When Digital Product Passports (DPPs) Apply
Digital Product Passports are not optional. They are a regulatory requirement under the EU Ecodesign for Sustainable Products Regulation (ESPR). For textile and apparel companies selling into the European Union, understanding when a DPP is required and what that means in practice is essential to continued access to the EU market. This page helps you determine whether and when Digital Product Passports apply to your products, without overcomplicating the regulation.
Regulatory Basis: what the law actually says
The European Union’s Ecodesign for Sustainable Products Regulation (ESPR) aims to make products more sustainable and transparent throughout their lifecycle. One of its key mechanisms is the Digital Product Passport.
Under ESPR:
Certain product categories must have a product-level Digital Product Passport when placed on the EU market.
Passports must contain specific data attributes relevant to sustainability, traceability, and circularity.
Passports must be accessible via a machine-readable link (typically QR code) tied to the physical product.
For textiles and apparel, the legislation and delegated acts explicitly include requirements for:
Material composition
Manufacturing and processing stages
Durability, repair, and end-of-life information
Supplier-sourced data (where applicable)
ESPR does not apply only to “big brands”, it applies to any company that places covered products on the EU market, wherever that company is headquartered.
What “placing on the EU market” means
A Digital Product Passport obligation is triggered when a product is placed on the EU market.
This generally means:
The product is sold, imported, or made available to end users within an EU member state.
The product physically enters the EU marketplace (not just held in a warehouse outside the EU).
Online or cross-border sales into the EU count as placing the product on the market.
So even if your business is based outside the EU — for example in the UK, US, or elsewhere — if your textile or apparel products enter the EU market in any way, ESPR requirements apply.
Which products are in scope (textile and apparel guidance)
Not all products are covered immediately or identically. Scope depends on:
A. Product type
Textile and apparel products, such as garments, accessories, and textile goods, fall under ESPR scope as regulatory guidance and delegated acts are phased in.
B. Material composition
Products composed partially or primarily of textile materials are included. Blends and multi-material products are typically covered because they require product-level data for compliance.
C. Timing and phase-in dates
Regulatory requirements are implemented in phases. For example, battery passports became enforceable on January 1, 2026. Textiles and apparel passports are on the regulatory timeline and become mandatory based on dates set in ESPR and its delegated acts.
Because these timelines can shift and be updated, it’s important to verify the current phase-in dates for textile categories.
Common misunderstandings about scope
“We already have sustainability data, so we’re compliant.”
General sustainability reporting or supplier certificates do not substitute for a Digital Product Passport unless they are structured at product level and meet ESPR data requirements.
“Our internal system can serve as our passport.”
Internal dashboards or compliance views are not passports in themselves. A Digital Product Passport must be accessible externally via a persistent link tied to the product.
“Only large brands need this.”
ESPR is size-agnostic. Obligations apply based on where the product is sold, not who sells it.
What level of data is required
A Digital Product Passport must present information at the product (SKU) level, not just the brand or material level.
This means:
Each distinct product version needs its own passport
Material composition must be expressed clearly and traceably
Provenance and process information must be attributable to sources
Durability, repair, recycling, and end-of-life data must be included where required
This level of granularity is what inspectors, retailers, and regulators evaluate in practice.
Why “early clarity” matters
Digital Product Passports are tied to regulatory readiness, not marketing.
This means:
Compliance requirements are enforceable
Products without a passport can be denied market placement
Retailers and distributors increasingly require passport visibility
While many organisations only begin preparing when enforcement looms, early clarity allows you to:
Understand obligations before timelines tighten
Identify supplier data gaps early
Build structured processes instead of reactive fixes
Avoid last-minute cost and resourcing spikes
Businesses that start early can integrate compliance into existing product and supply chain workflows, reducing operational disruption.
In practice, this leads to smoother market continuity and fewer surprises when requirements are enforced.
Summary: do you need a Digital Product Passport?
You will need a Digital Product Passport if:
You sell textile or apparel products into the EU
You place products on the EU market in any form
Your products have material and process attributes included in ESPR
You want to avoid disruption as enforcement becomes active
If you are uncertain about whether specific products are in scope, or what that means for your business, a readiness discussion can clarify based on your products and supply chain.