4. The Role of System Mapping in Chemical Traceability Implementation

4.1. Aligning Chemical Traceability with EU Sustainability Goals

Following Donella Meadows' definition of a system as an interconnected set of elements that is coherently organized in a way that achieves something as described in the (Meadows, 2009) article, the system maps for textiles and carpets represent two distinct but related visualisations showing how each industry's elements - including their respective chemical traceability systems - are interconnected and organized to achieve chemical traceability, which is why we refer to both "chemical traceability systems" and industry-specific "system maps".

As mentioned previously, chemical traceability in textiles and carpets represents a complex challenge where regulatory requirements, supply chain management, and sustainability goals converge. The textile manufacturing process encompasses multiple stages with distinct chemical inputs: spinning (using auxiliaries and finishing agents), dyeing and printing (requiring textile auxiliaries, dyes, and pigments), and finishing (involving various finishing assistants and technical auxiliaries). Furthermore, many textile companies now specialise in manufacturing products using recycled materials, including plastic. As the European Union introduces new mandates through the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP), the need to track and manage chemicals throughout the value chain becomes increasingly critical. This chapter examines how these requirements intersect with market dynamics and value chain operations to evaluate industry progress toward comprehensive traceability implementation.

The European Union's regulatory landscape will undergo significant changes in 2025-2027, introducing chemical traceability requirements as a key mechanism to enhance transparency and environmental accountability. These regulatory changes align with the EU Green Deal and Sustainable Products Initiative, which support circularity and traceability to achieve sustainability goals (Khan et al., 2021). Core regulations like REACH, CLP (Classification, Labelling and Packaging), and POPs (Persistent Organic Pollutants) establish fundamental requirements for chemical safety and information sharing. These are now being supplemented by the ESPR, which entered into force in July 2024, with specific requirements for textile products expected through delegated acts in early 2026. This regulatory evolution reflects the EU's broader commitment to circularity and environmental protection under the EU Textile Strategy, that defines the ambition and the Green Deal framework. However, implementation faces significant challenges due to the global nature of textile supply chains, where production often occurs in regions with different regulatory standards and enforcement mechanisms.

The complexity of chemical traceability is further amplified by the interaction between different regulatory frameworks and production processes. For both natural fibers like cotton and synthetic materials like polyester, production involves multiple stages where chemicals are introduced - from raw material and recycled material processing through spinning, fabric production, and garment manufacturing. Each stage introduces specific chemical management requirements under various regulations. For instance, while REACH governs general chemical safety, the ESPR and Digital Product Passport will add new layers of traceability requirements. Organisations must therefore develop systems that can track chemicals through complex production and recycling processes while meeting multiple regulatory obligations and adapting to evolving standards.