Textile Digital Product Passport: Dates, What’s Decided and What Isn’t

No textile digital product passport is required today, and on the European Commission’s own plan none can be required before 2029. The act that would create one, a delegated act for apparel textiles under the Ecodesign for Sustainable Products Regulation (ESPR), is planned for adoption in the fourth quarter of 2027, and the regulation sets a minimum of 18 months between such an act entering into force and its requirements applying. Nobody has yet decided what a textile passport contains, whether it identifies a style, a lot or a single garment, or what data carrier it uses.

This page is for the mill or garment exporter whose buyer has asked “are you DPP-ready?”, or who is being sold passport software. It separates what is decided, what is only planned and what is not decided at all, then sets out what a supplier can sensibly hold now without buying anything.

Textile digital product passport: decided, planned, not decided

What the regulation already fixes

ESPR is a framework. Article 9 says that where a product group’s delegated act requires it, a product may only be placed on the EU market if a digital product passport is available, and the data in it must be accurate, complete and up to date. Until a textile act exists, that duty has nothing to attach to for textiles. What the regulation does fix, for every passport that any act later requires:

• A carrier on the product. The passport is reached through a data carrier (a barcode, a 2D symbol or another machine-readable medium) linked to a persistent unique product identifier, placed on the product, its packaging or its accompanying documents as the act specifies (Arts 2(29) and 10(1)). The regulation does not choose the carrier.
• Open standards and no lock-in. Passport data must rest on open standards in an interoperable format and be transferable without tying the operator to one vendor (Art. 10(1)(d)).
• A back-up with a service provider. The operator placing the product on the market must keep a back-up copy of the passport with a passport service provider (Art. 10(4)). The requirements those providers must meet, and any certification of them, are left to a further delegated act (Art. 11), which the Commission’s timeline plans for 2027.
• A menu of contents. Annex III lists twelve elements a delegated act may draw a passport from, among them the unique product identifier, a GTIN under ISO/IEC 15459-6 or equivalent, commodity codes, compliance documents, operator and facility identifiers, the importer’s EORI number, and the service provider holding the back-up. Identifiers and carriers must follow the ISO/IEC 15459 series, parts 1 to 6. Annex III is a menu, not an order: the textile act will choose from it and attach its own conditions.
• A registry of identifiers, not of passports. The EU registry stores at least the unique identifiers, and the commodity code for goods being released into free circulation (Art. 13(1)). The passport itself is stored by the operator responsible for it or by a service provider (Art. 11(c)). Registration is done by the verified economic operator placing the product on the EU market, at the level the product’s delegated act sets (Implementing Regulation (EU) 2026/1778, Art. 8(1)).

The registry going live in July 2026 created no duty for textiles: it is infrastructure waiting for product acts. The first passport to become mandatory, for certain batteries under a separate regulation, does so on 18 February 2027, according to the Commission’s digital product passport page.

What the Commission plans, and how firm the dates are

The Commission’s Working Plan 2025–2030 (COM(2025) 187, 16 April 2025) puts textiles and apparel first among final products, with an indicative adoption year of 2027, and says the information requirements will work alongside the Textile Labelling Regulation. Its textile apparel passport page narrows that to the fourth quarter of 2027 and warns that timelines may evolve. The overview page says Q3 to Q4 2027, and the initiative’s entry on the Have your say portal, published in December 2025, still shows the first quarter of 2027. Planned dates move.

Getting from a planned adoption date to the earliest date a passport could be required takes three steps, all in the regulation:

• After adoption, the Parliament and the Council have two months to object, which either can extend by two months more. The act enters into force only if neither objects (Art. 72(6)).
• Its requirements cannot apply earlier than 18 months after it enters into force, except in duly justified cases for the whole act or for specific requirements (Art. 4(4)).
• Adopted at the very start of Q4 2027, with no extension and no exception, that puts the earliest application around mid-2029. A later adoption, a longer scrutiny or a longer transition pushes it out.

