The Digital Product Passport for textiles
ESPR is in force as the framework; the textile delegated act will fix the fields, the products and the date.
Regulation (EU) 2024/1781, Chapter III
Delegated act expected in 2027. Compliance realistically from 2028 to 2029.
The Ecodesign for Sustainable Products Regulation entered into force in July 2024. It is a framework: the textile-specific passport requirements are set separately, in a delegated act expected in 2027, and apply 18 months after that act enters into force. Until then every field list, including ours, is a forecast.
Three dates people mix up
- The EU registry that resolves passport identifiers went live for testing in July 2026. It stores identifiers, not product data.
- The textile delegated act is expected in 2027. It fixes which data fields a textile passport must carry, for which products, and from when. This is the date people quote when they say "required from 2027"; it is the adoption date, not the compliance date.
- Compliance follows 18 months after the act enters into force, which is why it is realistically from 2028 to 2029. If the act slips, compliance slips with it.
What the Commission's researchers propose (JRC study, May 2026)
- Fibre composition by approved fibre name and share of weight, the same data as the physical label, in machine-readable form.
- Producer identification: the economic operator responsible for the product on the EU market and the facilities involved.
- Substances of concern, at least those a recycler needs to know about.
- A robustness score and a recyclability score, each from 0 to 10, at model level, as disclosures rather than minimum thresholds.
- A manufacturing-stage footprint, with the method still under discussion.
- Repair information at model level, described as voluntary in the study.
- The study is preparatory. Its lists can change before the act, and anyone quoting an exact number of fields is quoting a proposal.
Identifiers and carriers
- ESPR asks for a persistent unique identifier per product and a data carrier on the product. It does not name a specific scheme.
- The first European standards for passports (identifiers, carriers, data exchange, access rights) were published in May 2026; six of them carry a presumption of conformity.
- GS1 Digital Link is the identifier form the standards and the registry point to in practice, which is why Seamdex uses it. It is compatible with the rules, not mandated by them.
The brand placing the product on the EU market owns the passport. Where a manufacturer outside the EU has not created one, or the product sells under the brand's own name, the brand must make sure a passport exists and is accurate before the product enters the market. The passport must stay reachable for the product's useful life; the exact period will be set in the act.
How the other rules connect to the passport
| Rule | Link to the passport | What it means in practice |
|---|---|---|
| Textile EPR | Direct | Composition, weight and recyclability attributes feed eco-modulated fees. One record serves both. |
| Textile labelling | Direct | The fibre composition on the label and in the passport must be the same data. |
| Green claims | Direct | Specific, verifiable product data is what a claim will have to point to. |
| Packaging (PPWR) | Direct | Packaging materials and weights sit next to the garment in the same record. |
| Substances of concern | Direct | The passport is the disclosure channel the study proposes for substances recyclers must know about. |
| Unsold goods ban | Indirect | The ban asks for disclosure of what was discarded; a passport per size makes counting trivial. |
What to prepare this season
- Structure the data every version of the rules will ask for: composition, weights, origin, substances and care, per style and size.
- Give every product a GTIN owned by your brand; the passport identifier hangs off it.
- Collect supplier data now. Most of what a passport needs sits with the factory, the mill and the certifier, not in your ERP.
- Treat the delegated act date as a planning date, not a legal one, and keep your field list ready to change.
One record
What the Seamdex record already carries
- Fibre composition per layer with certificates, weights, recycled content and the two 0 to 10 scores computed from the record.
- Economic operator, assembly factory and supply chain by tier, with a country-only disclosure option.
- A stable identifier and GS1 Digital Link QR per size, frozen at publish.
- Care, packaging and substance statements on the same record.
Built around the data set the Commission's researchers have proposed, updated as the delegated act lands. Not a compliance claim: no one can make one before the act exists.
Questions on this rule
Sources
- Regulation (EU) 2024/1781 (EUR-Lex) checked September 2026
- European Commission, Ecodesign for Sustainable Products Regulation checked September 2026
- JRC, preparatory study on textile products (Digital Product Passport) checked September 2026
Related rules
Regulatory dates last reviewed September 2026. Future dates are expectations, not law. This guide describes the rules; it is not legal advice.