The Ecodesign for Sustainable Products Regulation (Regulation (EU) 2024/1781, “ESPR”) entered into force in July 2024, but the specific product rules — including any Digital Product Passport (DPP) obligations — will flow from delegated acts adopted product group by product group. For textiles and apparel, the preparatory work is well under way, but a draft delegated act has not yet been published.
Where textiles sit in the ESPR Working Plan
On 16 April 2025 the European Commission adopted the first ESPR Working Plan 2025–2030 (COM(2025) 187 final). The Working Plan identifies the priority product groups for which delegated acts will be prepared in the first cycle. Textiles and apparel are on that list, alongside furniture, mattresses, tyres, iron and steel, and aluminium. The Working Plan’s timelines are explicitly indicative — they signal Commission intent, not legally binding deadlines.
For textiles, the Working Plan flags an indicative adoption window in 2027. That date is conditional on the preparatory work, the impact assessment, the Ecodesign Forum process, and the inter-service consultation all completing on schedule.
The JRC preparatory study and its third milestone
The technical foundation for the textile delegated act is being built by the Joint Research Centre (JRC) through a multi-milestone preparatory study. On 12 December 2025 the JRC published the third milestone of that study, covering scope, market analysis, user behaviour, the current EU Ecolabel and Green Public Procurement criteria, product technologies, environmental and economic analysis of textiles placed on the EU market, and a first set of design options.
Registered stakeholders attended an online consultation hosted by the JRC on 14 and 15 January 2026, and written contributions to the third-milestone working document were accepted until 30 March 2026. That consultation window has now closed; the study team is processing the input ahead of the next milestone. It is worth being precise about what this was: a preparatory-study consultation run by the JRC — not a Commission consultation on a draft delegated act, because no draft delegated act exists yet.
What the delegated act is expected to cover
Under Article 4 of ESPR, delegated acts set ecodesign requirements for the relevant product group. Under Article 9, those acts may impose Digital Product Passport requirements: which information must be in the DPP, who must populate it, who may access which fields, and which technical standards apply to data carriers and interoperability. The textiles act is widely expected to include a DPP requirement, but the exact data set, access roles, and timing will only be known when the Commission publishes the draft.
What operators can do now, honestly
- Read the third milestone. The JRC working document and its summary set out the Commission’s current technical thinking on scope and design options.
- Watch for the consultation outcomes and the next milestone — the processed stakeholder input will shape the design options that reach the draft act.
- Map your existing master data — composition, country of last substantial transformation, recycled content, durability evidence — against the categories the JRC is examining, so you are not starting from zero when the draft act lands.
- Do not assume a specific DPP schema, field count, or compliance date yet. Anything claiming otherwise is extrapolating beyond the published documents.
How Traceable is positioned
Traceable’s DPP platform is built to be regulation-agnostic. The same underlying data model that supports the EU Battery Regulation (Regulation (EU) 2023/1542) is configurable for new product categories as their delegated acts are adopted. When the textiles delegated act is published in draft, we will publish a mapping note against the platform’s existing schema and identify any new fields required for compliance.
Primary sources: ESPR Working Plan COM(2025) 187 final, 16 April 2025 (EUR-Lex); JRC Preparatory Study on Textiles, 3rd Milestone (JRC Product Bureau); Regulation (EU) 2024/1781 (EUR-Lex).
