No sector will be as comprehensively affected by the ESPR as textiles. The 2022 EU textiles strategy names product durability, recyclability and traceability as non-negotiable. This has flowed into the 2024 ESPR framework (Reg. 2024/1781); at the time of this article the textile-specific delegated act is still being drawn up, with a draft publication expected in Q4/2026 and application from 2028 at the earliest.
From then on every product that comes onto the EU market - a T-shirt, jeans, a leather jacket, a sports shoe - carries a DPP. With data on fibre, dye, water and energy consumption, recycling options and social aspects of manufacture.
The real problem: you do not know your supply chain
Most fashion brands have visibility down to the tier-1 factory - the assembler that sews. Perhaps they also know the tier-2 weaver or knitter. The tier-3 spinning mill? The tier-4 cotton farm? Rarely.
For the ESPR this is a problem. Mandatory fields such as:
- origin of the raw material - cotton from which growing region, which country
- dye chemistry - REACH compliance, freedom from heavy metals, microplastic release during washing
- social standards - minimum wage, no child labour
- water consumption per kilogram of product weight
sit at the start of the chain that you know the least.
Three data strategies we see in projects
1. “We ask every supplier individually”
Works in theory. In practice: your purchasing department has 400 suppliers, each supplier has 5 to 20 sub-suppliers, communication runs in English, Chinese and Hindi. The response rate after three months is below 30 per cent. And the data that does come back is in Excel and inconsistent.
That does not scale.
2. “We rely on certificates”
GOTS, OEKO-TEX, Fair Wear Foundation, Bluesign - there are good certificates. But the ESPR does not recognise certificates as a substitute for structured data. They are an input to the DPP, not the DPP itself. And: depending on the scheme, certificates only cover certain stages (GOTS covers the material chain, not assembly).
3. “We oblige tier-1 to pass on tier-2 and tier-3 data”
The most pragmatic route. Many tier-1 factories already have this data - for their own customers, for audits, for REACH compliance. They have simply not handed it over in structured form. Contractual clauses on passing it on, coupled with a shared data structure, get you to 70 to 80 per cent coverage without writing to every tier-3 individually.
The remaining 20 to 30 per cent are hard going - cotton fields without IT, dye houses with local bookkeeping systems. Consortium approaches help here: Textile Exchange, Microfibre Consortium, national associations.
What has to be turned into the DPP format
The ESPR textile passports consist of three levels. The first is already visible in the draft acts:
- product level - article number, brand, model, size, colour
- component level - fibres and their shares, weights, origin
- process level - dyeing, finishing, energy and water consumption
In addition the “unusual” fields that many brands overlook:
- repairability - replaceable parts, seams, zips
- recyclability - mono-material vs. mixed fabric, separability
- microplastic release rate during washing (test method to follow in the delegated act)
Extended Producer Responsibility - the often overlooked detail
In parallel to the ESPR the EU is working on a revision of the Waste Framework Directive with mandatory Extended Producer Responsibility (EPR) for textiles. France, the Netherlands and Sweden already have national schemes. The DPP will be the technical basis for it: the categorisation in the DPP determines the EPR fee. Modular design, mono-material and longevity become cheaper.
This is not a side issue. For a mid-sized fashion brand with 100 million euros of EU revenue, EPR fees per item are in the cent-to-euro range. Multiplied by five million items per year this produces a recurring cost item.
What you should start in 2026
Do not wait for the final act. Probably 80 per cent of the fields will be identical in the draft version up to Q4/2026 and in the final version. Three concrete steps:
- Structure the supplier register: bring all tier-1, with tier-2 data where available, into a uniform schema. An Excel export from SAP, Odoo or a PLM system is enough as a starting point.
- Pilot with one collection: take a limited-edition line or capsule collection and build a complete DPP for it. With real data, not estimated.
- EPR simulation: work through the fees to be expected in the various scenarios (mono-material vs. mixture). That creates internal advocates outside the compliance department.
Anyone who wants to be ready in 2028 needs the lead time - negotiating the data structure of a single supplier takes 6 to 12 months in practice.