Europe Is Writing Fashion’s Sustainability Rules. Can Asian Factories Deliver?

By Dr Thiwanka De Fonseka, Chief Sustainability Officer, Komar & One of NewInAsia’s 10 Top Voices You Should Follow in South Asia (2026)

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Europe is changing the rules of the apparel industry. The interesting part is that many of the people responsible for making those rules work are not in Europe. They work in spinning mills, fabric mills, dye houses and garment factories across Asia.

For years, sustainability regulation in fashion largely focused on what companies disclosed: carbon emissions, environmental policies, supplier lists and sustainability targets.

That is changing.

The European Union is increasingly looking at the product itself, including what it is made from, how it was produced, what information follows it through the supply chain and what happens at the end of its useful life.

The Ecodesign for Sustainable Products Regulation (ESPR) is an important part of that shift.

Textiles and apparel are a priority product group under the EU’s 2025–2030 working plan. Detailed textile requirements, including eventual Digital Product Passport obligations, are still being developed. The European Commission currently expects to adopt the relevant delegated act in the fourth quarter of 2027.

On paper, much of this is European regulation. In practice, it quickly becomes a supply-chain issue.

A Digital Product Passport, for example, can include information on fibre composition, product origin, repair, reuse, recycling and other aspects of a product’s life cycle.

But that information does not magically appear when a garment reaches Europe.

Someone has to generate and verify it, connecting information from fibre to yarn, fabric, wet processing, garment manufacturing and ultimately the finished product.

A significant share of that work will occur in Asia, where many of the industry’s supply-chain partners are concentrated.

Who Bears the Burden of EU Sustainability Compliance?

This is a question the industry needs to discuss more openly.

European regulations can impose legal obligations on companies placing products on the European market. However, legal accountability and operational responsibility are not always aligned.

A brand may ultimately be accountable for the information associated with a product, while much of the underlying data must come from suppliers several tiers removed from the brand.

This matters enormously in apparel because much of its environmental footprint is concentrated within the supply chain.

At Komar, for example, more than 98% of our greenhouse gas footprint falls within Scope 3. Our 2025 carbon inventory recorded approximately 799,000 tonnes of carbon dioxide equivalent (CO₂e) from purchased goods and services alone.

That is not particularly surprising for an apparel business.

The majority of a garment’s environmental impact is not generated in a corporate office. It is associated with raw materials, textile processing, manufacturing, transportation, product use, and end of life.

When regulation requires more environmental information about a product, the request inevitably travels upstream.

The risk is that we simply keep pushing requirements down the supply chain.

Brands ask vendors, vendors ask factories, factories ask mills, and mills ask material suppliers.

Eventually, someone has to collect the data, maintain the systems, undergo assessments, and pay for the people required to manage it.

That raises an uncomfortable but necessary question:

Who pays for transparency?

If sustainability data is becoming part of the product, the cost of producing credible information may also need to become part of the commercial conversation.

Why Supply-Chain Transparency Is More Than a Technology Problem

There is sometimes an assumption that supply-chain transparency is primarily a technology problem.

Buy a traceability platform, connect suppliers, and suddenly the supply chain becomes visible.

In my experience, it is rarely that simple.

A platform can organise information, but it cannot create information that does not exist.

A Tier 1 garment manufacturer may have sophisticated environmental management systems, energy records and chemical management data.

Move upstream to a smaller mill or raw-material processor, and the situation can look very different.

Data may be stored in spreadsheets. Electricity consumption may be available only at the facility level. Product-level energy allocation may not exist. Material certifications may be kept separate from commercial information.

Different customers may also request the same information in completely different formats.

This is where the next stage of traceability becomes challenging.

Operationally, it requires suppliers, systems and commercial teams to speak the same language and trust one another.

Factories need to understand why information is requested, how it will be used and whether sharing it poses commercial risks.

Brands and sourcing companies, meanwhile, need sufficient confidence in the information to use it for customer reporting and, eventually, product-level claims.

This cannot be solved simply by sending suppliers another questionnaire.

Could Sustainability Data Become a Competitive Advantage?

There is another side to this story.

Factories that build robust environmental and traceability systems may find these capabilities commercially valuable.

For many years, apparel sourcing decisions have focused on three familiar factors: price, quality and lead time.

I believe we are moving towards a fourth factor: data readiness.

That does not mean sustainability data will replace price, quality or speed.

A factory that cannot deliver the right product at the required quality, price and time will not succeed simply because it has an excellent environmental database.

However, manufacturing excellence alone may increasingly be insufficient.

A supplier that provides credible traceability, chemical information, environmental performance data and supporting documentation reduces risk for its customer.

It can simplify regulatory compliance, accelerate product development, strengthen sustainability claims and reduce the administrative burden of reconstructing information months after production.

