Regulatory guide
The Digital Product Passport (DPP) for textiles is the EU regulatory infrastructure that will require structured, machine-readable data on textile products placed on the EU market: composition, substances of concern, environmental indicators, traceability, and repair history.1 The textile delegated act under the ESPR is expected in 2027, with mandatory implementation following a transition period of around 18 months.2
The textile delegated act under the ESPR is still being prepared. The European Commission adopted the Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 in April 2025, identifying textiles (with a focus on apparel) as a priority category.2 Adoption of the textile delegated act is expected in 2027, with mandatory implementation following a transition period of around 18 months.
This guide reflects the state of the proposal as of mid-2026 and will be revised as the act is finalised.
The Digital Product Passport (DPP) is a structured, machine-readable record of a product's environmental, material, and traceability information, accessible to consumers, retailers, regulators, and recyclers through a digital carrier on or with the product. The DPP is a horizontal instrument of the ESPR: Chapter III of Regulation (EU) 2024/1781 (Articles 9 to 15), together with Annex III, establishes the general framework, and each product category is brought into scope through its own delegated act adopted under Article 4, which defines the specific data fields and access rules.1
For textiles, the DPP is intended to support several Union-level objectives: substantiating environmental claims, enabling reuse and recycling markets, supporting the Article 25 destruction ban by documenting the disposition history, and providing the data infrastructure for the broader circular economy programme.
The DPP is not a standalone regulation; it sits on top of the existing ESPR framework. Chapter III of the ESPR establishes the general DPP requirements (data content, carrier, access rights, registry, and back-up); each product-specific delegated act fills in the detail for that category.1 The textile delegated act will define what apparel and footwear must carry, in what format, at what level (model, batch, or item), and accessible to whom.
The legislative path for the textile DPP runs through several instruments. Regulation (EU) 2024/1781 (the ESPR) provides the legal basis: Chapter III (Articles 9 to 15) and Annex III establish the general DPP framework, and the product categories that must carry a DPP are brought into scope through delegated acts adopted under Article 4, informed by the Working Plan.1 Annex VII of the ESPR is a separate list: it sets the scope of the Article 25 destruction ban (apparel, clothing accessories, and footwear), not the scope of the DPP.
The Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, adopted by the European Commission in April 2025, identifies textiles as a priority category and sets out the indicative timeline for the textile-specific delegated act.2 The Working Plan is the Commission's roadmap, not a binding act; it signals intent and informs industry preparation.
The textile delegated act itself is in preparation by the Commission, in consultation with the Ecodesign Forum, member state competent authorities, and industry stakeholders including European apparel associations and recycling operators.3 Adoption is expected in 2027. After adoption, the act enters into force 20 days after publication in the Official Journal, with a transition period before mandatory implementation.
The earliest realistic date for mandatory textile DPP compliance is 2028, and it could fall later.
Two important caveats apply to this timeline. First, the roughly 18-month transition is a working assumption based on comparable delegated acts; the textile act may set a different period.
Second, the act may be phased, with different effective dates for different product sub-categories depending on supply chain readiness. Brands should plan for 2028 implementation at the earliest, with the understanding that the date may move.
The textile DPP is expected to carry five categories of data per product. The exact field list is being negotiated and will be locked in the final delegated act; the categories below are the working assumption based on the Working Plan, the ESPR Chapter III and Annex III framework, and the data fields already established for other ESPR categories.12
The percentage breakdown of fibres in the product (cotton, polyester, elastane, wool, blends), with attention to recycled content and bio-based content. This data already exists for most brands in their PIM systems for textile labelling; the DPP will require a structured, machine-readable format rather than narrative text.
The ESPR defines a 'substance of concern' in Article 2(27): substances of very high concern under REACH, substances with certain hazard classifications under the CLP Regulation, substances restricted under the POPs Regulation (which implements the Stockholm Convention), and substances that negatively affect the reuse or recycling of the product.1 The exact reportable list for textiles will be defined in the delegated act; documentation flows from the supply chain through declarations of conformity to the DPP.
