The EU is moving toward a mandatory textile digital product passport whose content is still being prepared: the preparatory work for its delegated act proposes information including fibre composition, environmental footprint and substances of concern for textile apparel placed on the European market. The legal basis is the Ecodesign for Sustainable Products Regulation, published as ESPR Regulation 2024/1781, which lists textiles and apparel as a priority product category. As of 14 September 2026, the delegated act that will set the exact data requirements for textiles had not been adopted, so some details remain subject to change. This article explains what ESPR already requires, what the preparatory work for the textile delegated act proposes, and what manufacturers should be doing now.
Why Textiles Are a Priority Under ESPR
ESPR Regulation 2024/1781 requires the Commission’s first working plan to prioritise textiles, in particular garments and footwear (Article 18(5)). The Commission’s working plan COM(2025) 187 describes textiles and apparel as having high potential to extend product lifetime, improve material efficiency and reduce impacts on water, waste generation, climate change and energy consumption. The Digital Product Passport (DPP) is the mechanism ESPR uses to make product data available across the supply chain and to consumers.
Under ESPR Article 9(1), a product covered by a delegated act that requires a passport can only be placed on the market or put into service if a digital product passport is available in accordance with that act, and Article 10(1) requires the passport to be connected through a data carrier physically present on the product, its packaging or documentation accompanying the product. For garments, a QR code printed or sewn onto the care label is one possible format; the delegated act will specify one or more data carriers to be used (Article 9(2)(b)). Scanning that code must give access to the product record, which contains the data fields specified in the relevant delegated act.
The DPP framework is designed so that different users see different levels of data. Consumers get publicly accessible information. Authorities, including market surveillance and customs authorities, can be given access to more detailed compliance information, such as technical documentation (ESPR Article 11(b) and Annex III, point (e)). The exact access tiers for textiles will be defined in the delegated act, following the same general structure ESPR establishes for all product categories.
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A May 2026 study for the European Commission’s Joint Research Centre, part of the preparatory study for the textile delegated act, discusses the data points below, and the impact assessment that is to follow the preparatory study has not been published. These are not yet confirmed in law, because the delegated act has not been adopted. The study states that its contents do not necessarily reflect the position or opinion of the European Commission, and that its findings require validation through stakeholder consultation and refinement during the impact assessment phase.
Fibre composition is the most fundamental field. The DPP is expected to require the percentage of each fibre type present in the product, for example 60% cotton, 35% polyester, 5% elastane. This goes beyond the current EU textile labelling rules under Regulation (EU) No 1007/2011, which already require fibre composition on labels, because the DPP will make this data machine-readable and linkable to supply chain records.
Recycled content percentage is a separate field in the JRC proposal, expressed as a percentage of the product’s weight. Under that proposal, a product made from 35% recycled polyester would declare that figure specifically, not just list polyester as a fibre type. This distinction matters for green claims compliance and for buyers calculating Scope 3 emissions.
Country of manufacture is not a settled field. The JRC study does not propose it as passport content, noting that origin, meaning the place of making-up, is under consideration in the revision of the Textile Labelling Regulation. It does propose a unique facility identifier for the place where the product was manufactured, and the Commission’s textile passport page says passport information may include origin information, depending on the final requirements of the delegated act.
Care instructions are expected to be included in machine-readable form, not only as the standard ISO symbols currently printed on labels. The JRC study links care instructions to maintenance under ESPR, and the Commission’s textile passport page says passport information could help downstream operators with repair, reuse and recycling.
Environmental footprint metrics are, in the JRC study, a carbon footprint or environmental footprint performance class, with a calculation method to be proposed under the delegated act based on the Product Environmental Footprint Category Rules; the study does not propose separate water or energy use figures. The study sets the footprint class and the absolute footprint value at product model level. Calculating them requires primary data from suppliers, which is one of the more demanding aspects of DPP compliance for brands that source from multiple factories.
Chemical compliance is partly settled by ESPR itself: a product-group delegated act’s information requirements must make substances of concern trackable throughout the product’s life cycle, unless another delegated act covering the product already does so or an exemption under Article 7(6)(b) applies (Articles 7(2)(a) and 7(5)). Whether the textile passport must also cover REACH restricted substances depends on the delegated act. For textiles, this covers substances such as certain azo dyes, formaldehyde, and heavy metals used in dyes and finishes. Brands will need test reports or supplier declarations to populate these fields accurately.
Repairability information is another aspect a textile delegated act can address: ESPR lists repairability among the product aspects (Article 5(1)(e)), and information requirements can cover how to repair the product (Article 7(2)(b)(ii)). For garments, the JRC study proposes repair instructions and contact details for the brand’s own repair services only as voluntary fields. The Commission’s working plan treats footwear as a separate product category from textiles and provides for a footwear study to be completed by the end of 2027.
