EU Digital Product Passport for clothing: what brands need to prepare

The EU Digital Product Passport (DPP) for clothing is decided in principle but not yet in detail. The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, has been in force since 18 July 2024. It says that once a product group is covered by one of its delegated acts, those products can only be placed on the EU market if a digital product passport is available. For clothing, that delegated act has not been adopted. The Commission’s working plan gives 2027 as the indicative year for adopting it, and the regulation says a delegated act cannot apply earlier than 18 months after it enters into force, except in duly justified cases. So no garment needs a passport today. What already applies is the ESPR ban on destroying unsold clothing, for large companies from 19 July 2026. Below: what is fixed, what is still being written, and the supplier data worth collecting now, while it is still easy to get.

This summarises what the texts say; it is not legal advice. Confirm your own case with a lawyer or compliance adviser.

The EU textile rules at a glance

A brand selling clothing in the EU meets four sets of rules, from different laws on different timetables.

How the ESPR reaches clothing

The ESPR is a framework. It does not set requirements for a t-shirt or a jacket by itself. Instead, the Commission adopts a delegated act for each product group under Article 4, containing performance requirements (such as durability or recycled content) and information requirements. Under Article 7, those information requirements include, as a minimum, a digital product passport and the tracking of substances of concern.

The regulation’s recitals list textiles, "in particular garments and footwear", among the priorities for the first working plan. The Commission’s Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025 to 2030, dated 16 April 2025, ranks textiles and apparel first among the new final products, and gives 2027 as the indicative timeline for adoption. The plan also says the ESPR information requirements for textiles will work alongside the Textile Labelling Regulation, which is under review.

Responsibility sits with whoever places the product on the market. Article 29 says that before placing a covered product on the market, an importer must ensure the manufacturer has carried out conformity assessment, that the product carries the required information, and that a digital product passport is available, including a back-up copy held by a passport service provider. For garments made in Bangladesh, that duty is likely to fall on the brand or its EU importer, not the factory, even though the factory holds most of the data.

What a digital product passport is

The passport is a structured digital record linked to the physical product. Article 10 requires that:

• it is connected through a data carrier to a persistent unique product identifier;
• the data carrier is physically present on the product, its packaging or accompanying documents, as the delegated act specifies;
• the data is based on open standards, machine-readable and transferable without being locked to one vendor.

Article 9 leaves the details to each delegated act: which data to include, which data carrier, where it goes, whether the passport is kept at model, batch or item level, who may see which data, who may update it, and how long it must stay available, which must be at least the product’s expected lifetime.

Annex III lists the menu the delegated act will choose from. For clothing, the most relevant entries are the unique product identifier, the GTIN, the commodity code (such as a TARIC code), compliance documents and certificates, manufacturer and importer details (including the importer’s EORI number), unique facility identifiers for the sites involved, and information on substances of concern.

Article 13 required the Commission to set up a central registry by 19 July 2026, storing at least the unique identifiers and, for goods being released for free circulation, the commodity code. On 17 July 2026 the Commission launched a DPP web page as the entry point for the system, noting that batteries come first and that textile apparel is among the product groups expected to follow over time.

What is decided and what is still being written

• Decided: the framework, the rule that covered products need a passport, the list of possible passport content in Annex III, the importer’s duty to make sure a passport exists, the destruction ban and its dates.
• Not decided: which garments the textiles act will cover, which data points become mandatory, whether the passport is kept per model or per batch, the data carrier and where it sits on the garment, any durability or recycled content thresholds, and the date the passport becomes mandatory.

Any fixed date you see quoted for a mandatory textile passport is an estimate. Working from the official texts: if the act were adopted early in 2027, the 18-month minimum would put its application in the second half of 2028 at the earliest; a later adoption moves that later still. Article 4 also asks the Commission to give businesses, particularly SMEs, sufficient time to comply.

What the JRC study proposes

The best indication of where the textiles act is heading is a study for the Commission’s Joint Research Centre (JRC), Study on DPP content for textile apparel products under ESPR, published in May 2026. It states that it does not necessarily reflect the Commission’s position, so treat it as a proposal. Its recommendations include:

• Batch identifiers as the minimum, built for example from a GTIN plus a lot number, populated with batch or model information depending on the data point.
• Producer identification at batch level, because the manufacturing facility can differ within a single model, and only the exact facility allows footprint figures to be checked.
• Chemicals at batch level, including every chemical used across all colours in the batch, as a worst case.
• Fibre composition at model level, since it is fixed by design.
• Recycled and organic content declared per model but verified per batch, in line with how third-party certification already works.
• Carbon or environmental footprint at model level as a baseline, with default values or averages allowed where data is missing.

The study’s list of data needs also includes country of origin, production sites and processing locations, care instructions, robustness tests (visual inspection, spirality and dimensional change), the presence of substances of concern, a recyclability score, and certificates and test results.