Environmental performance indicators such as the carbon footprint and water footprint of the product, calculated to a defined methodology. The Product Environmental Footprint (PEF) method, set out in Commission Recommendation (EU) 2021/2279, is the working assumption for the calculation framework.4 The precise indicators, calculation methodology, and verification requirements will be set in the textile delegated act.
The supply chain stages with country of origin: weaving or knitting, dyeing or printing, confection. This data overlaps with the existing AGEC Article 13 disclosure and EU textile labelling rules; the DPP will require a structured format rather than free text.
The most novel data category for textiles. It includes care instructions, repair and rework events, refurbishment events, and disposition status if applicable. For brands with mature rework operations, the data feeding this field comes from the operational record of the rework workflow. For brands without a rework workflow, the field will be largely empty for new units and populated only when the product enters a repair or rework process.
The DPP carrier is the physical or digital mechanism by which a consumer, retailer, or regulator can access the structured data. ESPR Article 9 requires the DPP to be accessible through a data carrier and allows for different carrier types, with the data carrier on the product itself where possible; the textile delegated act will specify the acceptable options for apparel and footwear.1 Three carrier options are most likely to be permitted.
A 2D barcode printed on the care label, hangtag, or packaging. Scanned with a standard smartphone camera. The QR code resolves to a URL where the DPP data is served. QR is the cheapest carrier to deploy and works with existing brand infrastructure; the trade-off is durability (printed labels degrade over wash cycles).
A short-range wireless tag embedded in the garment or hangtag. Read with an NFC-enabled smartphone. NFC is more durable than printed QR for in-garment placement and supports more sophisticated interactions (the chip can carry minimal data locally and resolve to fuller data online). Cost per unit is higher; the technology is more mature in luxury and footwear than in mass-market apparel.
Used widely in apparel logistics already, but the DPP context likely favours NFC over RFID at the consumer level because NFC is readable by consumer devices. RFID may have a role at the supply chain and retail level rather than at consumer access.
The brand's choice of carrier will depend on price tier, in-garment placement options, durability requirements, and existing labelling infrastructure. Many brands are expected to deploy QR codes initially with NFC migration over time.
The DPP data does not live solely with the brand. Under Article 13 of the ESPR, the European Commission must establish a central digital registry, required to be operational by 19 July 2026.1 Each DPP must be registered in it.
The brand publishes the DPP data to a server it controls or a service it contracts; the carrier (QR or NFC) resolves to the brand's data; the registry holds, at a minimum, the unique registration identifier of the product, providing the persistent reference even if the brand changes hosting providers. Customs authorities use the registry to verify products at the EU border.
The registry is established under Article 13; its operational details, including the format of the unique registration identifier, will be set by an implementing act under Article 13(5).1 The registry should not be confused with DPP service providers: those are the independent third-party operators that host DPP data and the mandatory back-up copy under Article 11. The Commission has run a separate call for evidence on the rules for DPP service providers.3 The registry holds identifiers and references; the DPP data itself lives with the brand or its service provider.
For brands, the practical implications are: the unique identifier must follow recognised standards (the GS1 Digital Link standard is widely expected to be central to textile DPP implementation); the data must be persistently hostable and updatable for the period set in the delegated act, including after insolvency, liquidation, or cessation of activity; and the registry will be the regulator's index for compliance checks. Brands that lose their DPP hosting infrastructure or fail to maintain it will be discoverable through the registry, and the Article 11 back-up obligation exists precisely to keep the data available if a provider fails.