When Will Compliance Be Required
The mandatory deadline for textile DPP compliance depends entirely on when the delegated act is adopted and what transition period it grants manufacturers. As of 14 September 2026, the delegated act had not been adopted. The Commission’s working plan COM(2025) 187 gives 2027 as the indicative timeline for adopting textile requirements, and under ESPR Article 4(4) a delegated act cannot apply earlier than 18 months after it enters into force, except in duly justified cases or where it partially repeals or amends a delegated act. The 2027 timeline is indicative, not a confirmed date. Manufacturers should treat it as a planning assumption, not a fixed deadline.
The delegated act will set its own date of application, and the 18-month minimum in Article 4(4) runs from its entry into force, not its adoption: a delegated act under ESPR enters into force only if neither the European Parliament nor the Council objects within two months of notification, a period either can extend by two months (Article 72(6)). The exact terms will be in the delegated act text.
The practical consequence is that brands selling into the EU market have until the act’s date of application to build the data collection and management systems they will need; unless an Article 4(4) exception is used, that date cannot fall before 2028. Waiting until the delegated act is published before starting that work is likely to leave insufficient time, given how long supplier data collection and system integration typically take.
French AGEC Law and the Textile Passport
Manufacturers already subject to France’s AGEC law (Loi Anti-Gaspillage pour une Économie Circulaire) should check whether any data they hold for it can be reused for the textile passport. This article does not analyse what AGEC requires, so check that against the official French text.
Brands that have already built product data pipelines are not starting from zero. Whatever that data covers, some passport elements come from ESPR itself rather than from national law. They include information that makes substances of concern trackable, subject to the exceptions in Articles 7(5) and 7(6)(b), and a data carrier physically present on the product, its packaging or accompanying documentation (Article 10(1)).
This check is useful for planning. Brands can audit their AGEC data against the expected DPP fields now, identify the gaps, and prioritise supplier engagement on the missing data points before the delegated act is finalised.
The Data Carrier Requirement
ESPR Article 10(1) requires the passport to be connected through a data carrier physically present on the product, its packaging or accompanying documentation, and Article 9(2)(b) leaves the choice of carrier to the delegated act. ESPR’s articles and annexes do not require a QR code; its recital 37 names one only as an example of a data carrier, and a QR code on the care label is one possible choice for garments. A QR code would link to the product’s passport, which must meet the essential requirements in ESPR Articles 10 and 11, and the economic operator placing the product on the market must upload its unique identifiers to the digital product passport registry that ESPR Article 13 required the Commission to set up by 19 July 2026, which the Commission announced as live on 20 July 2026.
ESPR sets no durability requirement for the data carrier itself: the delegated act will specify how the carrier is presented and positioned (Article 9(2)(c)), and the passport must stay available for at least the product’s expected lifetime (Article 9(2)(i)). If the delegated act places the carrier on the care label, label durability becomes a practical concern, particularly for garments that are washed frequently. Brands would then need to specify label materials and print standards that keep the carrier readable, and test them against relevant wash and wear cycles.
The passport must also be kept accurate, complete and up to date (ESPR Article 9(1)). If information in the passport changes, for example information on substances of concern, the passport must reflect that. This means the DPP is not a one-time data submission but an ongoing data management obligation.
What Manufacturers Should Do Before the Delegated Act Is Adopted
The delegated act is not yet law, but the JRC’s preparatory work shows which data points are under consideration. Manufacturers can act now without waiting for the final text.
- Map your current product data against the fields proposed so far, including fibre composition by percentage, recycled content, care instructions, a carbon or environmental footprint class, substances of concern and, as voluntary fields, repair information.
- Identify which fields you can populate from existing records and which require new supplier data collection.
- Engage your tier-one and tier-two suppliers on environmental footprint data. The JRC study proposes a carbon or environmental footprint class at product model level rather than separate water and energy figures.
- Review your care label specification in case the delegated act places the data carrier, such as a QR code, on the label, and check how a printed or woven code would survive the product’s expected wash and wear cycles.
- If you have AGEC obligations, audit your existing data pipeline against the expected DPP fields and document the gaps.
- Monitor the Commission’s ESPR working plan and the textile delegated act: the 18-month minimum in ESPR Article 4(4) runs from the act’s entry into force, not its adoption date.
None of these steps require the delegated act to be finalised. All of them reduce the compliance risk and the time pressure you will face once the act is adopted.
If you want to see how Traceable maps your product data to expected DPP fields and manages the supplier data collection process, visit traceable.digital/pricing to start a free trial. The platform is built around the ESPR framework and updates as delegated acts are confirmed.
