecolabel will be presumed to conform with the ecodesign requirements of the applicable delegated act. However, this presumption does not operate as a universal exemption: its effectiveness depends on a strict condition, "to the extent that those requirements are covered by the criteria of the EU Ecolabel" (Art. 16.2 of Regulation 66/2010).

This limitation is the axis of the convergence. A textile product certified with the Ecolabel under the future revision will only be exempt from demonstrating compliance with those ESPR parameters that are materially and identically integrated into the criteria of the label. If the delegated act requires, for example, a Digital Product Passport with traceability attributes that the Ecolabel does not require with the same granularity, holding the Ecolabel will not exempt from issuing the DPP. The presumption will operate, foreseeably, on technical thresholds: chemical restrictions, water-efficiency ratios in dyeing, colour-fastness parameters or abrasion resistance.

The calibration will require a mapping of correspondences between the articles of the ESPR delegated act and the future Ecolabel Decision. For brands, the Ecolabel will not be a "fast track" to evade the documentary obligations of the ESPR, but a complementary instrument that will facilitate the technical passing of certain conformity audits. It is a partial administrative simplification: recital 8 blocks the narrative of total equivalence, and the presumption will act only where strict isomorphism exists between the voluntary standard and the mandatory requirement.

What the EU Ecolabel is and what it is not

To contextualise the impact of the extension it is imperative to delimit the legal nature of the Ecolabel. The EU Ecolabel is, by definition of Article 1 of Regulation (EC) No 66/2010, a voluntary system. Its purpose is not to regulate basic market access, but to promote products with reduced environmental impact throughout their life cycle, providing consumers with accurate and non-misleading information. It is a market-pull tool, designed to incentivise the products with the best environmental performance, indicatively targeting the upper segment of the market.

In contrast, Regulation (EU) 2024/1781 (ESPR) is a market-push regulatory instrument. The ESPR establishes the imperative requirements that any physical product must meet to be placed or marketed on the internal market. Lacking conformity with the ESPR implies commercial exclusion; lacking the Ecolabel simply implies not bearing a distinctive of excellence, without access barriers. The asymmetry between the mandatory nature of the ESPR and the voluntary nature of the Ecolabel is the principle that delimits both regimes.

Under this framework, the Ecolabel is not —and will not be— equivalent to the Digital Product Passport (DPP) instituted by Chapter III of the ESPR. The DPP is a structured, interoperable and mandatory data vector that will accompany each product to guarantee the traceability of the value chain. The Ecolabel is a certification of compliance with predefined criteria granted after documentary audit and, often, laboratory tests. Obtaining the Ecolabel will not exempt the manufacturer from deploying the data architecture of the DPP, although the label may be registered as a positive attribute within the fields of the Passport itself.

Likewise, the Ecolabel must not be confused with the frameworks for substantiating environmental advertising claims, although it acts as a safe harbour: being an officially recognised third-party certification, it provides a robust substrate against the greenwashing prohibitions of Directive 2024/825 (ECGT). However, it imposes integral life-cycle criteria and does not serve to certify partial or isolated claims. It is a voluntary scheme of holistic excellence, unsuitable as a general substitute for the traceability and minimum-compliance systems that the ESPR will impose.

Calendar and window 2026-2028

The technical convergence between the revision of the Ecolabel and the development of the ESPR demands millimetric chronological coordination. Decision 2026/66 sets an immovable date: the current textile Ecolabel criteria, defined in Decision 2014/350/EU, cease to be valid on 31 December 2028. This horizon determines a window of action of barely three years (2026-2028) to execute a revision which, by mandate of recital 8, cannot be completed until the ESPR delegated act for textiles is adopted.

The sequencing depends on the milestones of the ESPR Working Plan 2025-2030 (Communication COM(2025) 187 final). That document places textiles as the top priority and foresees an indicative adoption date for its delegated act around the year 2027. Once the definitive text is published —establishing requirements of durability, recycled content, carbon footprint and DPP information— the final phase of revision of the Ecolabel criteria will be triggered.

The Joint Research Centre (JRC) and the Ecolabelling Board will have to transfer the parameters of the delegated act to the Ecolabel assessment framework, ensuring that the new thresholds represent a real leap in requirement against the legal baseline of the ESPR. The Commission will have to adopt and publish the new textile Ecolabel Decision during 2028, before the extension expires.

This coordination minimises uncertainty for the industry, but it requires vigilance of the deadlines. During 2026-2028, manufacturers wishing to certify textile products with the Ecolabel will continue to operate under the rules of Decision 2014/350/EU, with legal certainty guaranteed by Decision 2026/66. Nevertheless, technical departments must anticipate that the criteria that replace the current ones from 2029 will entail a notable tightening, as they will have to exceed the baseline requirement of mandatory ecodesign. The extension is not a reprieve from the requirement, but time for the recalibration of the standard.

Analytical reflection

Decision (EU) 2026/66 transcends mere deadline management: it crystallises a reconfiguration of the Union's product policy. The subordination of the revision of the voluntary Ecolabel scheme to the development of the mandatory ESPR framework evidences a strategy of regulatory consolidation. The Commission erodes the legislative silos, forcing interoperability between the legal-push (market-push) and commercial-pull (market-pull) mechanisms. By converting the Ecolabel into potential partial evidence of compliance with Regulation 2024/1781, the Union indirectly incentivises adherence to voluntary excellence schemes as a mechanism of documentary simplification.

This convergence demands a professionalised management of textile sustainability. Entities that base their claims on the extended criteria of Decision 2014/350/EU must interpret the extension to 2028 as a transition period to audit their supply chains. The future compatibility between the ESPR delegated act and the new Ecolabel will require a granular traceability architecture that surpasses passive documentary collection: chemical taxonomy (Restricted Substance List), mass balances for recycled content and origin traceability will become preconditions.

The scenario becomes more complex when it intersects with the environmental-claims framework of the ECGT Directive. While the Ecolabel will maintain its status as an official third-party certification —shielding its holders from accusations of greenwashing for generic claims—, obtaining it will become more expensive as it has to distance itself from the new legal floor set by the ESPR textile delegated act anticipated for 2027, whose calendar is detailed in the ESPR Working Plan 2025-2030.

Consequently, commercial differentiation based on sustainability will require traceable evidence. The presumption of conformity of recital 8 will operate under strict scrutiny. Brands that treat this extension as a pause in the requirement will be exposed to a double risk at the conclusion of the 2026-2028 triennium: the loss of the excellence certification and the blockage of market access for non-compliance with basic ecodesign.