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The European Union’s Digital Product Passport (DPP) requirement is part of the Ecodesign for Sustainable Products Regulation (ESPR), which fundamentally changes how fashion brands need to document and share product information. This page explains the regulatory framework, its implications for fashion brands, and who it applies to.

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What is the ESPR?

The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18 July 2024 as Regulation (EU) 2024/1781. It establishes a framework for setting ecodesign requirements for products sold in the EU, with the Digital Product Passport as a core mechanism for transparency.
The ESPR is framework legislation. This means it sets general rules, then delegates product-specific details to separate legal instruments called delegated acts.
The ESPR was first proposed on 30 March 2022 alongside the EU Strategy for Sustainable and Circular Textiles, which explicitly named Digital Product Passports as essential for textile transparency. After two years of legislative negotiation, the regulation is now law.

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Key objectives

The ESPR aims to:
  • Make products more durable, reliable, reusable, and repairable
  • Increase recycled content in products
  • Enable remanufacturing and high-quality recycling
  • Reduce carbon and environmental footprints
  • Restrict the destruction of unsold consumer goods

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What the regulation means for fashion brands

For fashion brands, the ESPR introduces mandatory requirements for product transparency and documentation. The Digital Product Passport becomes the primary mechanism for providing this information to consumers, authorities, and recyclers.

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The textile delegated act

While the ESPR framework is already law, the specific requirements for textile products will be defined in a textile-specific delegated act. This delegated act will specify:
  • Exactly what data fields must be included in the DPP
  • Technical standards for data formatting and access
  • When compliance becomes mandatory
  • Any exemptions or tiered requirements
The textile delegated act is expected to be adopted between late 2026 and Q2 2027, with brands getting at least 18 months after adoption to comply. This puts mandatory DPPs for new textile products around mid-2028.

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What brands will need to provide

Based on the ESPR framework and preparatory work, textile DPPs are expected to include:
  • Product identification (name, type, color, size)
  • Unique product identifier (GTIN or EAN)
  • Manufacturer and importer details
  • Material composition and percentages
  • Material origins
  • Production journey and traceability
  • Substances of concern
  • Certifications and compliance documentation
  • Lifecycle environmental impacts (carbon footprint, water consumption)
  • Recycled and bio-based content
  • Recyclability per material
  • Durability metrics
  • Repairability information
  • Care instructions
  • End-of-life handling guidance
For a detailed breakdown of each data requirement, see the data requirements page.

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Complementary regulations

The DPP doesn’t exist in isolation. Several other EU regulations interact with and reinforce the passport requirement: Empowering Consumers Directive (September 2026): Prohibits generic green claims without verifiable data, making the DPP a key source of substantiation. Forced Labour Regulation (December 2027): Requires supply chain traceability to prove products aren’t made with forced labor, overlapping with DPP traceability requirements. Ban on destruction of unsold textiles: Takes effect July 2026 for large enterprises, July 2030 for medium-sized enterprises.
The 2025 “Omnibus” simplification wave scaled back corporate sustainability reporting rules significantly, but the DPP framework itself was left untouched. Product-level requirements are moving forward as planned.

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Who does this apply to?

The Digital Product Passport requirement is expected to apply to any brand or company that places textile products on the EU market. This includes:
  • Fashion brands based in the EU
  • Non-EU brands that sell or import into the EU
  • Retailers that act as importers for private label products
  • Online marketplaces facilitating sales into the EU

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Geographic scope

If you sell textile products in the EU, the regulation applies to you regardless of where your company is based. This means brands in the US, UK, Asia, or anywhere else that sell to EU customers will need to provide DPPs for those products.

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Product scope

The DPP is expected to cover:
  • Clothing (shirts, dresses, trousers, outerwear, etc.)
  • Accessories (bags, scarves, hats, belts, etc.)
  • Footwear
  • Home textiles (curtains, bedding, towels, etc.)
The exact product categories will be confirmed in the textile delegated act. The EU has not yet published specific exemptions for smaller brands, though it’s possible the delegated act could introduce tiered requirements based on company size.

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Company size considerations

As of now, the ESPR does not exempt micro or small enterprises from DPP obligations, unlike some provisions (such as the ban on destruction of unsold goods, which currently exempts micro and small enterprises). However, this could change when the textile delegated act is published. Until then, the safest assumption is that DPP requirements will apply broadly across all company sizes.

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The data carrier requirement

The DPP must be accessible through a physical data carrier on the product itself. For most fashion brands, this means a QR code printed on the care label.
1

QR code generation

Generate a unique QR code for each product or product variant that links to the digital passport.
2

Label integration

Include the QR code on the product’s care label, which is finalized during pre-production.
3

Hosted passport

Ensure the QR code links to a hosted page containing all required DPP data in the correct format.
Labels and trims are typically finalized 6-10 months before a product enters the market, so brands need to have their DPP system in place well before the compliance deadline.

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Enforcement and penalties

While specific enforcement mechanisms for the textile DPP will be detailed in the delegated act, the ESPR gives EU member states authority to:
  • Conduct market surveillance and audits
  • Require corrective action for non-compliant products
  • Restrict or prohibit the sale of non-compliant products
  • Impose financial penalties
Non-compliance could result in products being blocked from the EU market. For brands that rely on EU sales, this represents a significant business risk.

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What happens after initial compliance

The DPP framework is designed to evolve. According to the European Parliament Research Service, progressively expanded DPP data requirements and broader stakeholder access are expected through the early 2030s. By 2030, the EU Textile Strategy targets all textile products on the EU market to be:
  • Long-lived and durable
  • Recyclable by design
  • Made substantially from recycled fibers
The DPP will be central to demonstrating and enforcing these goals.

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How Avelero helps

Avelero is built specifically to help fashion brands comply with the EU Digital Product Passport regulation. The platform:
  • Generates regulation-ready product passports with all expected data fields
  • Calculates lifecycle environmental impacts automatically using built-in LCA prediction
  • Integrates with existing systems like Shopify, PLM, and ERP
  • Provides fully customizable, brand-matched passport designs
  • Generates QR codes ready for care label production
For implementation guidance and key dates, see the timeline page.

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