A T-shirt from your current collection: sewn in Portugal, from a fabric woven in Turkey, from cotton whose origin nobody in your company can name any more. The product passport asks for exactly that field. And for the dye, the water use of the dye house and the working conditions in the spinning mill.
No sector in our industries reference will be as comprehensively affected by the ESPR as textiles. From 2029, most likely, every garment that comes onto the EU market carries a passport with data on fibre, dye, water and energy use, recycling options and the social conditions of manufacture. This article explains where that data sits, why the usual routes do not deliver it, which route does and what you should start in 2026.
The basis is the 2022 EU textiles strategy, which 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 2029 at the earliest.
The real problem: you do not know your supply chain
The industry counts its supply chain in tiers: tier 1 is the assembler that sews, tier 2 the weaver or knitter, tier 3 the spinning mill, tier 4 the cotton farm. Most fashion brands see as far as the assembler. Perhaps they also know the weaver. The spinning mill? The 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 the assembler to pass on the data of the weaver and the spinning mill”
The most pragmatic route. Many assemblers 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 spinning mill individually.
The remaining 20 to 30 per cent are hard going - cotton fields without IT, dye houses with local bookkeeping systems. Associations and industry alliances 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 amended Waste Framework Directive has already introduced mandatory extended producer responsibility for textiles (EPR); the national schemes have to be in place by 17 April 2028. France, the Netherlands and Sweden already have national schemes. The DPP will be the technical basis for it. Modular design, mono-material and longevity become cheaper.
The classification in the DPP determines the EPR fee.
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 assemblers, with their weavers’ data where available, into one uniform structure. An Excel export from your existing system is enough as a starting point.
- Pilot with one collection: take a small special 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 2029 needs the lead time - negotiating the data structure of a single supplier takes 6 to 12 months in practice.
Everything the regulation asks of textile brands, with the timeline, the roles, the required data, the official documents, is in our reference on the Digital Product Passport for textiles.
Questions on this article
When exactly does the passport become mandatory for textiles?
No date is fixed. The duty arrives with the ESPR delegated act for textiles and apparel, which the Commission working plan puts in the fourth quarter of 2027 and itself calls indicative; a draft is expected earlier. Art. 4(4) of the ESPR then requires at least 18 months between that act entering into force and its application, which is why 2029 is the earliest realistic year. Anyone naming a firm month today is guessing. Plan for the data, not for the date.
Does the duty apply to importers too?
Yes. It attaches to placing on the market, not to manufacturing (Art. 9 ESPR). Whoever brings a garment into the EU from a third country places it on the market and has to make sure the passport exists and its content is correct. In practice either your supplier delivers the data or you collect it yourself, and both need a clause in the purchasing contract. Those clauses renew on their own cycle, which is exactly why starting before the act is final pays off.
Do GOTS, OEKO-TEX or a similar certificate cover the requirement?
No. The ESPR does not recognise certificates as a substitute for structured data - they are an input to the passport, not the passport. Each scheme also covers only part of the chain, GOTS for instance the material chain rather than assembly. Use them as evidence behind a field and keep the field itself as data you can export, translate and put in front of an authority.
How far up the supply chain do I really have to go?
Far enough to fill the fields, which is deeper than most brands can see today. Raw-material origin, dye chemistry and water use sit two or three tiers above the sewing factory. The pragmatic route is contractual - oblige tier 1 to pass on the data from tier 2 and tier 3 in an agreed structure, which typically reaches 70 to 80 per cent coverage without writing to every spinning mill individually. The remaining 20 to 30 per cent, cotton fields without IT and dye houses on local bookkeeping, is where consortia and industry associations help.
What is the difference between the passport and the EPR obligation?
Two separate duties with separate deadlines. Extended producer responsibility makes you pay for the collection and treatment of what you put on a national market, and the schemes have to be in place by 17 April 2028 under Art. 22a of the amended Waste Framework Directive. The passport requires you to publish data about the product and arrives with the ESPR delegated act. The good news is that both draw on the same product data, and the categorisation that determines the fee is the one the passport carries.
Are shoes and home textiles in scope?
Two scopes overlap here. Regulation (EU) No 1007/2011 defines textile products for labelling by fibre content, while the extended producer responsibility of the amended Waste Framework Directive covers the textile, textile-related and footwear products listed in its annex, which is why shoes are in. The ESPR delegated act draws its own scope, and until it is published nobody can tell you with certainty whether a particular accessory is in or out. Building the data for a product that later turns out to be out of scope costs far less than the reverse.
Does the fibre composition label disappear?
No. It stays mandatory and physical under Regulation (EU) No 1007/2011. The passport adds the machine-readable depth the label has no room for, such as origin and finishing per component, and the working plan states that the ESPR information requirements are to be designed in synergy with the labelling regulation, which is itself under review. Expect one data source feeding both, not two parallel truths.
What should a brand actually do in 2026?
Three things that do not depend on the final text. Bring your tier-1 suppliers, with tier-2 data where you have it, into one uniform schema; an export from your existing system is a good enough starting point. Build one complete passport for a single collection with real rather than estimated data, because that is what surfaces the gaps. And work through the EPR fee for a mono-material version and a mixed-fabric version of the same product, which creates advocates outside the compliance department. Negotiating the data structure with a single supplier takes six to twelve months in practice, and that is the clock that matters.
