Indicative adoption: 2027

The textile
apparel digital
product passport

Textile apparel is an ESPR priority. The Working Plan indicates 2027 for adoption of product-specific rules. The material below discusses the JRC preparatory study, not adopted apparel passport requirements.

Timing

Adoption is not the deadline

Adoption, publication and application are different

Adoption is the formal decision to adopt an act. Publication, entry into force and application are separate stages. The act sets when its requirements apply.

Start organising existing data early, but keep proposed fields separate from final requirements.

Apparel categories considered in the study

  • Tops

    T-shirts, shirts, blouses, sweaters, hoodies and other mid-layers.

  • Outerwear

    Jackets, coats, blazers, parkas, rain jackets and outdoor vests.

  • Lower body

    Pants, shorts, jeans, skirts, dresses and jumpsuits.

  • Legwear and underwear

    Tights, stockings, socks, underwear and swimwear.

  • Accessories

    Hats, scarves, ties, belts, gloves and mittens.

  • Technical apparel

    Workwear and sportswear, provided they are apparel and not excluded.

The study uses a proposed scope for textile apparel, including an 80% textile-fibre threshold and exclusions for certain regulated products. This is not the general legal definition of every textile product.

Its proposed exclusions include smart and electronic textiles, personal protective equipment, medical devices and toys. A data carrier such as an RFID or NFC tag does not by itself make a garment an electronic textile. The final scope must be checked against the adopted act.

What this passport is not

  • The proposed passport focuses on the finished garment. Upstream traceability and data exchange can still support its preparation.

  • The study focuses on finished apparel rather than separate passports for fabric or yarn. The final legal scope will be set in the relevant act.

  • A mandatory DPP is more than a marketing QR code: its content, access and availability must meet the applicable product rules.

Responsibility

Who carries the obligation

Duties depend on your role and the applicable product rules. Company size alone does not determine responsibility.

  1. Manufacturer

    Must meet the manufacturer obligations under ESPR, including the passport requirements when the relevant product rules apply. This is not limited to manufacturers established in the EU.

  2. Importer

    Checks that products imported from outside the EU meet the applicable requirements, including passport availability. This does not remove the manufacturer’s obligations.

  3. Authorised

    An authorised representative may perform specific tasks within the limits of its mandate, without assuming overall responsibility for compliance.

  4. Distributor

    Checks passport availability where required before making the product available. It must not supply a product when it has reason to believe the applicable requirements are not met.

  5. Provider

    ESPR Article 2 defines a passport service provider as an independent third party that processes the data on the operator’s behalf.

Using a service provider does not remove the legal obligations of manufacturers, importers or other responsible economic operators.

Crumpled blue textile fabrics ready for sorting and recycling.

Identifiers

The codes apparel already uses

The study builds on identifiers the sector already issues rather than inventing new ones.

Identifier What it identifies
GTIN Global Trade Item Number. A GS1 trade-item identifier that can be combined with batch or serial information for more specific identification.
GLN Global Location Number. A GS1 identifier used for parties and locations.
HS / TARIC Customs classification, well established. Stakeholders warned the codes must not be implemented in a way that suggests passport duties apply only to imports, since apparel is also made inside the EU.
UPI Unique product identifier. Links the passport to the relevant product model, batch or item.
UOI Unique operator identifier. Identifies the relevant economic operator.
UFI Unique facility identifier. Identifies a location or facility where a delegated act makes that relevant.

An internal SKU is not necessarily globally unique. Map internal product references to the identifiers you intend to use.

Granularity

One passport per what?

Article 9(2)(d) leaves the level to the product-specific act. The study discusses practical options; these are not final requirements.

Level What the study found
Model The study reports model-level data exchange and discusses this level for fibre composition and environmental-footprint information. These are preparatory findings.
Batch The study describes batch-level use in production, testing and traceability. Businesses can define a batch differently, so the meaning needs to be clear.
Item The study discusses practical limits to item-level identification and possible phased approaches. It does not establish an immediate item-level legal duty.

Moving to item-level identifiers would demand substantial upgrades to supplier labelling, since production commonly uses shared labels across identical products.

Batch-level footprint calculation was judged disproportionate except where materials, processes or sourcing genuinely differ between batches.

Readiness

Available records and missing data

The study draws on interviews with selected supply-chain participants. It describes information held in documents, spreadsheets and email, alongside gaps in access and upstream data. This is evidence from the study, not a claim that every company already has every required field.

  • Product identifiers

    The study identifies established use of product and location identifiers, including GTIN and GLN. Coverage varies between businesses.

  • Fibre composition

    Fibre-composition labelling is already required for products covered by the Textile Labelling Regulation, subject to its rules and exceptions.

  • Robustness testing

    Existing test reports can provide useful evidence. Check which results are available and whether their methods match the eventual requirements.

  • Recycled content

    Recycled-content evidence may include GRS or RCS certification. Organic or cotton-sourcing claims are not interchangeable with proof of recycled content.

  • Environmental footprint

    The study discusses product environmental footprint methods for apparel and footwear. Carbon footprint is one aspect of environmental performance, not the whole PEF assessment.

  • Substance detail

    A certificate alone may not provide the substance concentrations or locations a future passport requires. Check the underlying reports and applicable disclosure rules.

Access model

Possible audiences and access

  1. Public Anyone with the code
  2. Repairers Repair and reuse operators
  3. Recyclers Sorting and recycling data
  4. Authorities Market surveillance, customs

ESPR Article 9(2)(f) concerns who can access which data; point (g) concerns who can create or update it. The product-specific act sets the details. The groups shown here are illustrative, not a fixed access scheme.

Access must take account of the relevant actors and the protection of confidential business information.

What to do now

Start with your suppliers

  • Look beyond direct suppliers

    Information about fabric, yarn and raw-material origin may sit several steps upstream. Identify who holds it and how it can be linked to your finished products.

  • Define your internal product model

    Your PLM structure and GTINs may group colours and sizes differently. Map the relationship so you can assess the eventual requirements.

  • Organise existing test results

    Extract useful results from existing reports and keep links to the evidence. Check whether additional information or testing is needed.

  • Explore a footprint pilot

    If a pilot is useful for your business, document the method, product level and assumptions. The preparatory study does not establish the final legal calculation method.

FAQ

See all questions

When will a textile Digital Product Passport become mandatory?

The application date is not fixed. The Working Plan indicates 2027 for adoption of textile-apparel rules. The final act will set the scope and application date.

Does the passport apply to fabric and yarn?

The preparatory study focuses on finished apparel. Fabrics, yarns and fibres supply data for those products, but the final legal scope must be checked in the adopted act.

Do we need one passport per garment or per style?

The product-specific act will decide. The study discusses model, batch and item approaches and the practical limits of each. Do not treat any study option as an adopted legal requirement.

Our upstream suppliers will not share data. What happens?

Supplier data gaps can make preparation harder. Start by identifying the missing evidence, agreeing requests and recording unresolved issues. A supplier’s refusal does not automatically remove the responsible operator’s legal duties.

Is workwear or sportswear covered?

The study considers technical apparel, including workwear and sportswear, subject to proposed exclusions such as PPE and medical devices. Final scope depends on the adopted act.

Start before the act, not after

DPPVIEW helps organise apparel data, map existing identifiers and identify supplier gaps. Start with passport preparation while the final product rules and our hosting platform are still being developed.

Discuss passport preparation

Sources

The sources distinguish the adopted legal framework from the JRC preparatory study and practical preparation suggestions.

Last reviewed: . This page describes a proposal, not adopted law. We update it when the Commission publishes a draft delegated act.