Mandatory DPP Legislation EU

The EU is introducing digital product passports gradually, product group by product group. For textiles the obligation is expected around 2029. Get ready easily with us and gain an advantage over the competition.

ESPR legislation

The data for textile passports is being decided right now.

The ESPR has applied since 18 July 2024. For textiles, the Commission is still preparing the delegated act. Adoption is planned for 2027, and the obligation starts at the earliest 18 months after the act enters into force, so around 2029.

H2 2026

consultation on the textile act: the required data set is being decided now

~2029

indicative start of the obligation for textiles; collecting data from suppliers takes whole seasons

●Once the obligation applies, textile products without a DPP may not be placed on the EU market

What is ESPR

Ecodesign for Sustainable Products Regulation

ESPR (Ecodesign for Sustainable Products Regulation) je nařízení Evropské unie, které vstoupilo v platnost 18. července 2024. Jeho cílem je nastavit závazná pravidla pro udržitelnost produktů uváděných na trh EU.

Nařízení pokrývá téměř všechny fyzické produkty - od textilu přes elektroniku po nábytek a stavební materiály. Hlavním nástrojem pro dosažení transparentnosti a cirkularity je digitální produktový pas (DPP).

Pro textilní průmysl má ESPR zásadní dopady: Komise plánuje přijmout delegovaný akt pro textil v roce 2027 a povinnost DPP pro oděvy a textilní výrobky nastane nejdříve 18 měsíců od nabytí účinnosti aktu, tedy orientačně v roce 2029 (podle pracovního plánu Komise COM(2025) 187). Firmy, které splnění legislativy odloží, riskují sankce nebo dokonce zakázání prodeje.

18. 7. 2024

Date ESPR entered into force

2027

Planned adoption of the textile delegated act (ESPR working plan)

~2029

Indicative start of the obligation for textiles, at the earliest 18 months after the act enters into force

190,000

textile companies in the EU must implement DPP

Legislative timeline

What happens when

Legislation arrives gradually through delegated acts. Textiles are among the first categories to be regulated. Other groups follow: furniture around 2028 and electronics around 2028–2029 (indicative, Commission working plan COM(2025) 187). For comparison, the battery passport becomes mandatory on 18 February 2027.

18 Jul 2024

ESPR applies

In force

19 Jul 2026

Ban on destroying unsold clothing and footwear for large companies (small and micro companies are exempt, medium-sized ones later). The EU passport registry is to be set up by the same date.

Applies

2027

Planned adoption of the delegated act for textiles

Textiles!

~2029

Obligation for textiles starts, at the earliest 18 months after the act enters into force (indicative)

Obligation

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What DPP must contain

Requirements for the digital product passport

Final details will be specified in delegated acts, but the core areas are already clear. The DPP must be accessible via a data carrier (e.g. QR code) and contain structured data.

Unique product identifier (GTIN)Globally unique product identifier according to GS1 Digital Link standard

Material compositionDetailed breakdown of fibres and materials with percentage share

Origin and place of manufactureCountry of origin of materials and place of final product manufacturing

Environmental impactCarbon footprint, water footprint according to PEFCR Apparel & Footwear methodology

Care instructionsGuidelines for maintenance, washing, and drying to extend product lifetime

Repairability & durabilityInformation on how to repair the product or where to find spare parts

RecyclabilityGuidelines on how to properly recycle the product at end of life

Substances of concernHazardous substances under REACH that limit recycling or reuse

Value chain traceabilityInformation about suppliers, processors, and manufacturers across the chain

QR code as data carrierPhysical data carrier directly on the product or packaging scannable by mobile phone

Legislative interconnection

DPP, ESPR and EPR - three pillars

The digital product passport is the central element of the entire circular economy ecosystem in the EU.

