If you sell apparel, footwear or home textiles in the EU, each product will need a Digital Product Passport for textiles. Textiles are the first product group in the Ecodesign for Sustainable Products Regulation working plan, so the textile delegated act sets the pattern every other sector will follow.
This guide covers what that passport must contain, when it applies, and where the data behind it comes from. It is written for the product, sustainability and IT people who will have to produce one for every style, not for the lawyers who will read the act.
Key takeaways
The ESPR working plan of April 2025 names textiles and apparel as a priority group. The delegated act is expected in 2027, with passports required for products placed on the market from a date the act will set, typically 18 months later.
Every style needs a Digital Product Passport with a unique identifier, a data carrier on the product, and a fixed set of data fields. The fields are the same for every brand. Only the values differ.
Fibre composition, dye and finishing chemistry, country of each production step and the certificates behind sustainability claims live in your supply chain. Not in your PLM. Collecting them is the work.
Since 19 July 2026 large companies may not destroy unsold apparel and footwear. Medium-sized companies follow in 2030. This part of ESPR does not wait for the delegated act.
The identifier, the data carrier and the supplier data pipeline are the same whatever the final field list says. Brands that build them now spend 2027 filling fields. Not building systems.
ESPR textiles: which products are covered
The working plan groups textiles and apparel together. The Commission's preparatory study covers clothing, footwear, household textiles such as bed linen and towels, and the textile components of accessories. Technical textiles and workwear are inside the scope of the study; carpets and mattresses are handled as separate product groups.
Scope follows the product, not the seller. A brand headquartered outside the EU that places textiles on the EU market carries the same passport duty as an EU brand. Marketplaces and importers become responsible when no EU manufacturer exists.
| Product group | Covered by the textile act | Note |
|---|---|---|
| Clothing and apparel | Yes | Lead category in the preparatory study |
| Footwear | Yes | Natural-rubber soles also fall under EUDR; leather left its scope in July 2026 |
| Home textiles | Yes | Bed linen, towels, curtains |
| Bags and textile accessories | Partly | Textile components in scope; leather goods pending |
| Carpets, mattresses | Separate acts | Named in the working plan on their own |
| Second-hand textiles | No | Passports follow the first placing on the market |
When the textile passport applies
Three dates matter: when ESPR entered into force, when the textile delegated act is adopted, and when products must carry a passport. Only the first is fixed today.
ESPR enters into force
Regulation (EU) 2024/1781 establishes the Digital Product Passport and empowers the Commission to set product-group rules through delegated acts.
Working plan names textiles first
The first ESPR working plan lists textiles and apparel, furniture, tyres, mattresses, iron, steel and aluminium as the priority groups for 2025 to 2030.
Destruction ban for unsold apparel and footwear
Large companies may no longer destroy unsold clothing, accessories and footwear. This applies without a delegated act.
ESPR delegated act for textiles adopted
The act fixes the data fields, the performance requirements and the application date for textile passports.
Passports required on new products
From the application date, textiles placed on the EU market must carry a valid passport registered in the EU DPP registry.
Treat 2027 as a planning date, not a legal one. When the act is adopted we update this page and the ESPR guide the same week.
What the ESPR Digital Product Passport must contain
ESPR Article 9 and Annex III define what any Digital Product Passport carries; the textile act picks which items are mandatory for textiles and adds sector-specific ones. The list below is what the preparatory study and the working plan point to. Fields marked "expected" are not final.
Data fields
| Field | What it holds | Status |
|---|---|---|
| Unique product identifier | A GS1 GTIN or equivalent, one per model, plus batch or item level where the act asks for it | Required by ESPR |
| Manufacturer and importer | Legal name, address, and the EU operator responsible for the product | Required by ESPR |
| Fibre composition | Fibre names and percentages per component, aligned with the Textile Labelling Regulation | Expected |
| Substances of concern | Presence of substances on the ESPR list above threshold, per component | Required by ESPR |
| Recycled content | Share of recycled fibre and the standard used to verify it | Expected |
| Durability | Test results for the durability parameters the act selects, such as pilling, colour fastness and seam strength | Expected |
| Repairability and care | Repair information, spare parts where relevant, and care instructions | Expected |
| Country of production steps | Where spinning, weaving or knitting, dyeing and finishing, and assembly took place | Expected |
| End-of-life information | How to sort, recycle or return the product; links to take-back schemes | Expected |
| Compliance documents | Declaration of conformity, certificates behind any environmental claim | Required by ESPR |
Two design decisions in ESPR shape all of this. First, the passport has access levels: consumers see care and composition, customs and market surveillance see the compliance documents, recyclers see disassembly data. Second, the data must be machine-readable and interoperable, which is why the identifier and the data carrier are standardised rather than left to each brand.
