EU regulatory framework
- → Double-materiality assessment covering impact and financial perspectives
- → Reporting aligned with European Sustainability Reporting Standards (ESRS)
- → Third-party limited assurance on sustainability disclosures
- → Digital tagging in XHTML format for machine readability
Fashion brands meeting revenue or employee thresholds must disclose supply-chain emissions, labour practices, circularity metrics, and governance structures. Non-compliance risks fines, reputational damage, and restricted access to EU capital markets.
China green standards
- → Compliance with national green-product evaluation standards for textiles
- → Restricted-substance testing aligned with GB 18401 safety requirements
- → Voluntary China Green Product Certification for market differentiation
- → Labelling and documentation in Mandarin meeting SAMR guidelines
European brands exporting to China must align product testing and certification with GB/T standards. Green certification can unlock preferential treatment on platforms like Tmall and JD, but the process requires dedicated local compliance support.
Are you prepared?
Regulatory Audit
Comprehensive assessment of your current compliance posture across all applicable EU and China regulations.
Gap Analysis & Roadmap
Identify gaps, prioritise actions, and build a phased implementation plan with clear milestones and deadlines.
Ongoing Monitoring
Continuous regulatory tracking and alerts so you are never caught off-guard by new requirements or enforcement changes.
What is in force, what is provisional, what is expected.
Half of this is not settled law. Deadlines agreed under the Digital Omnibus still require formal adoption and can move, so they are labelled as provisional rather than quoted as dates. Plan against the obligation; treat the date as the estimate it is.
| Obligation | Status | Confidence | What it means |
|---|---|---|---|
| EU AI Act — Article 50 transparencyRegulation (EU) 2024/1689, Article 50 | In force since 2 August 2026 | In force | Catches any business producing AI-generated content or running public-facing AI interfaces — campaign imagery and lookbooks included. |
| EU AI Act — GPAI enforcement and penaltiesRegulation (EU) 2024/1689, Chapter V and Article 99 | In force since 2 August 2026 | In force | Obligations applied from 2 August 2025; the enforcement powers and penalty regime switched on a year later. |
| EU AI Act — Annex III high-risk obligationsDigital Omnibus political agreement, 7 May 2026 | Provisionally deferred to 2 December 2027 | Provisional | Deferred under the Digital Omnibus agreement of 7 May 2026. Still requires formal adoption, so plan against the obligation rather than the date. |
| EU AI Act — Annex I high-risk obligationsDigital Omnibus political agreement, 7 May 2026 | Provisionally 2 August 2028 | Provisional | Same Digital Omnibus caveat: agreed, not yet formally adopted. |
| Obligation | Status | Confidence | What it means |
|---|---|---|---|
| ESPR Article 25 — unsold textile destruction banRegulation (EU) 2024/1781, Article 25 | In force since 19 July 2026 for large enterprises | In force | Destroying unsold apparel and footwear is prohibited for large enterprises, with disclosure obligations attached. |
| ESPR textile delegated actEuropean Commission ESPR working plan | Adoption expected 2027 | Expected | Minimum eighteen-month transition once adopted, so compliance realistically lands in 2028–29. The data spine is the slow part; start it before the schema is fixed. |
| Digital Product Passport — batteriesRegulation (EU) 2023/1542 | February 2027 | Expected | First mover across all product categories. Useful precedent for how the textile passport is likely to be structured. |
| EU Deforestation Regulation (EU) 2023/1115 - due-diligence statement per consignmentRegulation (EU) 2023/1115, Annex I | Applies from 30 December 2025 for large and medium operators, 30 June 2026 for micro and small, after the 12-month deferral of the original December 2024 date. Further simplification has been under discussion - re-check before planning against it. | In force | Covers seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. For fashion that means BOVINE LEATHER and NATURAL RUBBER, with geolocation back to the plot. Cotton is not in scope - a claim that it is was on this site and was wrong. |
