EU Textile Digital Product Passport Gains Momentum: JRC Publishes Key Study on DPP Data Requirements
2026.08.20
The European Union is steadily advancing its vision for a more transparent and sustainable textile industry. In May 2026, the European Commission's Joint Research Centre (JRC) released the report "Study on DPP Content for Textile Apparel Products under ESPR", providing important technical recommendations for the future implementation of Digital Product Passports (DPPs) in the textile and apparel sector.
As part of the preparation for the Ecodesign for Sustainable Products Regulation (ESPR), the study outlines what information companies may need to collect, manage, and disclose through Digital Product Passports. While the report does not represent the European Commission's final position and remains subject to stakeholder consultation and impact assessments, it offers valuable insight into the likely direction of future EU textile compliance requirements.
For textile and apparel businesses exporting to Europe, understanding these developments is becoming increasingly important.
What Products Could Be Covered?
According to the JRC's recommendations, Digital Product Passports for textiles would apply primarily to finished textile products containing at least 80% textile fibers by weight. Examples include:
- Most apparel products
- Fashion accessories
- Functional sportswear
- Workwear and occupational clothing
The study proposes excluding certain product categories from the initial scope, including:
- Intermediate textile products such as fibers, yarns, and fabrics
- Smart textiles and e-textiles
- Personal Protective Equipment (PPE)
- Medical devices
- Textile products classified as toys
This targeted approach allows regulators to focus first on mainstream consumer textile products while further assessment continues for more complex product categories.
What Information Will the Digital Product Passport Contain?
The report recommends structuring DPP information into four major categories, aligned with Annex III of the ESPR framework.
1. Product Identification and Classification
To ensure traceability and standardization, each product may be required to include:
- Unique product identifiers such as GTIN or SGTIN
- Batch identifiers
- Model identifiers
- Product categories aligned with ESPR and Product Environmental Footprint Category Rules (PEFCR)
- Commodity and customs codes such as HS and TARIC codes
2. Manufacturer and Facility Information
The proposed DPP would also contain detailed information regarding the responsible economic operators and production facilities, including:
- Manufacturer or importer details
- Global Location Number (GLN)
- Information about production facilities and relevant supply chain actors
3. Product Attributes and Environmental Data
One of the most significant components of the DPP relates to sustainability and environmental performance. Suggested data fields include:
- Fiber composition
- Durability information supported by standardized testing
- Information on substances of concern (SoC), including their location and concentration within the product
- Recycled and organic material content
- Chain-of-custody evidence supporting sustainability claims
- Product Environmental Footprint (PEF) data aligned with PEFCR methodologies
- Product care instructions
This level of transparency aims to improve consumer awareness while supporting circular economy objectives.
4. Compliance Documentation
The Digital Product Passport is also expected to serve as a repository for regulatory compliance information, such as:
- EU Declaration of Conformity
- Technical specifications
- Test reports
- Additional certification and conformity assessment documents
Data Granularity: Three Levels of Information
Recognizing the complexity of textile supply chains, the study proposes three levels of DPP data granularity:
Model Level
Products sharing the same design, pattern, and technical characteristics would generally be grouped together under a single model identifier, regardless of color or size variations.
Batch Level
A batch would refer to products manufactured within the same timeframe, facility, and production process. Materials may originate from different raw material batches.
Item Level
The most detailed level of traceability would apply to individual product units.
This layered approach is designed to balance traceability requirements against implementation costs and operational practicality.
Proposed Access Rights
The JRC recommends a role-based access system to ensure sensitive business information is protected while maintaining transparency.
Consumers and the General Public
Users could access:
- Fiber composition
- Product identification information
- Care instructions
- Durability indicators
Stakeholders with Legitimate Business Needs
Authorized parties such as recyclers may be able to access:
- Detailed substance-of-concern information
- Environmental footprint metrics
- Additional technical sustainability data
Authorities and Customs Agencies
Regulatory authorities would have access to the most comprehensive information, including:
- Full conformity documentation
- Certification records
- Environmental footprint calculation parameters
- Supporting technical evidence
Expected Timeline for Implementation
Textiles and apparel have already been identified as a priority product category under the EU's ESPR and Energy Labelling Working Plan 2025-2030.
Current expectations suggest that the European Commission could adopt the final textile delegated act around 2027. Both ecodesign requirements and Digital Product Passport requirements are anticipated to be incorporated within the same legislative framework.
However, the timeline may evolve depending on stakeholder consultations, technical developments, and regulatory impact assessments.
Looking further ahead, the EU may expand DPP requirements beyond apparel to include:
- Home textiles
- Interior textiles
- Additional textile products
- Other consumer product categories
How Should Businesses Prepare?
Although final requirements have not yet been finalized, proactive preparation can help companies reduce compliance risks and avoid costly adjustments later.
Conduct a Data Gap Assessment
Review existing data against the four proposed DPP categories:
- Product identification
- Manufacturer information
- Product sustainability data
- Compliance documentation
Identify missing information and establish plans to close those gaps.
Strengthen Supply Chain Traceability
Develop robust systems for tracking:
- Recycled materials
- Organic materials
- Sustainability certifications
- Chain-of-custody documentation
Enhance Chemical Management Programs
Companies should move beyond identifying substances of concern and establish mechanisms for collecting and sharing information about their concentration and location within products.
Standardize Durability Testing
Evaluate current testing methodologies and compare them against emerging EU expectations. Aligning with international standards can improve readiness.
Improve Product Identification Systems
Assess the organization's ability to implement identifiers such as:
- GTIN
- SGTIN
- GLN
- Batch identifiers
- Item-level identifiers
Establish DPP Data Governance
A successful Digital Product Passport strategy requires clear governance covering:
- Data ownership
- Data verification
- Update procedures
- Access management
- Machine-readable data formats
Monitor Regulatory Developments
Businesses should closely follow upcoming EU consultations, impact assessments, and delegated act proposals to stay ahead of compliance obligations.
Conclusion
The JRC's latest study provides the clearest indication yet of how Digital Product Passports may be implemented in the European textile and apparel sector. While the recommendations are not yet legally binding, they signal a major shift from fragmented sustainability declarations toward a standardized and digitally managed compliance framework.
For brands, manufacturers, importers, and supply chain partners, the message is clear: data transparency, traceability, and sustainability verification are becoming essential requirements for access to the EU market. Companies that begin preparing today will be far better positioned to navigate the future regulatory landscape and gain a competitive advantage in an increasingly transparent global textile industry.
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