Data carrier and access
Every product carries a data carrier that resolves to its passport: a QR code, an NFC tag or an RFID label. For textiles the carrier sits on the care label or a hang tag, and must survive the product's use phase, which is why printed QR on the care label is the default and NFC is used where the label would not last.
The carrier encodes a GS1 Digital Link: one URL that points to the passport and can route different audiences to different views. The identifier behind it is registered in the EU DPP registry, which customs will check at the border once the act applies.
Where the data comes from
Most brands find that about a third of the passport can be filled from systems they already run, and two thirds has to come from suppliers. The split looks like this.
| Data | Usually lives in | How it reaches the passport |
|---|---|---|
| Identifier, model, brand, manufacturer | ERP or PIM | Synced once per style |
| Fibre composition, care | PLM, tech pack | Synced, then confirmed by the mill |
| Dye and finishing chemistry, substances | Dye house, finisher | Supplier declares per order, certificate attached |
| Country of each production step | Tier 1 to tier 3 suppliers | Supplier answers per purchase order |
| Recycled content, organic and other claims | Certificate bodies via the supplier | Transaction certificate read and linked |
| Durability test results | Test lab | Report attached per style |
The supplier rows are where programmes stall. Emailing a spreadsheet to sixty mills and dye houses produces sixty formats and a season of chasing. The operation that works is the reverse: the supplier receives a link for the styles they make, sees the fields pre-filled from your purchase order, and answers in their own language. That is what Trace does inside Tappr, and it is the same pipeline EUDR and AGEC need, so it is built once.
For the data you already hold, the question is structure rather than collection. Brand Cloud reads articles from your ERP or PLM, maps them to the passport fields and flags what is missing per style, so the gap list exists before the delegated act does.
Unsold textiles and the destruction ban
ESPR Article 25 bans the destruction of unsold consumer products, and the annex names apparel, clothing accessories and footwear first. Large companies have been covered since 19 July 2026; medium-sized companies follow on 19 July 2030. Small and micro companies are exempt.
Two duties come with it. Companies must disclose, once a year, the number and weight of unsold products they discard and why. And "destruction" is read widely: it covers incineration and landfill, and the exemptions for safety, damage and counterfeit goods have to be documented per product.
In practice the ban turns unsold stock into a data question. If every item already carries an identifier and a passport, the disclosure report is a query rather than a stock count, and the exemption evidence sits with the product record.
How it fits with AGEC, PPWR and labelling
The textile passport does not arrive alone. Three other rules ask for overlapping data, and the passport is the place to hold it once.
- Loi AGEC already requires French sellers to publish origin of the main production steps, recycled content and the presence of hazardous substances for textiles. The same fields appear in the passport list above, so AGEC data collected now is passport data.
- PPWR governs the packaging around the product from 12 August 2026: recyclability, recycled content and labelling of polybags, boxes and hangers. It is separate from the product passport but usually collected from the same suppliers.
- The Textile Labelling Regulation revision is expected to allow digital labels. When it does, the fibre composition on the passport and on the label become one dataset.
- The Empowering Consumers Directive bans unproven green claims from 27 September 2026. The certificates linked in the passport are the proof it asks for.
What to prepare this season
The delegated act will fix the field list; it will not change the plumbing. These five steps are the same whatever the final text says.
- Give every style a GS1 identifier. If you already print EAN barcodes you have GTINs; the passport reuses them.
- Map your current product data to the field list above. Note per field whether it lives in your systems or with a supplier. The gap list is your project plan.
- Start supplier collection with one product group. Studio Anneloes started with one workwear line and reached most of the collection within a year; the first group teaches the process.
- Decide the data carrier. Printed QR on the care label for most apparel; NFC where the label does not survive the product. Generate the code inside the label workflow you already run.
- Publish a passport for one style now. A live passport with composition, origin and care is already useful to customers, and it proves the pipeline end to end. See what one looks like on the apparel page.