| GB 31701 - China national safety technical code for infant and children textile productsGB 31701-2015 | Mandatory since 1 June 2016. Class A (under 36 months), B and C by age and skin contact. | In force | Any childrenswear sold in mainland China needs the class marked on the label and the test evidence behind it. It governs cords, sharp points, formaldehyde and colour fastness, and it is enforced at customs. |
| US Consumer Product Safety Improvement Act - lead, phthalates and tracking labelsPublic Law 110-314 | In force since 2008, with the lead limit at 100 ppm since 2011. | In force | Childrenswear sold into the US needs third-party testing to a CPSC-accepted lab and a permanent tracking label. It applies to components, not just the finished garment, which is where BOM data has to be good enough to answer. |
| EN 14682 - cords and drawstrings on children's clothingEN 14682:2014 | Harmonised standard, current version EN 14682:2014. | In force | Sets what is permitted at the hood, neck, waist and hem by age band. A safety standard rather than a certification: conformity is presumed if you meet it, and the burden is on you if you do not. |
| California AB 1817 - PFAS in textile articlesCalifornia AB 1817 (2022) | Banned in textile articles from 1 January 2025; outdoor apparel for severe wet conditions from 1 January 2028, with disclosure required in the meantime. | In force | The first US state ban to bite on apparel. Outdoor and technical brands get the extra window only if the product genuinely qualifies as severe-wet-conditions gear, and have to label it until then. |
| REACH universal PFAS restriction - EU-wideECHA restriction proposal, January 2023 | Proposal submitted January 2023 by five member states; still in ECHA committee opinion-forming. No adoption date. | Expected | The broadest of the PFAS instruments and the one with no date. Plan the substitution roadmap against the state-level bans that already apply, not against this - but assume it lands. |
| French AGEC law 2020-105 - environmental information and anti-waste obligationsLoi n 2020-105 (AGEC) | In force since 2020, obligations staged by company size through 2025. | In force | Requires per-product environmental information for goods sold in France, bans destruction of unsold textiles, and underpins the Refashion EPR scheme. It is why a French-market SKU needs data a pan-EU SKU does not yet. |
| Obligation | Status | Confidence | What it means |
|---|---|---|---|
| UCP — Universal Commerce ProtocolNRF specification; Shopify agent registration, 17 June 2026 | Spec public since January 2026 | In force | Published by the NRF. Shopify has offered self-serve agent registration since 17 June 2026, which is the practical route in for most brands. |
| ACP — Agentic Commerce ProtocolProtocol specification; Instant Checkout deprecation, March 2026 | Live | In force | The protocol survives; the in-chat checkout product built on it does not. Instant Checkout was deprecated in March 2026 — the clearest available warning that protocol selection needs judgement, not enthusiasm. |
| AP2 — Agent Payments ProtocolAP2 specification | Live | In force | Signed Intent, Cart and Payment mandates carried as verifiable credentials. Relevant only where an agent completes a payment rather than handing off. |
| MCP and A2AMCP and A2A specifications | Live, and shared across camps | In force | The shared transport layer every major agent ecosystem has converged on. Building your systems as MCP tools is the least vendor-committing move available. |
These dates are an architecture problem, not a policy one.
Transparency obligations, content provenance and passport-ready product data are all outputs of how your systems are structured. So is protocol readiness for the surfaces where discovery is moving. Both are engagements rather than advice.
EU AI Act, content provenance and DPP-ready product data - as an architecture problem, not a policy document.
See the capability →UCP, ACP, AP2 and MCP - catalogue readiness for the surfaces where discovery now happens.
See the capability →One company. Two front doors.
We are not advisers who read about agentic AI. We designed, built and operate McLeuker AI - a multi-agent platform for fashion, running in production. That is where the consulting comes from: every recommendation is something we have already had to make work.
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The agentic AI platform we built and run for fashion brands. Your engagement ships onto it, loaded with your brand context.
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