In 2026, four European regulations were all packed into the same shoebox: packaging, environmental claims, PFAS and unsold stock. For those working on the volume, sustainability has become a dossier: it sits on the importer’s desk, but it is the supplier who fills it in.
The box is made of cardboard. Inside is a pair of trainers wrapped in tissue paper and a bag of filler. In 2026, this item was subject to four different regulations.
From 12 August, anyone placing the box on the shelves of a European shop must be able to demonstrate that the packaging complies with the regulations, by means of a declaration and a technical dossier. From 27 September, the words ‘eco’ or ‘sustainable’ may no longer be printed on the lid without verifiable evidence. If the upper has a PFAS-based water-repellent treatment, that pair cannot be sold in France: the ban applies to products manufactured from 1 January 2026. And if the pair remains unsold, from 19 July a large company can no longer destroy it.
Taken together, these dates send a clear message. By 2026, sustainability will no longer be a marketing choice but a documented obligation: every regulation has a deadline, a responsible party and documentation to be retained. Legal responsibility lies with the importer, but the data must be provided by the manufacturer, often based in Asia. For those dealing with large volumes, moreover, the heaviest cost to bear will not be the recycling levy, which amounts to just a few pence per pair. It will be the red tape involved in having to register and report in every country where the products are sold. Not everything, however, is moving faster. Leather has been excluded from the deforestation regulation; the digital passport for footwear does not yet have a specific date for coming into force; and the next deadlines fall between 2027 and 2028.
THE IMPORTER IS LIABLE, THE SUPPLIER DOCUMENTS
Almost all of these regulations identify the same responsible party: whoever first places the product on the European market. In high-volume trade, this is the importer, the brand, the retail chain purchasing private-label goods and, increasingly, the online marketplace. It is this party that is accountable to the authorities and pays any penalties.
The manufacturer in China, Vietnam or India has no direct obligations towards the European Union. However, in order to comply with regulations, their European client needs their data: declarations on chemical substances, material composition, the origin of the leather, and evidence to support any environmental claims. For this reason, the obligation is passed on to the supplier via the purchase contract, not through legislation. Anyone unable to provide these documents risks losing the client.
The size of the company is only partly relevant. The Omnibus Directive, published in February 2026, limited the Corporate Sustainability Reporting Directive (CSRD) to companies with more than 1,000 employees and a turnover of 450 million euro : the vast majority of high-volume operators are exempt. Regulations on packaging, environmental claims and chemicals, on the other hand, apply to everyone, regardless of company size.
TWO-THIRDS OF IMPORTS COME FROM CHINA AND VIETNAM
To understand who will be required to provide these documents, one need only look at where the shoes come from. In 2025, of the European Union’s footwear imports from non-EU countries, China accounted for 41.5 per cent (€11.4 billion) and Vietnam for 25 per cent (€6.9 billion): together, they made up 66.5 per cent. They were followed by Indonesia (6.2 per cent) and India (4.1 per cent). The figures are taken from the Commission’s DG Trade country factsheets, based on Eurostat data (calculated by value rather than by number of pairs).
UNSOLD GOODS: NO LONGER TO BE DESTROYED FROM 19 JULY
According to an estimate by the European Commission published in February 2026, between 4 and 9 per cent of unsold textiles in Europe are destroyed each year without ever having been worn. The Ecodesign Regulation prohibits the destruction of unsold clothing, accessories and footwear. The ban comes into force on 19 July 2026 for large enterprises and in 2030 for medium-sized enterprises. Micro and small enterprises are exempt.
There are ten exemptions, set out in a Commission act of February 2026, which cover, for example, damaged or unsafe products. Anyone destroying goods under an exemption must document this and keep the records for five years. Furthermore, large enterprises must already declare annually how many unsold products they dispose of and why: from February 2027, they will do so using a single European template.
For those operating on a large scale, the consequence is immediate. An oversized order can no longer simply be sent for pulping: end-of-line stock must be resold, donated or sent for recycling, and each of these options incurs a cost. Forecasting errors now cost more than before.
MANDATORY RECYCLING: A FEW CENTS PER PAIR, A SYSTEM FOR EACH COUNTRY
EU Directive 2025/1892 extends extended producer responsibility (EPR) to footwear: those who sell must pay a contribution to fund the collection and recycling of the products they place on the market. Member States must transpose the directive by 17 June 2027 and implement national systems by 17 April 2028; micro-enterprises have until April 2029. The ‘producer’ is the first party to sell the product in each country, including those selling online from outside the EU.
How much does it cost? France has been applying EPR to footwear for years and is the most established benchmark. In 2026, the Refashion fee ranges from €0.06 to €0.21 per pair, depending on the product’s characteristics. For an importer selling 100,000 pairs a year in France, this amounts to between €6,000 and €21,000.
