Digital Product Passports for Textiles & Fashion
What the ESPR delegated act for textiles, the revised Waste Framework Directive, and mandatory EPR schemes mean for fashion brands and textile producers selling in the EU.
Why Textiles Are a Priority Under ESPR
Textiles and apparel are one of the highest-priority product categories in the EU's Ecodesign for Sustainable Products Regulation (ESPR) — Regulation (EU) 2024/1781. The ESPR Working Plan 2025–2030, adopted by the Commission on 16 April 2025 (COM(2025) 187 final), identifies textiles and apparel as a final product category with a delegated act target date of 2027.
The decision reflects the environmental weight of the sector: textiles are among Europe's largest sources of microplastic pollution, generate significant volumes of unsold and destroyed stock, and involve complex, opaque global supply chains. The EU's regulatory response is layered — combining product-level DPP requirements under ESPR, mandatory Extended Producer Responsibility (EPR) schemes under the revised Waste Framework Directive, and a prohibition on the destruction of unsold goods.
The ESPR Delegated Act for Textiles
The textiles and apparel delegated act under ESPR has not yet been adopted as of 11 October 2026, and its call for evidence and public consultation have not yet opened. The Commission gives two different indicative adoption dates: Q1 2027 on its Have Your Say page, and Q3 to Q4 2027 on its DPP timeline. The Commission is conducting preparatory studies through the Joint Research Centre (JRC), which published the third milestone of its textiles preparatory study in December 2025.
Once adopted — targeting 2027 — the delegated act will establish:
- Specific ecodesign performance requirements for textiles: minimum durability standards, recycled content thresholds, restrictions on hazardous substances, and design-for-recyclability criteria
- Digital Product Passport (DPP) data fields specific to textiles — the exact fields will be set by the delegated act based on the JRC study findings
- Compliance timelines: companies typically have approximately 18 months after a delegated act enters into force before the requirements become enforceable
Under ESPR Article 4(4), a delegated act normally applies at least 18 months after it enters into force. If the textiles act is adopted in 2027, full DPP requirements for textiles would realistically apply in late 2028 to 2029. That is Norruva's estimate, not a legal date: no textile DPP obligation has a date yet.
What Data Will the Textiles DPP Require?
The data fields will be set by the delegated act, which selects them from the elements listed in Annex III of Regulation (EU) 2024/1781 (Article 9(2)(a)). Annex III is not a minimum that every DPP must include. For textiles, Norruva expects the data to cover:
- Material composition: fibre types and percentages, including whether fibres are recycled or virgin
- Substances of concern: any SVHC (Substances of Very High Concern under REACH) present above 0.1% by weight
- Carbon footprint by lifecycle phase
- Recycled content percentages, by material type
- Durability and repairability information — including washability cycles and care instructions
- End-of-life guidance: how to return, resell, repair, or recycle the product
- Country of origin and manufacturing location
- Supplier traceability data referenced in the DPP
The DPP will be linked to each product via a QR code, RFID, or other data carrier. It will be accessible to consumers, recyclers, resale platforms, and market surveillance authorities — each with different access rights defined by Article 11 of ESPR.
The Destruction Ban: Unsold Textiles
ESPR Article 25 prohibits the destruction of unsold consumer products listed in Annex VII. For textiles and footwear the prohibition applies to large companies from 19 July 2026 and to medium-sized companies from 19 July 2030. Micro and small enterprises are exempt.
Delegated Regulation (EU) 2026/296, adopted on 9 February 2026, sets the derogations from the ban and has applied since 19 July 2026. Implementing Regulation (EU) 2026/2, adopted the same day, sets the details and format for disclosing discarded unsold products (ESPR Article 24). It applies from 2 March 2027, and the first disclosure covers the first full financial year after that date, due within 12 months of that year's end.
For the fashion industry, this is a structural shift. Brands that currently destroy unsold seasonal stock as standard practice must both stop doing so and report on their unsold inventory volumes.
Mandatory EPR for Textiles: April 2028
The revised Waste Framework Directive — which entered into force on 16 October 2025 — requires all EU Member States to establish operational Extended Producer Responsibility (EPR) schemes for textiles by April 2028.
Under these schemes:
- Any brand placing clothing, accessories, footwear, bed linen, curtains, or similar textile products on the EU market must register with the national EPR scheme and pay a per-unit fee
- EPR fees finance the collection, sorting, reuse, and recycling infrastructure for textile waste
- Eco-modulation provisions mean that EPR fees will be adjusted based on the sustainability characteristics of the product — as defined by ESPR criteria. Products with poor durability, low recycled content, or restricted recyclability will face higher fees
- The obligation applies to non-EU e-commerce sellers placing products on the EU market, not just EU-established producers
- Micro-enterprises receive an additional year of grace beyond the April 2028 deadline
Member States must transpose the revised directive into national law by June 2027. From April 2028, registration in an EPR scheme will be a condition of placing textile products on the EU market.
France's AGEC: The National Precursor
France's Loi Anti-Gaspillage pour une Economie Circulaire (AGEC), adopted in 2020, introduced product transparency requirements for textiles years before the EU-level framework. French rules require fibres, origin, and traceability information to be disclosed at point of sale. AGEC's DPP-like requirements — enforced from January 2022 for large brands — provide a practical reference point for what EU-level textile DPP compliance will look like operationally, even though the EU requirements will be more detailed.
What Brands and Retailers Should Do Now
The delegated act has not been adopted, but the direction is fixed. Practical steps for compliance planning:
- Audit your product data: Do you know the fibre composition, origin, and substance content of every SKU? Most brands discover significant data gaps when they begin this exercise
- Review supplier contracts: Your tier-1 suppliers need to be contractually required to provide DPP-grade data. This obligation flows up the chain
- Assess EPR exposure: Identify the EU member states where you place products on the market. EPR registration and fee obligations will apply state by state from April 2028
- Monitor the delegated act process: Track JRC preparatory study outputs and Commission consultation documents — these provide advance notice of the specific DPP data fields that will be required
Sources
- Regulation (EU) 2024/1781 (ESPR), Articles 9–13, 22–25, Annex III — EUR-Lex: https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng
- ESPR Working Plan 2025–2030, COM(2025) 187 final — EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52025DC0187
- Ecodesign requirements for sustainable and circular apparel textiles, Have Your Say initiative 16116, European Commission: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16116
- Digital Product Passport and indicative DPP timeline, European Commission: https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en
- Revised Waste Framework Directive — textiles amendment, entered into force 16 October 2025 — EUR-Lex (original WFD): https://eur-lex.europa.eu/eli/dir/2008/98/oj
- European Commission — EC announcement of revised WFD entering into force: https://environment.ec.europa.eu/news/revised-waste-framework-directive-enters-force-2025-10-16_en
- Delegated Regulation (EU) 2026/296 (destruction-ban derogations) — EUR-Lex: https://eur-lex.europa.eu/eli/reg_del/2026/296/oj/eng
- Implementing Regulation (EU) 2026/2 (unsold-goods disclosure) — EUR-Lex: https://eur-lex.europa.eu/eli/reg_impl/2026/2/oj/eng
- JRC Textiles preparatory study — 3rd Milestone (December 2025): https://susproc.jrc.ec.europa.eu/product-bureau/sites/default/files/2025-12/Textile-Prep-Study_3rd-Milestone_SUM_20251212.pdf