Fashion brands selling in the EU will need Digital Product Passports on virtually every garment by approximately mid-2028. The ESPR framework is already law. What’s pending is the textile-specific delegated act that defines exact data requirements and the mandatory compliance date.
Confirmed dates
These dates are established in adopted EU regulations.July 2024: ESPR enters into force
The Ecodesign for Sustainable Products Regulation (ESPR) became law on 18 July 2024 as Regulation (EU) 2024/1781. What this means: The legal foundation for Digital Product Passports is in place. The framework gives the European Commission authority to adopt product-specific requirements through delegated acts.April 2025: Textiles designated as priority product group
The European Commission adopted its 2025-2030 Working Plan, officially designating textiles as a top-priority product group for DPP requirements. What this means: Textile DPP requirements are moving forward as a priority, not a future consideration.July 2026: Central DPP registry operational
The EU’s central Digital Product Passport registry must be operational. What this means: Technical infrastructure for hosting and accessing passports will be in place before brand compliance is required.July 2026: Destruction ban for large enterprises
Ban on destruction of unsold textiles takes effect for large enterprises. What this means: Large brands must track and account for unsold inventory, reinforcing the need for product-level data systems.September 2026: Empowering Consumers Directive
The Empowering Consumers Directive takes effect, prohibiting generic green claims without verifiable data. What this means: Brands can’t make environmental claims without substantiation. The DPP becomes a key source of verifiable data.December 2027: Forced Labour Regulation
The Forced Labour Regulation becomes fully applicable. What this means: Supply chain traceability isn’t just a DPP requirement—it’s a market access requirement. Products made with forced labor are banned from the EU market.July 2030: Destruction ban extends to medium enterprises
Ban on destruction of unsold textiles extends to medium-sized enterprises. What this means: More brands will need product-level tracking and data systems.Expected dates
These dates are based on strong consensus across EU institutions, law firms, and industry sources, but are not yet locked in legislation.Late 2026 to Q2 2027: Textile delegated act adopted
The textile-specific delegated act is expected to be adopted between late 2026 and Q2 2027.This delegated act will define the exact data fields required in textile DPPs, technical standards for implementation, and the mandatory compliance date.
Mid-2028: Mandatory DPPs for new textile products
Based on 18 months after the expected delegated act adoption, mandatory DPPs for new textile products are expected around mid-2028. What this means: Every new textile product entering the EU market after this date will need a compliant Digital Product Passport.What brands should do when
Compliance isn’t something you start 18 months before the deadline. Fashion production lead times and data infrastructure requirements mean you need to act earlier.Now through late 2026: Run a pilot
Use the time before the delegated act to test your DPP implementation.Actions:
- Pick 5-10 representative products from your current or upcoming collection
- Map the data you already have (materials, suppliers, certifications)
- Generate test passports to identify data gaps
- Work with suppliers to fill missing information
- Test QR code integration on sample labels
When delegated act is published (late 2026-Q2 2027): Move to production
Once the exact data requirements are finalized, transition from pilot to full implementation.Actions:
- Review delegated act requirements and adjust data collection as needed
- Integrate DPP system with PLM, ERP, and e-commerce platforms
- Generate QR codes for upcoming collections
- Update label specifications for factory production
- Train teams on new data requirements and workflows
9-10 months before deadline: Labels in production
Care labels with DPP QR codes need to be finalized and ordered.Actions:
- Finalize QR code placement on care label designs
- Submit label artwork to trim suppliers
- Place bulk orders for DPP-ready labels
Compliance deadline (mid-2028): All new products have DPPs
Every new textile product entering the EU market must have a compliant DPP.Actions:
- Ensure all products in production include DPP QR codes on care labels
- Monitor regulatory guidance for any technical updates
- Maintain and update passport data as products evolve
Production lead time considerations
Fashion production timelines significantly affect when you need to act:12-18 months before market entry
12-18 months before market entry
Design and development phase
- Initial product concepts
- Material selection and sourcing
- This is when you should be thinking about DPP data collection
6-10 months before market entry
6-10 months before market entry
Pre-production and sampling
- Tech packs finalized
- Care labels and trims specifications locked
- Samples produced and approved
- DPP QR codes must be ready for label production at this stage
3-6 months before market entry
3-6 months before market entry
Bulk production
- Factory manufacturing
- Labels already printed and attached during production
- Too late to add DPP QR codes at this stage
Market entry
Market entry
Product launch
- Products available for sale
- DPP must be accessible via QR code
- Data must be hosted and maintained
Post-2028: Evolving requirements
The DPP framework is designed to expand over time. Brands should expect:2028-2030
- Expanded data fields: Additional requirements based on learnings from initial implementation
- Broader stakeholder access: More parties (recyclers, resale platforms, consumers) accessing DPP data
- Integration with other systems: Connections between DPP and customs, EPR schemes, recycling infrastructure
2030 and beyond
The EU Textile Strategy sets 2030 as the target year for all textile products on the EU market to be:- Long-lived and durable
- Recyclable by design
- Made substantially from recycled fibers
The DPP isn’t a one-time compliance project. It’s an evolving product data infrastructure that will grow more comprehensive over time.
Why starting early matters
Waiting until the delegated act is published to start working on DPP compliance leaves very little margin: Scenario 1: Start now (pilot phase)- You identify data gaps early
- Suppliers have time to provide missing information
- You test QR code integration without pressure
- When delegated act drops, you adjust and scale what’s already working
- You’re ready to generate production QR codes within weeks
- You’re building data infrastructure from scratch under deadline
- Supplier engagement happens under time pressure
- Integration projects compete with ongoing collection development
- You risk missing the window for label production
- You may need to delay product launches or risk non-compliance
Running a pilot now doesn’t require a months-long project. Pick a few products, generate test passports, and identify what data you’re missing. That’s enough to make full implementation straightforward when the time comes.
How Avelero accelerates implementation
Avelero is designed for brands that need to move quickly:- Fast setup: Connect your product data and start generating passports in days, not months
- No six-month integration projects: Works with existing systems (Shopify, PLM, ERP) or direct uploads
- Built-in environmental impact calculation: No need for separate LCA subscriptions
- Pilot-friendly: Start small, scale when ready
- Compliance-ready: Designed around expected ESPR requirements