EU Digital Product Passport explained: ESPR rules, timeline and what it means for fashion

Most fashion brands think the Digital Product Passport is a 2028 problem. Technically, they’re right. In practice, the brands that wait until 2028 are the ones who will be scrambling to retrofit their entire supply chain documentation in 12 months. The ones preparing now will barely notice the transition.

Here’s what the EU Digital Product Passport actually requires.

What is the EU Digital Product Passport?

The Digital Product Passport (DPP) is a digital record linked to a physical product, accessible via a QR code, NFC chip, or RFID tag. Think of it as a product’s official biography: where it was made, what it’s made of, how it performed against environmental benchmarks, and what should happen to it at the end of life.

The Digital Product Passport (DPP) was formally introduced under the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, published in June 2024 and in force since July 2024 . The goal is to make product information transparent and consistent across the EU market: for consumers, authorities, and business buyers alike.

Why the DPP Is a framework, not yet a requirement for textiles

The Digital Product Passports are a requirement under the Ecodesign for Sustainable Products Regulation (ESPR), which is a framework regulation by the European Commission.This framework also covers legislation for Extended Producer Responsibility (EPR) and the prohibition of destroying unsold products. For every specific product category, a delegated act will be adopted, this is a secondary piece of legislation that defines what data a DPP must contain for a given product category. For textiles, footwear, and accessories, the delegated acts are still in the making (written 21 april 2026. We will update this content as soon as the delegated acts are final). 

As of April 2026:

• The ESPR Working Plan (2025 – 2030) sets an indicative timeline of 2027 for the delegated act regarding textiles, apparel, and fashion accessories.
• Once adopted, delegated acts will legally apply 18 months after entry into force, meaning mandatory compliance for textiles is realistically 2027 – 2028. While this seems long this also means slow fashion designers creating products that will be rotating in stores in 2 – 3 years should already add them to their productions.
• Footwear is assessed separately; a Commission study on footwear is expected by end-2027.

Preparation for compliance is strongly advised. Now is the moment to understand the timeline and requirements clearly and act accordingly. This way you can start adjusting at your own pace already and prevent last-minute stress when all companies will need them at once and DPP-supporting teams at the same time. 

Which fashion products will eventually need a DPP?

The ESPR Working Plan identifies textiles and apparel as a priority product group. The exact scope for DPPs will be defined in the delegated act, but current research from the European Parliamentary Research Service (EPRS, 2024) and the 2025 European Commission Textile Preparatory Study points toward a wide remit: covering clothing, fashion accessories like bags, scarves and beanies, as well as home textiles.

Footwear: No delegated act currently; a separate assessment is underway with conclusions expected by end-2027.

Small accessories (textile jewelry or socks): The future textiles act will define the scope in this product category. ESPR does allow flexibility on how the data carrier is presented. It can be either on the product, on the packaging, or in accompanying documentation, specifically for small items where a QR code on the garment itself is impractical.

Second-hand and vintage: Products already on the EU market before a delegated act comes into force are not required to comply retroactively. For new products entering circulation after the obligation date, however, resellers must ensure their customers can access the DPP. This includes online marketplaces and second-hand platforms, not only original brands’ webshops.

There is one foreseeable challenge here worth naming: clothing labels get cut out. In addition, printed ink on care labels always fades, and theycbecome illegible after years of washing. A QR code on a care label that won’t survive a decade of wear, resale, and alteration cannot support a circular economy. The durability and placement of DPP data carriers is a standardisation problem the delegated act still needs to solve and one that brands producing long-lasting clothing are likely to tackle by opting for jacquard-woven polyester labels. At COSH! We’ve interviewed several brand label providers, thus far, none have come forward that can make natural fibre (e.g. cotton) jacquard-itemised QR code labels – which is contradictory to the ecodesign rules for recycling of garments of natural fibre content. This is a shame and a true business opportunity for any industrial engineering student to develop new solutions.

What data will a fashion and textile DPP need to contain?