The first act is aimed at apparel: the Commission’s page treats home and technical textiles as separate subgroups. Footwear is not in the first working plan; a study on it is due by the end of 2027.

The same page lists what the passport may contain, depending on the final act: product identification and characteristics; fibre composition as required under the Textile Labelling Regulation, where relevant; information for use, repair and maintenance; information for reuse, resale, disassembly, refurbishment and end of life; origin information; and the identity of the economic operators involved. It is an indication, not a field list, and the page says the exact requirements will come from the act and its technical specifications.

The duty, the page says, falls mainly on the operators placing apparel on the EU market (manufacturers, producers or importers); distributors must make sure a passport exists; and some supply-chain actors, notably suppliers, may have to provide relevant information available to them. That last clause is the one that reaches a mill or factory outside the EU, and what it will ask for is not written yet. Under ESPR a manufacturer is whoever markets the product under its own name or trademark (Art. 2(42)), so on a private-label order it is usually the brand.

What is not decided for textiles

Article 9(2) lists what each product group’s act has to settle. For textiles, every item on it is open:

• the data the passport must hold, chosen from Annex III;
• which data carrier, and where on the product it is placed;
• whether the passport is set at model, batch or item level, and how those levels are defined;
• how a customer reaches it before buying, including when buying online;
• who may read which data, and who creates or updates it;
• how long it must remain available.

Nor are there performance classes for textiles. ESPR lets an act set classes of performance (Art. 7(4)), and where member states offer incentives for regulated products, they must aim them at the top two classes populated across the EU (Art. 64). With no textile act there are no classes, so no “tiers”, “bonus levels” or passport scores a product can earn today.

Five claims to check before you sign anything

GTIN, batch, serial and GS1 Digital Link

Annex III names the GTIN, as provided for in ISO/IEC 15459-6 or an equivalent, as one possible passport element. GS1 operates the GTIN system, and it is one route among others: ESPR asks the Commission to keep its identifier rules as technology-neutral as possible (Art. 12(6)). In GS1’s own terms, from its Application Identifier table and the GS1 Digital Link URI Syntax standard (release 1.7.0):

GS1 Digital Link is neither an identifier nor a passport. It is GS1’s standard way of writing those identifiers as a web address, so that one QR code can carry the GTIN, the lot or serial number, and a link to information about the product. The batch and serial numbers qualify the GTIN rather than replace it, so a lot is written as the product’s GTIN plus a batch number, not as a GTIN of its own. GS1’s glossary also places responsibility for the GTIN with the brand owner, the organisation that owns the product’s specification wherever it is made. On a private-label order, that is normally the buyer.

The registry rules already show how the levels nest. Where a passport is set at item level, the batch and model identifiers must be linked to it where they exist, and a batch-level passport must be linked to its model identifier (Implementing Regulation (EU) 2026/1778, Art. 8(4) and 8(5)). The harmonised standards EN 18219 (unique identifiers) and EN 18220 (data carriers; the British edition is BS EN 18220) cover how passport systems handle both. Whichever level the textile act picks, a supplier whose lot records connect yarn, fabric and finished goods will be able to answer it.

What a supplier can do now, without buying anything

Much of what the Commission says a textile passport may draw on is information suppliers are already asked for under rules that apply today. Keeping it in order costs time, not software.

Fibre composition, under rules already in force

The Textile Labelling Regulation, (EU) No 1007/2011, already requires every textile product on the EU market to state the name and percentage by weight of all its fibres, in descending order (Art. 9), using only the fibre names in its Annex I (Art. 5). Between businesses in the supply chain, that information may travel in commercial documents instead of on a label (Art. 14(2)). Composition is determined by the methods in Annex VIII (Art. 19), which in places refer to parts of the EN ISO 1833 series (ISO 1833-1 sets out its general principles). The Commission names fibre composition “as required under the Textile Labelling Regulation” among possible passport contents. So a composition statement for each article, in Annex I names and backed by a test report, is required now and is the most obvious candidate for reuse. The Commission’s review page planned a proposal to revise the Regulation by the second quarter of 2026; until a revision is adopted, the 2011 rules apply.

