UpcomingProduct levelESPRDirect passport link
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)
- Identifiers at three levels: the model (one GTIN per style, where most fields live), the batch (data that varies per production run) and the item (a serial number per garment, proposed as voluntary at first).
- 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, with an operator identifier such as an EORI number or a GLN, and an identifier for each facility involved.
- Substances of concern, at least those a recycler needs to know about.
- A robustness score and a recyclability score 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.
- Tiered access: the study proposes that composition, scores, care and repair information are public, while substance concentrations, test reports and calculation inputs are restricted to authorities or to actors with a legitimate interest, such as recyclers. The exact tiers are for the act to set.
- 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.
The other rules connect to the passport in two ways. Direct: the obligation is a passport field, so filling it in is the compliance act and the value itself is what gets checked. Indirect: the rule sets no passport field, but the passport shows the materials, origins and facilities behind a product, so a claim or report made elsewhere can be held against it.
How the other rules connect to the passport
| Rule | Link to the passport | What it means in practice |
|---|---|---|
| Textile EPR | Direct | Fees rest on weight and are modulated on ecodesign criteria; composition, weight and recyclability sit in the same record. 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 has 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. |
| Environmental footprint | Direct | A footprint class is proposed as a public passport field; the French environmental cost and the EU method already need the same inputs. |
| Unsold goods ban | Indirect | The ban asks for disclosure of what was discarded; a passport per size makes counting trivial. |
| Forced Labour Regulation | Indirect | Sets no passport field. The origin and facility identifiers a passport carries are the data an authority would hold against its forced labour risk database. |
| Deforestation regulation (EUDR) | Indirect | Sets no passport field, and finished fibres are outside its scope. Raw-material origin in the passport would be the evidence trail if that scope ever widened. |
| CSRD and CSDDD | Indirect | Company-level reporting and due diligence rules that create no passport field. Passport data can feed a report, and a report can be checked against it. |
| Voluntary SME standard (VSME) | Indirect | Sets no passport field. What a brand reports under the standard can be compared with the suppliers and origins its passports show. |
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 a 0 to 10 robustness score and a 0 to 11 recyclability score 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.
FAQ
Questions on this rule
No. ESPR is in force as the framework, but the textile-specific requirements only become binding once the delegated act is adopted, expected in 2027. Compliance is realistically from 2028 to 2029.
No. The regulation asks for a persistent unique identifier and a carrier; the European standards and the registry point to a URL form that GS1 Digital Link provides. It is the practical choice, not a legal requirement.
No. The GS1 Digital Link standard lets any web server answer the link, so a GS1-run resolver is optional. What matters is a GTIN licensed to your brand by your national GS1 member organisation and a well-formed link.
No, and neither can we. The textile act is not adopted. What you can buy today is structured data that every version of the rules will draw on.
Sources
- Regulation (EU) 2024/1781 (EUR-Lex) checked October 2026
- European Commission, implementing the Ecodesign for Sustainable Products Regulation checked October 2026
- JRC, preparatory study on textile products (Digital Product Passport) checked October 2026
Related rules
- Textile producer responsibility in the EU
- Fibre names and the textile label
- Environmental claims on garments and in marketing
- Substances of concern in garments
- The environmental footprint of a garment
- The ban on products made with forced labour
- Corporate reporting and due diligence (CSRD and CSDDD)
- The voluntary sustainability standard for SMEs (VSME)
Regulatory dates last reviewed October 2026. Future dates are expectations, not law. This guide describes the rules; it is not legal advice.
From the blog
Related reading
- 23 September 2026 · Standards, Product dataGS1 Digital Link for fashion brands, and one correctionWhat a Digital Link QR code is, why the same code can serve a till and a customer, and why the claim that the EU mandates it is not accurate.
- 18 September 2026 · Regulation, Product dataTwo scores EU researchers want on every garment passportA robustness score and a recyclability score sit in the preparatory work for the textile passport: how they are built, what moves them.