The exact requirements aren’t officially communicated yet. Based on the ESPR (2024) and the 2025 Commission Textile Preparatory Study, the delegated act is expected to require data across six categories:

• Material composition and weights: fibre content, percentage of recycled or certified inputs
• Key manufacturing processes: dyeing, finishing, country of origin per production stage
• Core environmental indicators: climate impact, water use, energy intensity
• Chemical compliance references: REACH compliance, restricted substances lists
• Basic supply chain traceability: at minimum tier 1 and tier 2 suppliers
• Durability, repairability, and recyclability: repair guides, care and washing instructions, disassembly instructions, end-of-life pathways

If your brand already collects this data internally, DPP compliance will be an integration exercise. If you don’t know your tier 2 suppliers, or if your fibre composition data lives in a spreadsheet nobody has updated since 2021, that’s where the real work starts.

How brands are preparing their DPPs now

Adding DPPs to all your products may not be mandatory yet, but the infrastructure is already being built and the brands that have a leading position on supply chain transparency are finding commercial advantages in the process. They have run pilots and are now starting with definite implementations.

Luxury fashion label Honestby was the first to offer full product transparency and traceability. Niki de Schryver, currently founder of COSH! was business developer and COO of the revolutionary label at the time (2010−2012) and has been named as ​‘the Godmother of DPP’ being the woman behind the scenes of world’s first 100% transparent fashion brand with attention to production, material, and pricing. She is now proudly presenting the COSH! DPP solution available especially for SMEs. 

Patagonia has published detailed material and supplier data for years. Their Worn Wear programme documents repair rates and product longevity. That data architecture maps almost directly onto anticipated DPP requirements.

WOLVIS runs a take-back and resale programme that requires product traceability from the point of first sale through to resale. The operational systems they’ve built are the same ones a functioning DPP depends on at COSH!

Closer to home, several COSH! brands and retailers are already using sustainability data tools that generate the kind of product-level documentation the DPP will eventually require. Getting started doesn’t mean deploying enterprise software in 2024. It means knowing what you make, knowing where it comes from, documenting it and communicating it to your costumers.

Contact COSH! to get started with the COSH! DPP solution for SMEs. 

What should you do now?

For most brands, preparation in 2024 – 2026 looks like this:

1. Audit your product data: do you know your fibre composition by product line, not just by brand? Do you log a country of origin for each production stage?
2. Map your supply chain: identify your tier 1 and tier 2 suppliers and begin formalising those relationships with documentation.
3. Review your unsold goods policy: the destruction ban is active for large companies from July 2026. What is your current end-of-season practice?
4. Assess your data systems: where does your product information live, and can it be linked to individual items?

Starting small is fine. Not starting isn’t.

Do you feel ready? COSH! supports you with the implementation of DPPs across your collections. Getting started with the COSH! DPP solution is easier and more affordable than you think. Contact us to get a free demo, plan a consultancy session, or request your DPPs immediately. 

For smaller brands and retailers specifically, read our guide: How the EU Digital Product Passport Will Affect SMEs, Brands and Retailers

Frequently Asked Questions

Q: Is the EU Digital Product Passport already mandatory for fashion brands? A: DPPs are not yet under inspection and fined in the textile sector. The DPP was established under ESPR (Regulation (EU) 2024/1781) in July 2024, but becomes mandatory only once the European Commission adopts a product-specific delegated act. For textiles, that act is expected around 2027, with mandatory compliance in 2028.

Q: Does the EU Digital Product Passport apply to footwear and small accessories like socks or gloves? A: Footwear is under a separate regulatory assessment with conclusions expected to be communicated by end-2027. The footwear DPP requirements are expected to be defined after the textile act is finalised.
Small accessories fall under the future textiles delegated act, which will define the exact product scope, exemptions, and permitted data carrier placements like packaging.

This article is based on ESPR Regulation (EU) 2024/1781, the ESPR Working Plan 2025 – 2030, the European Parliamentary Research Service (2024), and the European Commission Textile Preparatory Study (2025). Last updated: April 2026.

For questions about DPP readiness for your brand or store, contact COSH! at cosh.eco.