Among the product groups the EU has lined up for a Digital Product Passport, textiles come first. The ESPR working plan for 2025-2030 puts apparel at the top of the priority list, which means fashion brands are likely to face a passport obligation before most other sectors. The exact requirements will arrive through a delegated act specific to textiles; this article sets out what is reasonably established today and what brands can start on without waiting for the final text.
Why textiles are first
The choice is not arbitrary. Textiles are a high-volume, high-impact category with a long and often opaque supply chain, which is exactly what the Digital Product Passport is designed to address. The 2022 EU Strategy for Sustainable and Circular Textiles already signalled the direction, and the ESPR turns it into a concrete instrument. A delegated act for textiles is expected to follow the regulation's framework, with application likely from 2027 onwards — a date to treat as planning guidance rather than a fixed commitment, since it has not been set in law.
The data a textile passport is likely to carry
The precise field list belongs to the delegated act and is not final, so this is the expected shape rather than a definitive specification. Based on the ESPR framework and the strategy behind it, a textile passport is likely to cover fibre composition; the share of recycled content; durability and care information; reparability and the availability of services or spare parts where relevant; recyclability and end-of-life guidance; the presence of substances of concern; and traceability of the main production steps and the operators involved.
Microplastics shedding and the environmental footprint of production are under active discussion and may appear in some form. The sensible reading is to structure the data you already control — composition, origin, suppliers — cleanly per product, so that adding regulated fields later is a matter of mapping rather than rebuilding.
It does not stand alone
The passport sits alongside other obligations a fashion brand is already meeting or will soon. The revised Waste Framework Directive introduces extended producer responsibility for textiles across the EU, which makes per-product data on composition and recyclability useful well beyond the passport itself. Rules on environmental claims push in the same direction: a claim is easier to defend when the underlying product data is structured and verifiable. The passport is best seen as the place this information converges, not as a separate compliance silo.
Authenticity and compliance on one carrier
Fashion is also one of the sectors most exposed to counterfeiting, and this is where a passport and an authentication seal reinforce each other. A QR code can carry the passport identifier and serve the regulated information. A cryptographic NFC tag can carry the same identifier while also proving, on each tap, that the item is genuine and not a copy. For a brand that needs both to satisfy the regulation and to protect against counterfeits, putting both functions on a single carrier avoids running two parallel systems on the same garment.
What to do before the act lands
The useful work is data work, and it can start now. Get product composition and supplier information into a structured form, organised per SKU rather than per collection. Decide how each item will carry its identifier — a printed QR code, a sewn-in NFC label, or both for higher-value lines — and make sure the destination it resolves to will stay reachable for years. When the textile delegated act is published, the regulated fields then drop into a structure that already exists, and the deadline becomes an update rather than a project.
Mapping out a passport for an apparel range? We can look at your data and your carrier options together. Get in touch.