The figure is modest. The problem lies in the multiplication effect. Each country will have its own system, its own rules and its own deadlines. Anyone distributing to four European markets will have to register four times and submit four periodic declarations. For a high-volume business with tight margins, could the administrative cost exceed the levy? In Italy, the implementing decree is still in draft form at the Ministry of the Environment.
WHAT HAS BEEN POSTPONED: LEATHER IS EXCLUDED FROM THE EUDR, THE DIGITAL PASSPORT IS DELAYED
Not all deadlines have been brought forward. Two, in particular, have been pushed back or scaled back.
Cowhide has been excluded from the Deforestation Regulation (EUDR). The regulation will apply from 30 December 2026 and requires importers of certain raw materials to prove that they do not originate from deforested land, by geolocating the production sites. For leather, this would have meant tracing the product back to the farm (a difficult, if not impossible, task). The Commission excluded it by means of a delegated act dated 13 July 2026. According to UNIC, the scrutiny period by the Parliament and the Council ended on 15 September without any objections. When the exclusion was still a proposal, on 4 May 2026, Manuel Rios, president of the European tanners’ confederation COTANCE, commented as follows: ‘Today, the European Commission has saved over 30,000 jobs in European tanneries and sent a clear signal to the world: the leather industry is not a problem to be eliminated through regulation — it is a solution worth investing in.’
There is still no set date for the digital product passport in the footwear sector. In October 2025, it was expected to be introduced for fashion and footwear between 2027 and 2028. The Commission’s work plan for footwear currently only provides for a study to be completed by the end of 2027. Realistically, the requirements will not come into force before 2030.
The directive on green claims, which was intended to regulate the certification of environmental claims, has also been on hold since June 2025. Environmental communication is therefore governed by Directive 2024/825, transposed into Italian law by Legislative Decree 30 of 2026: no generic claims, no uncertified sustainability labels.
WHAT’S COMING: FORCED LABOUR, MARKETPLACE MONITORING, PFAS
From 14 December 2027, the European regulation on forced labour will come into force. It applies to all operators, regardless of size. If an authority establishes that forced labour has been used in the production of a product, at any stage of the supply chain, it may ban its sale and order its withdrawal. For those sourcing from Asia, this means knowing not only the direct supplier, but also who produces the materials – from cotton to leather to accessories.
Marketplaces are under scrutiny. From 1 July 2026, parcels sent from outside the EU directly to consumers, valued at up to 150 euros, will be subject to a fixed duty of 3 euros per tariff heading. Previously, they were exempt. Meanwhile, the European Footwear Confederation (CEC) has purchased and tested 76 pairs from Shein, Temu and AliExpress: according to the study, published on 13 October 2026, 27 pairs (36 per cent) failed to comply with at least one European chemical requirement. Whilst the sample size is small, the CEC’s call is clear: more effective controls on online sales and direct imports.
On PFAS, the European situation remains unresolved. In France, a ban is already in place. At EU level, a restriction covering the entire family of substances is under consideration: the final opinion of ECHA’s Scientific Committee is expected by the end of 2026, after which it will be up to the Commission to propose the legislation
Key figures
66.5 per cent: the share of China and Vietnam in EU imports of footwear and headwear from non-EU countries, by value (2025, DG Trade based on Eurostat data)
4–9 per cent: the proportion of unsold textiles destroyed each year in Europe (European Commission estimate, February 2026)
€0.06–0.21: fee per pair for footwear recycling in France (Refashion, 2026)
27 out of 76: pairs purchased on Shein, Temu and AliExpress that fail to meet at least one chemical requirement (CEC study, October 2026)
THE BOX STAYS THE SAME, BUT THE DOCUMENTATION GETS LONGER
Let’s go back to the cardboard box. The box itself hasn’t changed. What has changed is what has to accompany it: a declaration of conformity for the packaging, chemical testing, proof for every word printed on the lid and, soon, registration for recycling in every country where it is sold. From 2030, the e-commerce parcel containing it cannot be more than half empty, and any packing material counts as empty space.
For high-volume trade, the question in 2027 is no longer whether to comply, but who will maintain the documentation: the importer, the supplier or an external service provider. Those who can answer and manage that substantial documentation effectively will have an advantage over their competitors.
Material traceability and digital passports are among the recurring themes for start-ups at the Innovation Village Retail, organised by Expo Riva Schuh and Gardabags. During the now traditional Start-up Competition, we will see what solutions technological innovation has in store for the deadlines of 2027 and beyond. The trade fairs return to Riva del Garda from 16 to 19 January 2027.
