Digital Product Passport for Textiles: Status

This article sets out what is known, what is not, and what brands and retailers can sensibly prepare today.

Where textiles stand in the ESPR process

The ESPR is a framework regulation. It creates the passport system but leaves product rules to delegated acts. The first ESPR working plan, adopted in April 2025, lists "textiles/apparel" among the prioritised final products, with adoption indicated for 2027. The Commission's dedicated page for textile apparel narrows this to the fourth quarter of 2027 and marks the timeline as subject to change.

Step	Status on 11 November 2026
ESPR framework	In force since 18 July 2024
Textiles in the working plan	Yes, focus on apparel
Preparatory study by the Joint Research Centre (JRC)	Ongoing, with stakeholder consultation
Delegated act for textile apparel	Not adopted. Indicated for Q4 2027.
Obligation to provide a passport	None yet. Earliest after the transition period.

The same delegated act is expected to set both the ecodesign requirements, for example on durability or recyclability, and the passport requirements. The two belong together: the passport is the channel through which much of the required information is delivered.

Which textile products are likely in scope

The Commission's page speaks of textile apparel and explains the focus: apparel is the largest textile subgroup by consumption in the EU, ahead of home and interior textiles and technical textiles. The exact scope, usually defined by customs codes and product definitions, will only be fixed in the delegated act.

Two points are already clear from the working plan:

Footwear is not part of the first working plan. A study is to assess its potential under the ESPR by the end of 2027.
Home textiles and technical textiles are not named as a priority group in the first plan.

If you sell mixed assortments, for example apparel, shoes and accessories, expect the passport to arrive for part of the range first.

What data a textile passport is expected to contain

No field list is final. The Commission's textile page says the final content depends on the delegated act and names the kinds of information the passport may include:

product identification and characteristics
fibre composition, where relevant, in line with the Textile Labelling Regulation
information on use, repair and maintenance
information for reuse, resale, disassembly, refurbishment, disposal and recycling
origin information
identification of the relevant economic operators

The ESPR itself gives further hints. Annex I lists the product aspects on which requirements can be set, including durability, reparability, recycled content, substances of concern and the environmental and carbon footprint. Article 7 requires that information requirements enable the tracking of substances of concern. Which of these become mandatory fields for apparel, and at which level of detail, is exactly what the delegated act will decide.

Treat any list you see today, including the one in our DPP data checklist builder, as a preparation aid and not as the legal requirement. For the general logic of passport data, read what data goes into a DPP.

Model, batch or item: an open question that matters

The ESPR lets each delegated act decide whether the passport refers to the model, the batch or the individual item. For apparel this choice has large practical consequences:

Model level means one passport per style or style-colour, close to how product data is managed today.
Batch level ties the passport to a production lot, which requires lot information to reach the label.
Item level means a unique identifier per garment, which affects labelling, printing and IT systems far more.

The level is not decided. When a draft delegated act is published for feedback, this is one of the first things to look for.

The data carrier on a garment

The passport must be reachable through a data carrier that is physically present on the product, its packaging or the accompanying documentation; the delegated act will say where. The Commission's textile page expects the passport to be accessible at online points of sale and through a data carrier on the product, such as a QR code.

For garments, practical questions follow: care label, hangtag or woven label; durability of the print over the product's life; and how the code relates to existing barcodes. Our comparison of QR code, NFC and RFID as DPP data carriers covers the options.

Rules that already apply to textiles today

While the passport is still ahead, two ESPR rules on unsold consumer products already apply and are often mixed up with it.

Destruction ban. Since 19 July 2026, large companies may not destroy unsold apparel, clothing accessories and footwear listed in Annex VII of the ESPR. Medium-sized companies follow on 19 July 2030. Micro and small enterprises are exempt. Delegated Regulation (EU) 2026/296 sets out the cases in which destruction remains permitted, for example for dangerous or non-compliant products.

Disclosure. Companies that discard unsold consumer products must publish information about quantities, reasons and treatment each year. Micro and small enterprises are exempt; medium-sized companies are covered from 19 July 2030.

Separately, national rules may already require product-level environmental information. France is one example: its anti-waste law (AGEC) requires a product sheet on environmental qualities and characteristics for many consumer products. Such national schemes are not the EU passport, but the data collected for them is a useful starting point.

What brands and retailers can prepare now

The honest position is that you cannot build a compliant textile passport yet, because the requirements do not exist. What you can do is remove the known bottlenecks.

Clean product master data. Make sure each style has a stable identifier, such as a GTIN, and that fibre composition is stored in structured form, not only on an image of the care label.
Know your suppliers. Origin and operator information is on the Commission's list. Record which facility performs which production step, at least for the main stages.
Collect care, repair and end-of-life information. Much of it exists in scattered form. Bring it into one place per style.
Check substances. Find out what you know about substances of concern in your materials and where the gaps are.
Clarify roles. If you sell under your own brand, you are the manufacturer in the legal sense. If you import other brands from outside the EU, you are the importer. See ESPR for SMEs.
Follow the JRC study and the draft act. The preparatory study documents show which options are being weighed.

None of these steps is wasted if dates move, because they improve data you need anyway for customers, marketplaces and existing labelling law.

What not to do yet

Do not print passport QR codes on permanent labels based on assumptions about the required format.
Do not buy into a data model that cannot be changed once the delegated act is published.
Do not present a voluntary product page as an "EU Digital Product Passport". Until the act applies, there is no such thing for apparel.

Checklist for textile companies

You know which of your products are apparel and which are footwear, home textiles or accessories.
Each style has a unique identifier and structured fibre composition data.
You can name the main production facilities per style.
Care, repair and end-of-life information is stored in one place.
You know whether the unsold-goods rules apply to your company size.
Someone follows the Commission's textile page and the "Have your say" portal.
Your planning assumes "adoption plus at least 18 months" and is updated when the draft act appears.

Sources

This article is general information, not legal advice. Status checked on 11 November 2026.

FAQ

When does the Digital Product Passport for textiles start?

There is no fixed date yet. The Commission indicates the fourth quarter of 2027 for adopting the ESPR delegated act for textile apparel. After adoption, a transition period of at least 18 months applies, so an obligation before 2029 is unlikely.

Which textile products will need a passport?

The first ESPR working plan prioritises textiles with a focus on apparel. The exact product scope will be defined in the delegated act. Footwear is not included in the first working plan; a study is to assess it by the end of 2027.

Do small fashion brands have to comply?

Passport duties under the ESPR follow the product and the role, not company size. A small brand that places apparel on the EU market under its own name is the manufacturer in the legal sense. Whether the delegated act contains relief for small companies is not yet known.

Is the ban on destroying unsold clothing part of the DPP?

No. It is a separate ESPR obligation. It has applied to large companies since 19 July 2026 and will apply to medium-sized companies from 19 July 2030. Micro and small enterprises are exempt.