The Textile Digital Product Passport

ESPR (EU 2024/1781), which came into force on 18 July 2024, is the EU's umbrella framework for product sustainability requirements and Digital Product Passports. Rather than setting rules for every product category in one go, ESPR operates through delegated acts — category-specific secondary legislation that the Commission adopts after technical preparatory work.

Textiles (apparel and footwear) are named in the ESPR Working Plan 2025–2030 as a priority group, sitting alongside iron & steel, tyres, aluminium, furniture, and mattresses. Being a priority group means the Commission has committed to developing a delegated act for textiles within the plan period — not that the rules are already in place.

The textile industry was chosen as a priority because of its substantial environmental footprint: high water and chemical use, complex global supply chains, fast fashion's disposal rates, and microplastic shedding during washing. The textile DPP is designed to make that footprint transparent, traceable, and actionable at the point of sale.

The key point: batteries are first, not textiles. The battery DPP is the first mandatory DPP under ESPR. Textiles follow later. Here is the current picture:

Dates marked "expected" or "indicative" are based on the Commission's working plan and publicly available preparatory work — not adopted law. Verify against official EU sources as requirements are finalised.

The precise data fields for the textile DPP will be set in the delegated act — they are not finalised law. The following fields are expected based on ESPR's general framework and the Commission's preparatory and technical work. Treat this as planning guidance, not a compliance checklist.

Collecting this data requires supplier transparency that many brands have not yet formalised. The supply chain data challenge — mapping Tier 2 and Tier 3 suppliers for raw materials and processing — is likely to be the hardest part of textile DPP compliance.

ESPR applies to any economic operator placing in-scope products on the EU market — this includes manufacturers, importers, and authorised representatives regardless of where the business is registered. The obligation attaches to the act of selling to EU customers, not to the location of the seller.

SMBs are not categorically exempt. ESPR does not contain a general small-business carve-out for DPP requirements, although the Commission has indicated it will consider proportionality in individual delegated acts. Do not rely on size as a reason to delay preparation.

Brands that do not currently sell into the EU but plan to expand should factor textile DPP compliance into their EU market entry planning.

The enforcement date is still several years away, but the data-gathering work for textiles is substantial. Starting now puts you ahead of the compliance curve — and produces supplier and material data that has immediate value for marketing, retail buyer conversations, and consumer transparency.

Use our DPP Readiness Scan to get a personalised gap assessment for your product catalogue in under two minutes.

PassportBox is built for Shopify apparel and footwear brands preparing for DPP compliance. It removes the infrastructure burden — hosting, QR generation, registry integration — so you can focus on collecting and maintaining the product data itself.

PassportBox does not provide legal advice and cannot guarantee regulatory compliance. You remain responsible for ensuring your passport data meets the requirements of the published textile delegated act. But it removes the technical and infrastructure work so that compliance effort goes into data quality, not plumbing.