ESPR

Ecodesign for Sustainable Products Regulation - sets mandatory requirements for product sustainability and circularity

→

DPP

Digital Product Passport - the central tool for ESPR compliance. Contains data on materials, impact, and circular flows

←

EPR

Extended Producer Responsibility - every Member State must have a textile EPR scheme in place by 17 April 2028 at the latest. Fees will be adjusted according to the product's durability, repairability and recyclability

ESPR → DPP

ESPR mandates DPP as a mandatory tool for transparency

DPP → EPR

EPR fees will be adjusted according to product properties. How these properties will be demonstrated has not yet been specified.

EPR → ESPR

EPR incentivises circular design that ESPR requires

Consequences of non-compliance

What happens without DPP

ESPR mandates member states to introduce penalties that must be "effective, proportionate and dissuasive". At minimum, they must include fines and exclusion from public procurement.

Market placement ban

Products without DPP may not be legally sold in the EU from the date the delegated act takes effect

Fines and penalties

Each member state sets its own fines - but at minimum they must be "dissuasive"

Public procurement exclusion

Companies non-compliant with ESPR may be temporarily excluded from public tenders

Důležité: Market surveillance úřady v jednotlivých státech EU budou kontrolovat správnost, úplnost a soulad DPP s legislativou. Produkty budou muset být registrovány v centrálním registru EU před uvedením na trh.

Why start now

Compliance is the minimum. The advantage is starting early.

Companies that implement DPP before the obligation arrives aren't just addressing legislation - they gain a competitive advantage through new data, circular flows, and customer trust.

Less stress when the obligation arrives

Implementing DPP for thousands of products requires time for data collection, team training, and testing. Companies that start today have time to iterate without deadline pressure.

Post-sale product data

The sooner you start collecting data from DPP (scans, returns, circular flows), the better insights you'll have for product development, EPR reporting, and ESG auditing.

Competitive marketing advantage

A DPP with verifiable data on origin and impact is a stronger selling point than any copywriting. Customers pay a premium for transparency.

Preparation for EPR (April 2028)

Every Member State must set up an extended producer responsibility scheme for textiles (Directive (EU) 2025/1892). Fees will be adjusted according to the product's durability, repairability and recyclability. How these properties will be demonstrated has not yet been specified. Each Member State sets its own rates; the scheme must be in place by 17 April 2028 at the latest. Micro-enterprises have until 17 April 2029.

Find out what awaits you and how to prepare.

We'll discuss your situation, answer legislation questions, and show how cyrcID helps meet ESPR with minimal effort.

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Answers to the most common questions about ESPR, DPP, and obligations for textile brands.

Frequently asked questions about legislation

What is ESPR and when did it enter into force?

ESPR (Ecodesign for Sustainable Products Regulation) is an EU regulation that entered into force on 18 July 2024. It sets mandatory requirements for sustainability, circularity, and transparency of products placed on the EU market.

When will DPP be mandatory for textiles?

The Commission plans to adopt the delegated act for textiles in 2027, and the obligation starts at the earliest 18 months after the act enters into force, so around 2029 (Commission working plan COM(2025) 187). These dates are indicative. The required data set is being decided now, and collecting data from suppliers takes whole seasons, so it pays to start well ahead.

Does this apply to small brands and e-shops too?

Yes, ESPR applies to all entities placing products on the EU market - regardless of size. This includes manufacturers, importers, and distributors.

What must the DPP contain?

The DPP must contain a unique product identifier, material composition, environmental impact, care instructions, repairability and recyclability information, supply chain traceability, and a QR code as data carrier.

What are the penalties for non-compliance?

Penalties include a ban on placing products on the EU market, financial fines set by member states, and exclusion from public procurement. Under ESPR, penalties must be "effective, proportionate and dissuasive".

How do DPP, ESPR, and EPR differ?

ESPR is the overarching regulation that sets the rules. DPP is the tool (digital passport) that ESPR requires. EPR (Extended Producer Responsibility) falls under a separate directive, (EU) 2025/1892: every Member State must have a textile EPR scheme in place by 17 April 2028 at the latest. Fees will be adjusted according to the product's durability, repairability and recyclability. How these properties will be demonstrated has not yet been specified.