In that sense, data becomes part of the product.

These capabilities may increasingly influence which suppliers are easiest to work with in regulated markets.

Building Capacity Across the Supply Chain

I can already see this trend in our supply chain.

Komar achieved 100% adoption of the Higg Facility Environmental Module (FEM) self-assessment among more than 265 Tier 1 and Tier 2 suppliers during the 2025 reporting cycle.

We also reached 87.5% adoption of ZDHC Level 1 or higher chemical formulations across applicable wet-processing facilities.

These programmes began as environmental management tools. Increasingly, they are becoming part of the information infrastructure supporting the product.

For larger, more sophisticated factories, this transition may offer a competitive advantage.

For smaller suppliers, however, there is a real risk of exclusion if compliance costs and complexity rise faster than their capacity to invest.

That is why brands, vendors and sourcing companies need to think carefully about building supplier capacity.

If the industry wants better information, we have to help build the systems that produce it.

The Risk of Measuring Sustainability Without Improving It

There is another danger in this transition.

We can become extremely good at measuring sustainability without becoming equally adept at improving it.

The apparel industry now has dashboards, scorecards, questionnaires, life cycle assessments, facility environmental assessments, supplier platforms and increasingly sophisticated carbon-accounting systems.

All of these have value.

But a dashboard does not decarbonise a dye house. A Digital Product Passport does not make polyester circular. A traceability platform does not install solar panels.

At some point, sustainability has to lead to tangible changes in how products are made.

That is why an organisation’s climate strategy should keep measurement and action connected.

The data should tell us whether the strategy is working. It should not become the work itself.

Europe Is Also Changing What Happens After a Product Is Sold

The regulatory shift extends beyond product information.

The revised EU Waste Framework Directive mandates Extended Producer Responsibility (EPR) schemes for textiles and footwear.

Member States will need to establish systems through which producers contribute financially to the collection, sorting, reuse and recycling of textile waste.

The EU has also introduced restrictions on the destruction of unsold apparel and footwear, with the prohibition applying to large companies starting in July 2026 and later to medium-sized companies.

Taken together, these measures begin to change the economics of a garment.

Historically, much of the industry has optimised the path to the point of sale.

The next regulatory era asks companies to consider the entire journey: where materials came from, what happened during manufacturing, what information accompanies the product, how long it can remain in use and what happens when the consumer no longer wants it.

That is a very different operating model.

Why Asian Factories Are Central to Europe’s Sustainability Transition

It would be easy to frame all of this as a European compliance story. However, I think that misses the bigger picture.

The EU can set the conditions for placing products on its market, including imported products.

But regulation alone cannot create a traceable, low-carbon and increasingly circular apparel industry.

That transformation has to happen throughout the supply chain.

It happens when a mill replaces coal with cleaner energy, when a factory installs renewable electricity, and when a supplier can trace certified material from an upstream source to a specific production order.

It also happens when chemical information is reliable enough to track a product through processing, and when sourcing decisions begin to recognise these investments rather than treating sustainability as an additional requirement suppliers are expected to absorb.

This is why I believe the relationship between European regulation and Asian manufacturing deserves far more attention.

Moving Beyond Compliance to Strategic Partnership

Asian factories should not be treated merely as the final recipients of European sustainability requirements.

They will be central to whether those requirements achieve their environmental objectives.

There is also an opportunity.

Suppliers that invest early in renewable energy, traceability, environmental data and cleaner production may become more valuable partners to brands operating in increasingly regulated markets.

Likewise, brands and sourcing organisations that build genuine long-term partnerships with those suppliers may be better positioned than companies that continue to manage sustainability primarily through questionnaires and compliance audits.

The future of sourcing may therefore involve four questions rather than three:

• What does it cost?
• Can you meet the required quality standards?
• Can you deliver it on time?
• Can you prove how it was made?

That fourth question could have profound consequences for the apparel industry.

Europe may be writing many of the new rules for sustainable products. However, whether those rules lead to genuinely more sustainable products will depend, to a significant degree, on what happens thousands of kilometres away from Brussels.

It will depend on decisions made in spinning mills, fabric mills, dye houses and garment factories across Asia.

The next chapter of sustainable fashion will not be written solely in Brussels. It will also be written on factory floors in Asia.

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About the Contributor

Dr Thiwanka De Fonseka is Chief Sustainability Officer at Komar, where he leads initiatives focused on environmental and product sustainability.

He works with internal cross-functional teams and external organisations, including Cascale, ZDHC, BCI and Textile Exchange, to advance sustainability objectives.

His expertise focuses on aligning business strategy with sustainable practices and integrating innovative solutions into corporate operations to support responsible business practices across the global fashion industry.

He was also featured in NewInAsia’s 10 Top Voices You Should Follow in South Asia (2026).

Read the Chinese article here.