Digital product passport for textiles: when does it apply and what goes in?
As of · sourced from primary law · not legal advice · Auf Deutsch lesen
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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.
The short answer
For textiles the digital product passport is no duty yet. It comes with a delegated act under Articles 4 and 9 ESPR, Regulation (EU) 2024/1781. The Commission’s working plan gives 2027 as the provisional year of adoption for textiles and apparel. Such an act applies as a rule no earlier than 18 months after entry into force (Art. 4(4)).
Art. 4, 9 and 18(5)(c) ESPR
Legal basis: the Ecodesign Regulation
The ESPR has been in force since 18 July 2024. It names “textiles, in particular garments and footwear” as a priority for the first working plan (Art. 18(5)(c)). A product may only be placed on the market with a passport once a delegated act requires one (Art. 9(1)). For textiles that act does not exist yet. On 11 November 2026 we found no act under Article 4 for any product group on EUR-Lex.
The working plan COM(2025) 187 of 16 April 2025 includes textiles and apparel, not footwear. For footwear the Commission is commissioning a study, to be completed by the end of 2027. The basics of the passport are in the guide Digital product passport: deadlines and product groups, all industries at a glance under Product passport by industry.
Timeline with status
The year in the working plan is the provisional year of adoption, not the start of the duty. The plan is a Commission communication, not law.
| Step | Date | Status | Provision |
|---|---|---|---|
| ESPR in force | 18 July 2024 | binding | Art. 80 Regulation (EU) 2024/1781 |
| Ban on destroying unsold apparel, large enterprises | 19 July 2026 | binding | Art. 25(1), Annex VII ESPR |
| Commission’s digital product passport registry (deadline) | 19 July 2026 | binding | Art. 13(1) ESPR, Implementing Regulation (EU) 2026/1778 |
| Delegated act for textiles and apparel | 2027 | indicative | COM(2025) 187 |
| Passport duty for textiles | as a rule no earlier than 18 months after the act enters into force | planned | Art. 4(4) ESPR |
| Ban on destruction, medium-sized enterprises | 19 July 2030 | binding | Art. 25(1) ESPR |
Which data is fixed
For textiles, none yet. The act selects from the list in Annex III ESPR what must or may go in. That list includes the unique product identifier, the GTIN or an equivalent identifier, commodity codes, compliance documentation, instructions for use and safety information, details of the manufacturer and the importer, and the service provider holding the back-up copy.
The working plan says the ESPR information requirements for textiles will “work in synergy with the Textile Labelling Regulation, currently under review”. Already today you have to label or mark the fibre composition (Art. 14(1) Regulation (EU) No 1007/2011). Which data on materials, durability or recycling is added will only be set in the act.
What you can do today
- Check whether the ban on destruction applies to you: since 19 July 2026 for large enterprises, from 19 July 2030 for medium-sized ones. Micro and small enterprises are exempt.
- Keep fibre composition, care information and suppliers per model in a table, not only on the label.
- Assign a GTIN to each model where you have one. Annex III lists the GTIN as a possible identifier.
- Give each model a permanent address that a later QR code can carry.
- Watch the Official Journal. Only the act sets the date.
How ProofPass helps
The product passport module gives every model a permanent address and a QR code. Documents such as the declaration of conformity or care instructions are stored with versions. The textile deadlines are in the deadline tracker. Which groups the working plan covers is answered on the page ESPR working plan: which product groups?.
Further reading
- The product passport module: permanent address, QR code and documents per product
- The basics in the guide Digital product passport: deadlines and product groups
- Every date per product group in the deadline tracker
- All industries at a glance: product passport by industry
Frequently asked questions
Does the textile passport also cover footwear?
Not in the first step under the working plan COM(2025) 187. Footwear is not included there; the Commission is having a study prepared by the end of 2027. Art. 18(5)(c) ESPR does name footwear among the priority groups.
Does a small fashion label have to do anything today?
Not for the passport, because the act is missing. The ban on destroying unsold apparel under Art. 25(1) ESPR does not apply to micro and small enterprises. Fibre labelling under Art. 14 Regulation (EU) No 1007/2011 applies to everyone.
Is the passport required per garment or per model?
The act decides. Art. 9(2)(d) ESPR allows the model, batch or item level.
What does “adoption 2027” mean for my planning?
That the Commission provisionally intends to adopt the act in 2027. Under Art. 4(4) ESPR it applies as a rule no earlier than 18 months after entry into force. Arithmetically the duty is therefore not before mid-2028, barring a justified exception.
With ProofPass
ProofPass does not provide a product passport under an ESPR act today, because there is none yet for this group. You get a permanent address per product, a QR code, a GS1 Digital Link address from your GTIN if you want one, and an archive of every document version. That is the groundwork a later passport needs. Which fields it requires is decided by the act alone.
The terms and legal notices are in German, and the German version is binding.
Sources
- Regulation (EU) 2024/1781 (Ecodesign for Sustainable Products Regulation, ESPR), Official Journal (read on 11 November 2026)
- European Commission: Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030, COM(2025) 187 of 16 April 2025 (read on 11 November 2026)
- Regulation (EU) No 1007/2011 (textile fibre names and labelling of fibre composition)
- Implementing Regulation (EU) 2026/1778 (digital product passport registry), OJ of 17 July 2026
As of 11 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.