Origin and supply-chain evidence

Origin information is on the Commission’s list of possible passport content. One rule already makes supply-chain evidence a condition of market access, and a second has a fixed start date:

• United States. Under the Uyghur Forced Labor Prevention Act, US Customs and Border Protection has applied a rebuttable presumption against affected goods since 21 June 2022. An importer overcomes it only with clear and convincing evidence, and CBP’s guidance expects due diligence and supply-chain tracing behind that evidence.
• European Union. The Forced Labour Regulation, (EU) 2024/3015, prohibits placing on the EU market, making available or exporting any product made with forced labour, from 14 December 2027 (Arts 3 and 39, Official Journal).

The record that serves both, and a future passport, is the same: for each order, which sites made it, which fibre or yarn went in and from whom, and the documents that show it.

Identifiers you already hold

• Commodity codes for each article (Annex III, point (d)). Customs already needs them.
• A list of every site that touches the product, including job workers, with legal names and addresses. Annex III includes facility identifiers, and where a site has none, the operator creating the passport must first ask whether one exists and may then request one on that site’s behalf (Art. 12(3)).
• Lot records that connect yarn lot, dye lot or fabric batch to the finished order, for the reasons in the section above.
• The importer’s EORI number and the EU responsible operator are also on the menu, but they sit on the buyer’s side, not yours.

Check yourself against the menu

The DPP Annex III readiness check counts which of the twelve Annex III elements you can produce a document for today, and reports the result as counts and a proportion, not as a pass or a fail. It gives the buyer an honest answer, and it gives you questions for any vendor: which of the twelve does your platform hold for us, and where does each come from? Which of the six cited standards does it implement, and can our data leave in an open format, as the regulation’s no-lock-in rule expects? Hold off choosing a “certified” hosting provider until the service-provider act sets the conditions. The digital product passport hub gathers the related records and tools.

A reply to “are you DPP-ready?”

A defensible answer, in substance: no textile passport requirement exists yet, and the Commission plans the act for late 2027; today we hold the fibre composition of each article under the Textile Labelling Regulation with test reports, the commodity codes, lot records from yarn to finished goods, and a list of every site involved; we will supply what the act requires once it is adopted. That answer survives the follow-up questions. A plain “yes” does not.

The destruction ban, which does apply

Separately from passports, ESPR has prohibited since 19 July 2026 the destruction of unsold consumer products listed by customs code in its Annex VII: apparel and clothing accessories in chapters 61 and 62, leather apparel (4203), headgear (6504 and 6505) and footwear (6401 to 6405) (Art. 25). It binds large enterprises now and medium-sized ones from 19 July 2030. Micro and small enterprises are outside it, but an operator outside the ban may not destroy stock passed to it in order to get round the ban. Delegated Regulation (EU) 2026/296, adopted on 9 February 2026 and applying from 19 July 2026, sets out when destruction is still allowed (dangerous or irreparably damaged goods, infringing goods, donations nobody accepted, among others) and the records to keep for five years. Operators that discard unsold products must also disclose it every year (Art. 24, again with micro and small enterprises exempt and medium-sized ones from 19 July 2030); Implementing Regulation (EU) 2026/2, adopted the same day, sets the disclosure format from 2 March 2027.

How this page is kept

Last verified: 3 October 2026. Built from the text of Regulation (EU) 2024/1781 in the Official Journal and the delegated and implementing acts adopted under it, the Commission’s digital product passport pages and its Working Plan 2025–2030, CEN-CENELEC’s notice on the passport standards, and GS1’s reference publications. The ESPR dates are also held in the ESPR record in the regulation register, with a confidence marker on every date; the Q4 2027 date is marked indicative because the Commission calls it that. This page will be revised when the textile act is adopted or the Commission changes its plan. It describes what the instruments say; it is not legal advice for a particular product or shipment. Corrections are welcome through the contact page.