The textile DPP will not replace existing disclosure obligations; it will augment them. Three regimes coexist with the future DPP.
| Existing regime | What it covers | Relationship to DPP |
|---|---|---|
| ESPR Article 24 disclosure | Annual brand-level disclosure of unsold product destruction; the standardised Annex I format under Commission Implementing Regulation (EU) 2026/2 applies to products discarded in financial years starting on or after 2 March 20276 | Shares underlying operational data; Article 24 reports brand-level aggregates, the DPP reports product-level data |
| AGEC Article 13 (France) | Product-level environmental disclosure with QR-code access, in force in France under Decree 2022-7485 | The DPP is broader in scope and depth; AGEC remains in force, with the two regimes overlapping heavily and expected to converge over time |
| REACH and textile labelling | Substance-of-concern and material-composition data (in force) | The DPP will reference these data rather than duplicate them |
The pattern across all three regimes is consistent: unit-level traceability of products from manufacture through disposition is becoming the default. The DPP is the data-aggregation layer that pulls existing obligations into a single accessible record.
Brands that build the operational data layer for Article 24 will have most of what the DPP requires for traceability and repair history.
Brands cannot implement the DPP before the delegated act is final, but they can build the data infrastructure the DPP will require. The work is largely the same work as preparing for ESPR Article 24 and complying with AGEC Article 13; the DPP layers on top.
Product data needs to be in a structured, machine-readable format at the unit or SKU level. Material composition, country of origin per manufacturing stage, care instructions, and substance-of-concern attestations should live in the PIM with structured fields, not free text. Brands with mature PIMs are largely there; brands relying on spreadsheets and product datasheets will need to consolidate.
Repair and maintenance history is the most novel DPP data category. It requires unit-level identification at intake, time-stamped status changes through the rework workflow, and structured disposition records. This is the same operational layer that produces Article 24 disclosure; the rework lifecycle data flows back into the product record to populate the DPP's repair history field.
The DPP data must be hosted persistently with a stable URL and an API for the central registry to resolve. ESPR Article 11 also requires a back-up copy of the DPP to be held by an independent third-party DPP service provider, so a purely in-house hosting model is not sufficient on its own.1 Several service vendors are building DPP-specific products, and PIM and PLM vendors are adding DPP modules; brands should pilot with a small product line before committing to a strategic vendor.
The European Commission has signalled openness to industry pilots ahead of mandatory implementation. A brand piloting a DPP on a limited product line in 2026 or 2027 will be substantially further forward than a brand starting at mandatory implementation.
Flexireo was co-developed over two years with a multinational sporting goods brand, processing more than 50,000 products through the platform. The operational data captured for rework coordination feeds directly into the DPP's repair and maintenance history field.
Every rework, refurbishment, and repair event is captured with unit-level identifier, timestamp, operator, and supporting evidence. The same data that produces the ESPR Article 24 disclosure populates the DPP's repair history.
For brands integrating Flexireo with a PIM or DPP service partner, the rework lifecycle data flows back into the product record as the DPP is built.
Flexireo does not produce the full DPP. The platform's role is the operational layer for rework and disposition data; the PIM and DPP service handle the other DPP fields (composition, substances, environmental indicators, traceability of original manufacture).
The DPP for textiles will be a multi-system data aggregation; Flexireo provides one of the inputs.
For brands running a DPP pilot before mandatory implementation, a first Flexireo pilot project can be implemented in one week and starts producing the repair history data immediately. Pilot pricing: €1,250 flat for up to 2 months and 30,000 units, with a full money-back guarantee.
Book a 30-minute demo and we will show you how the operational data layer for rework, which Flexireo provides today, feeds the DPP's repair and maintenance history when mandatory implementation arrives. The platform that runs your rework today is the platform that produces the DPP data tomorrow.
Primary sources cited inline above. Links open in a new tab.
Disclaimer. This page is for general informational purposes only and does not constitute legal advice. The textile delegated act under the ESPR is in preparation; data fields, carriers, registry specifications, and timelines described on this page are working assumptions and may differ from the final delegated act.
Readers should consult the primary sources linked above and seek qualified legal advice before relying on any statement on this page. Page published 13 May 2026; last reviewed 13 May 2026.