What is the ESPR, and when does it affect your brand?

What the ESPR actually is

Regulation (EU) 2024/1781 entered into force in July 2024. It replaced the old Ecodesign Directive, which applied mainly to energy-using products like fridges and washing machines, and extended the same logic to almost every physical product placed on the EU market.

The regulation itself does not say what your T-shirt’s passport must contain. It is a framework. It gives the European Commission the power to set product-specific rules later, through what are called delegated acts — one per product group. Each delegated act decides the mandatory data fields, the access rules, and the date from which the obligation applies.

This structure matters more than any single rule, because it explains why nobody can give you a definitive field list for textiles today. The textile delegated act has not been adopted.

What a Digital Product Passport is

A Digital Product Passport is a structured digital record attached to a specific product, model or batch, reachable through a data carrier — in practice, a QR code printed on the label or hangtag.

Three things distinguish it from a product page on your website:

• It is structured, not free text. The data follows a defined schema so that a recycler’s system, a customs authority’s system and a consumer’s phone can all read the same record and understand it the same way.
• It is role-aware. The regulation distinguishes between data visible to consumers, data visible to economic operators such as retailers and recyclers, and data visible only to market surveillance authorities. A passport that shows everything to everyone does not meet the requirement, however polished it looks.
• It must persist. Passport data has to stay accessible for the product’s useful life plus a period after end of life, set by each delegated act. For a jacket sold in 2029, that could mean keeping the record available into the 2040s. A QR code that stops resolving is a compliance failure on a product that has already left your warehouse.

Who it applies to

The obligation falls on whoever places the product on the EU market. That includes:

• EU manufacturers
• Importers bringing goods into the EU
• Non-EU brands selling into the EU, including online
• Fulfilment service providers in some circumstances

There is no small-business exemption. This is the point most brands get wrong. A forty-person leather goods maker in Italy faces the same passport obligation as a multinational retailer. The regulation says nothing about company size.

What differs is capacity, not duty. A large retailer treats a six-month compliance implementation as a line item. A small brand treats it as the whole year’s budget. That asymmetry is real, but it is not a legal defence.

When this actually applies — the honest timeline

This is where most vendor websites become unreliable, so here are the facts with their sources.

The only binding DPP deadline today is batteries. Regulation (EU) 2023/1542, Article 77, requires a digital battery passport for industrial batteries above 2 kWh, EV batteries and light-means-of-transport batteries placed on the EU market from 18 February 2027. That date is fixed and in force.

For textiles, no date is fixed. On 16 April 2025 the Commission adopted the ESPR and Energy Labelling Working Plan 2025–2030, COM(2025) 187. It names the first product groups and the years in which their delegated acts are expected to be adopted:

Read that table carefully. These are adoption years for the legal act, not compliance dates. Once a delegated act enters into force, it applies at the earliest eighteen months later. For textiles, that puts the realistic compliance date somewhere around 2029 — and it could move.

If a vendor tells you textiles must comply in 2027, they have either misread the Working Plan or are manufacturing urgency. Neither is a good sign in a compliance partner.

So why start now?

Because the deadline that binds you is not the regulation’s. It is your supply chain’s.

Mapping a textile supply chain to the fibre level takes between eighteen months and three years for a brand that has never done it. You have to find out which mill spun the yarn, get a transaction certificate from them, reconcile the quantities against what your garment factory actually received, and then do it again for every season and every new supplier. Suppliers do not respond quickly to requests they have never received before.

Brands that begin data collection in 2026 will have a working system when the act lands. Brands that begin six months before the deadline will be paying emergency consultancy rates for incomplete data.

What a textile passport is likely to contain

The final field list will come from the delegated act. But the groundwork is already public.

The EU-funded Trace4Value pilot project, which built working DPP prototypes with brands including Kappahl and Marimekko, identified around 125 likely data points for textiles. The Joint Research Centre has published a draft specification covering roughly the same ground. Both point in the same direction.

Expect the passport to cover:

• Identification — product identifier, GTIN or equivalent, model, batch, the economic operator responsible, and the facility where it was made.
• Material composition — fibre types and percentages, recycled content share, and where each material originated.
• Supply chain — the production steps from fibre through spinning, weaving or knitting, dyeing and finishing, to assembly, with the country and facility for each.
• Chemicals — substances of concern present above threshold concentrations, and compliance with REACH restrictions.
• Durability and repairability — expected lifetime indicators, repair instructions, spare part availability.
• Environmental footprint — carbon footprint, water use, microplastic shedding, calculated by a prescribed method.
• End of life — recyclability, disassembly instructions, take-back options, and care information that extends product life.
• Certifications — GOTS, GRS, OEKO-TEX and similar, with their scope and validity.

The hardest of these is not the footprint calculation. It is the supply chain, because that data does not exist inside your company. It lives with suppliers who have no system for giving it to you.

Two things that changed in 2026

The central EU registry went live. Commission Implementing Regulation (EU) 2026/1778 laid down the technical rules for a central EU registry of product passports. It opened in July 2026, with battery economic operators as its first mandatory users from February 2027.

This matters when you evaluate software. A platform that generates standalone passport pages is not the same as one that registers identifiers with the central registry. Ask any vendor specifically how they handle registration.

Harmonised standards were published. On 15 July 2026, Commission Implementing Decision (EU) 2026/1736 published six harmonised standards — EN 18216:2026 through EN 18223:2026 — drafted by CEN, CENELEC and ETSI. They cover data exchange protocols, unique identifiers, data carriers, data storage and persistence, APIs and system interoperability.

Under Article 41(2) of the ESPR, conformity with a harmonised standard creates a presumption of conformity with the corresponding legal requirement. In plain terms: if your platform implements these standards, a market surveillance authority is expected to accept that the technical requirements are met.

This gives you a precise question to ask every vendor under evaluation: which of EN 18216 through EN 18223 does your platform implement, and what evidence can you show? A vendor who answers vaguely, or redirects to product features, is telling you where their compliance expertise actually sits.

What happens if you do not comply

The ESPR leaves penalties to each member state, so the specifics vary. The regulation requires them to be effective, proportionate and dissuasive, and names the measures authorities can take:

• Withdrawal of the product from the market
• Prohibition on placing the product on the market
• Financial penalties set at national level
• Exclusion from public procurement for a period

For a brand, the commercial risk usually arrives before the legal one. Retailers and marketplaces will require passports from their suppliers ahead of the deadline, because the retailer carries its own obligation. Losing a wholesale account is faster and more expensive than a fine.

What to do in the next twelve months

1. Count your SKUs and your suppliers. Not an estimate. The actual number of products you place on the EU market, and the actual number of suppliers who touch them. This number determines everything else.
2. Find out how deep you can already see. Most brands know their tier 1 — the factory that assembles the garment. Far fewer know the mill, and almost none know the spinner. Find your edge.
3. Start one supplier request. Pick a single product and ask every supplier in its chain for material data and certificates. What comes back, and how long it takes, tells you more about your readiness than any assessment.
4. Choose a data model, not a QR generator. Generating a QR code is trivial. Holding structured, role-aware, verifiable data for ten years is not. Evaluate on the second.
5. Do not wait for the final field list. The fields will be refined; the underlying data will not change. Fibre origin is fibre origin whether the act calls it one thing or another. Collecting it now is never wasted.

Common questions