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TEXTILES & APPAREL · ESPR PRIORITY PRODUCT GROUP

Digital Product Passports for Textiles & Apparel

Textiles and apparel are a priority under ESPR. The Commission currently targets Q4 2027 for adoption of a textiles delegated act, not for company compliance. Final product scope, passport information and application timing are still to be defined.

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Current position

Regulatory status at a glance

ESPR sets the framework; the future textiles delegated act will determine product-specific obligations.

Priority

ESPR priority product group

The 2025–2030 Working Plan prioritises textiles and apparel for product-specific ecodesign work.

Process

Technical preparation underway

The JRC preparatory study and May 2026 textile DPP-content study inform possible requirements; neither is final law.

Indicative timing

Q4 2027 adoption target

The Commission textile-specific DPP page gives Q4 2027 as the indicative target for delegated-act adoption. This is not a company compliance deadline.

Uncertainty

Requirements are not final

Final scope, dataset, passport granularity, access rights, product-specific ecodesign rules and application date remain open.

Potential scope

Who may be affected

Apparel and garments are central to current textile preparatory work; the final coverage of other textiles and operator duties will come from the delegated act. Although ESPR mentions footwear alongside garments, the 2025–2030 Working Plan considers footwear separately and does not include it in the first plan. Q4 2027 is an indicative textiles/apparel delegated-act adoption target, not a footwear timetable.

Economic operators

  • Textile and apparel manufacturers and brands
  • Importers of potentially covered products
  • Private-label and retail operators placing covered products on the EU market
  • Suppliers providing fibre, material, chemical and production evidence

Textile product areas discussed in the current work (not final legal scope):

  • Apparel and garments
  • Other textiles (final coverage pending)

Regulatory sequence

Textiles & apparel DPP timeline

Adoption of a delegated act and the date companies must apply its rules are separate events.

  1. 2024

    ESPR establishes the framework

    Regulation (EU) 2024/1781 establishes the framework for product-specific ecodesign requirements and Digital Product Passports.

  2. April 2025

    Textiles and apparel prioritised

    The 2025–2030 Working Plan identifies textiles and apparel as a priority product group.

  3. 2025–2026

    JRC preparatory work and DPP-content study

    Preparatory research, including the May 2026 textile DPP-content study, informs options but is not final law.

  4. Q4 2027Indicative

    Textiles/apparel delegated act planned

    The Commission textile-specific DPP page gives Q4 2027 as an indicative target for textiles/apparel delegated-act adoption, not a company compliance deadline.

  5. Application dateNot yet defined

    Compliance start depends on final delegated act

    No company application date has been defined; any transition and application timing will depend on the adopted act.

Confirmed framework

What is already known about the DPP framework?

ESPR establishes the DPP framework where a product-specific delegated act requires a passport. Textile-specific requirements have not been finalised.

  • Unique product identity

    Each passport links to a persistent unique product identifier. The identifier level for covered textiles will depend on the delegated act.

  • Physical data carrier

    The passport is accessed through a physical data carrier; its placement for covered textiles remains to be specified.

  • Interoperable data

    DPP data uses open standards and interoperable formats and, where appropriate, is machine-readable, structured, searchable and transferable.

  • Reliable information

    Passport information must be accurate, complete and kept up to date.

  • Product-specific rules

    Any textile-specific performance and information requirements, including DPP data fields, will be set by the delegated act.

Pending delegated act

What is still to be defined for textiles and apparel?

Preparatory studies are not binding requirements. The delegated act must settle the product-specific details.

  • Product scope

    Final covered apparel and other textile products, boundaries and exclusions remain pending; this is not the final legal scope.

  • Required DPP data

    The final mandatory dataset has not been defined.

  • Passport granularity

    Whether information is required at model, batch or individual-item level.

  • Data-carrier placement

    Whether the carrier appears on the product, packaging or accompanying documents.

  • Access rights

    Which information will be public or limited to defined actors.

  • Not yet defined

    Application date

    The compliance start and any transition arrangements depend on the final act.

  • Ecodesign requirements

    The final textile-specific performance and information rules.

Provisional only

Possible data categories to prepare for

The final DPP dataset is not yet defined. These are provisional evidence and data-readiness areas drawn from the framework and preparatory work, not final mandatory fields:

  1. 01Product identification and classification
  2. 02Fibre and material composition
  3. 03Manufacturing and supplier information where required
  4. 04Substances and chemical information
  5. 05Durability, repairability and care information
  6. 06Recycled content, circularity and end-of-life
  7. 07Sustainability and environmental information
  8. 08Compliance and traceability evidence

Readiness pathway

Five steps to start now

Prepare trustworthy product and supplier data without assuming that proposed fields will become mandatory.

  1. Map product families and SKUs

    Document garment and textile product hierarchy and variants, while keeping future legal scope open.

  2. Build reliable material BOMs

    Connect fibre and material composition records to the right products and versions.

  3. Identify supplier evidence dependencies

    Trace where fibre, material, chemical and production evidence originates and where gaps remain.

  4. Assign ownership for updates

    Set owners for claims, certificates, source records and product-data changes.

  5. Normalize identifiers and structured data

    Prepare identifiers, evidence links and update workflows for possible DPP publication.

Ease your transition with Circlepass

Want help working through this list? We can support your team step by step.

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How Circlepass helps

Make textile product information workable

Circlepass helps teams connect product and material records, supplier inputs, evidence, ownership and controlled updates for DPP readiness. This is not a certification, legal conclusion or compliance guarantee.

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Textiles and apparel DPP questions

Is a textile Digital Product Passport already mandatory?

No textile-specific DPP obligation is final at the review date. ESPR establishes the framework, but a future delegated act must set the product-specific rules and timing.

Is Q4 2027 the deadline for companies?

No. Q4 2027 is the Commission’s indicative delegated-act adoption target, not a company compliance or application deadline. The application date is not yet defined.

Which textile and apparel products will be covered?

The final scope is not settled. Garments are central to current textile work; the delegated act will determine other covered textiles. Although ESPR mentions footwear alongside garments, the Working Plan considers footwear separately and does not include it in the first plan. Q4 2027 is an indicative textiles/apparel delegated-act adoption target, not a footwear timetable.

Will imported and private-label products be affected?

Potentially. Rules may apply to covered products placed on the EU market, including imported and private-label products. Specific duties depend on the adopted act and each operator’s role.

What data is likely to be needed?

The final dataset is not available. Provisional preparation areas include identity, fibre and material composition, supplier and chemical evidence, care and durability, circularity, sustainability and traceability. Study proposals are not mandatory fields.

What should brands and manufacturers do now?

Map product families and SKUs, build material BOMs, identify supplier evidence dependencies, assign data and claim ownership, and prepare structured identifiers and update processes without assuming final requirements.

Official EU sources

Regulatory references last checked on 24 September 2026

  1. 01Ecodesign for Sustainable Products Regulation (EU) 2024/1781
  2. 02ESPR and Energy Labelling Working Plan 2025–2030
  3. 03European Commission: Digital Product Passport for textile apparel
  4. 04JRC Product Bureau: Textile Products preparatory-study documents
  5. 05European Commission: Digital Product Passport overview
  6. 06European Commission: DPP Registry
  7. 07European Commission: Guidance for economic operators