The data to start collecting from your supplier now

None of this is mandatory yet, but almost every item below is created at the factory or further up the chain, at the time of production. Asking for it with each order costs little; rebuilding it for goods made two years earlier is often impossible.

Keep the data in one structured file per style, colour and lot, not in email attachments. Check that certificates are genuine and cover the site that made your goods; our guide on how to verify a factory certificate in Bangladesh shows how. And for commodity codes, see HS codes for clothing, then confirm the code with your broker.

The ban on destroying unsold clothes, already applying

Article 25 of the ESPR prohibits the destruction of unsold consumer products listed in Annex VII from 19 July 2026. Annex VII covers apparel and clothing accessories in chapters 61 (knitted) and 62 (woven) of the EU’s combined nomenclature, leather apparel (4203), hats and headgear (6504 and 6505) and footwear. The ban applies to medium-sized enterprises from 19 July 2030. Micro and small enterprises are exempt, but a company outside the ban may not destroy unsold products supplied to it in order to get round it.

In February 2026 the Commission adopted a delegated regulation setting out the limited cases where destruction is still allowed, such as unsafe or damaged items, counterfeit goods and products rejected by charities. The Commission says companies relying on these exemptions must provide proof, such as documents or test results, and keep records for five years. The expected alternatives are selling, including at a discount, donating, or preparing for reuse.

Article 24 adds disclosure. Companies that discard unsold products must publish each year, on an easily accessible page of their website, the number and weight discarded by product type, the reasons, the share sent for reuse, recycling, recovery or disposal, and what they are doing to prevent it. The first disclosure covers the first full financial year during which the regulation is in force. An implementing regulation introduces a standard disclosure format from February 2027, and medium-sized companies follow from 2030.

The Commission estimates that 4 to 9% of textile products placed on the European market are destroyed before use, between 264,000 and 594,000 tonnes a year. For sourcing, overstock can no longer simply be written off and destroyed, so order quantities deserve more care.

Textile EPR under the amended Waste Framework Directive

Directive (EU) 2025/1892, adopted on 10 September 2025 and published on 26 September 2025, entered into force on 16 October 2025 and amends the Waste Framework Directive. It makes producers responsible for the textile, textile-related and footwear products listed in its new Annex IVc, which includes all of chapters 61 and 62, household textiles such as bed linen and curtains, hats and footwear. Producers must cover the costs of collecting, transporting, sorting and treating those products once used or discarded.

A "producer" includes a business established in a member state that first supplies such products there from another member state or a third country, and a business that sells directly to end users by distance contract from another member state or from outside the EU. Member states must require distance sellers based in another member state to appoint an authorised representative, and may require it of sellers based outside the EU.

Member states must bring their national laws into force by 17 June 2027 and set up the schemes by 17 April 2028. Fees are to be based on weight and, where appropriate, quantity, and modulated according to the ESPR ecodesign requirements, which links the two systems. Member states may also modulate fees for fast-fashion practices. Registration, fees and reporting will be set country by country; our pages for German brands and French brands cover sourcing for those markets.

The Textile Labelling Regulation, now and after its revision

Regulation (EU) No 1007/2011 applies today. Textile products, and products containing at least 80% textile fibres by weight, must be labelled or marked with their fibre composition whenever they are made available on the market. The label must be durable, easily legible, visible and securely attached, in the official language or languages of the member state where the product is sold, unless that state provides otherwise. Products with non-textile parts of animal origin must say "Contains non-textile parts of animal origin". The composition must also be visible before purchase, including online.

The Commission notes that the current rules are limited to fibre composition. After a public consultation from 19 December 2023 to 15 April 2024, it planned a proposal for the second quarter of 2026. The European Parliament’s legislative tracker, last updated on 1 August 2026, still showed no proposal adopted. The JRC study lists origin (the place of making-up), care instructions and size as under consideration for the revision, with basic mandatory information on the physical label and supplementary information on a digital label hosted on the passport. Until a new text is adopted, label to the current regulation; our guide to clothing care label symbols covers the physical label.

A realistic order of work for a brand

1. Now: label to Regulation 1007/2011 (our EU brands page covers the wider market). If you are a large enterprise, stop any destruction of unsold stock and prepare the annual disclosure.
2. From your next order: collect the supplier data in the table above for every style, colour and lot, and keep it in one place.
3. 2027: the indicative year for adopting the textiles act; national EPR laws are due by 17 June 2027.
4. By 17 April 2028: expect to register with EPR schemes in your markets.
5. After the textiles act enters into force: at least 18 months, unless the act says otherwise, to have passports in place for covered products.

What to do next

The passport will run on supply-chain data, so start with a supplier who can document it. We are a buying house in Narayanganj, Dhaka, and orders are made in audited partner factories. Before production we name the factory making your order in writing, with its address, certificates and audit reports, which is the starting point for the facility data above. For more, see our compliance and audits and sustainable clothing manufacturing pages. Send us your styles and target markets; we reply within one working day.