What Is the Textile Product Passport?
A textile product passport is a digital record, mandated under the EU's Ecodesign for Sustainable Products Regulation (ESPR), that stores verified data about a garment or textile's composition, origin, carbon footprint, repairability, and recyclability. It links to the physical product via a QR code or RFID tag and remains accessible across the supply chain — from raw fibre to end-of-life sorting facility. The underlying legal framework is ESPR Regulation EU 2024/1781.
That 40-word definition is what most brands need to communicate to senior leadership: not a sustainability label, not a marketing asset, but a compliance infrastructure that the EU will enforce through market access controls. Textiles are among the first ESPR priority categories — the delegated act defining exact requirements is expected between 2025 and 2026, with mandatory compliance following 18 to 36 months after publication.
To understand the full DPP framework that the textile passport sits within, the guide on what is a digital product passport covers the architecture shared across all product categories — batteries, electronics, furniture, and textiles alike.
Regulatory Basis: ESPR and the EU Textile Strategy
The textile product passport does not exist in isolation. It is one instrument within a broader legislative programme targeting the EU textile sector's environmental footprint — an industry responsible for approximately 10% of global carbon emissions, 20% of global wastewater, and the consumption of around 98 million tonnes of non-renewable resources per year according to the European Environment Agency's estimates.
Two regulatory pillars shape the textile DPP obligation:
ESPR Regulation EU 2024/1781
The ESPR regulation, published in the EU Official Journal on 28 June 2024, is the primary legal vehicle. It replaces the Ecodesign Directive 2009/125/EC and expands the framework from energy performance to the full environmental lifecycle of products. Article 9 of ESPR establishes the legal architecture for the digital product passport: mandatory data fields, technical standards for data carriers, access control tiers (consumers, economic operators, market surveillance authorities), and the requirement that passports remain accessible for a product's useful life plus a defined post-end-of-life period.
Crucially, ESPR does not define product-specific requirements within the main text. Those are delegated to the Commission, which publishes delegated acts category by category. For textiles, the Commission's working plan — the Ecodesign Working Plan 2022-2024 — explicitly listed garments and home textiles as a priority product group. The delegated act is under development and expected in the 2025-2026 window.
EU Strategy for Sustainable and Circular Textiles (2022)
Published in March 2022, the EU Textile Strategy set the policy direction that the ESPR delegated act will operationalise. Key targets from the strategy directly map to DPP data fields: all textiles placed on the EU market must be durable, repairable, and recyclable by 2030; fast fashion must become a declining trend; and producers must take responsibility for textile products at end-of-life. The digital product passport is the mechanism through which these targets become verifiable obligations rather than voluntary pledges.
The Extended Producer Responsibility (EPR) framework for textiles — introduced through the revised Waste Framework Directive 2008/98/EC as amended — adds a financial dimension. As textile EPR schemes become mandatory across member states (France, Netherlands, and Sweden are already operational; Germany and Spain are implementing), the DPP becomes the data backbone for calculating producer fees and verifying recyclability claims.
Which Textile Products Are Covered?
The ESPR framework does not restrict the textile DPP to fashion. Coverage is broad and deliberately so — the EU wants to address the full material footprint of the sector, not just the brands with the most visible greenwashing exposure.
Apparel and Footwear
Garments — from T-shirts to outerwear, formal wear to sportswear — represent the core of the initial delegated act's scope. Footwear is expected to be covered under a separate or closely related delegated act. The Commission has been careful in its working documents not to exclude any apparel sub-category: luxury fashion faces the same data obligations as mass market clothing, and workwear is as in-scope as leisurewear.
Home Textiles
Bedding, towels, curtains, upholstery fabrics, and floor coverings are included within the textile DPP scope. This is significant for furniture manufacturers who source textile components — a sofa with a textile seat covering may need a DPP covering both the structural product (potentially under a separate ESPR furniture delegated act) and the textile component.
Technical and Industrial Textiles
Geotextiles, medical textiles, filtration fabrics, and protective clothing fall within the technical textile category. These products often have simpler consumer-facing requirements — end-users are typically industrial operators rather than general consumers — but the supply chain traceability and chemical substance disclosure obligations apply with equal force.
What Is Currently Excluded
Second-hand garments are not required to carry a new DPP, though platforms and resellers may voluntarily link to the original manufacturer's passport. Products placed on the market before the mandatory compliance date are grandfathered under the pre-regulation regime. Very small businesses (micro-enterprises with fewer than 10 employees and under €2 million turnover) may receive exemptions or simplified obligations — the delegated act will specify the SME provisions.
| Product Category | DPP Scope | Key Data Emphasis |
|---|---|---|
| Apparel (all segments) | In scope — priority category | Fibre composition, recyclability, durability score |
| Footwear | In scope (separate or joint delegated act) | Material layers, sole repairability, chemical substances |
| Home textiles (bedding, towels, curtains) | In scope | Fibre origin, wash durability, care instructions |
| Upholstery and floor coverings | In scope | Composition, recyclability route, fire-retardant substances |
| Technical and industrial textiles | In scope (simplified consumer layer) | Chemical substances, composition, traceability |
| Second-hand garments | Out of scope (voluntary DPP linkage possible) | — |
| Food-contact textiles | Food regulation takes precedence | — |
Required Data Points: What Goes Into a Textile DPP?
The Commission's preparatory study for the ESPR textile delegated act — published by the Joint Research Centre — outlines the data categories that the mandatory DPP is expected to cover. These are not final until the delegated act is published, but the JRC analysis has proven reliable for anticipating regulatory direction in other ESPR categories like batteries and electronics.
Fibre Composition and Material Origin
The percentage composition of each fibre type — cotton, polyester, elastane, wool, lyocell, and so on — must be declared at the same level of precision required under the EU Textile Regulation 1007/2011 (which already mandates fibre labelling). The DPP adds a verification layer that simple labelling lacks: the data must be traceable to certified supplier declarations, not just brand self-attestation.
For natural fibres, geographic origin of cultivation or rearing must be disclosed. For synthetic fibres, the feedstock origin (virgin fossil-based versus recycled content) must be specified with percentage precision. Recycled content claims are among the most scrutinised because they directly affect recyclability scores and consumer-facing sustainability claims.
Country of Manufacturing and Supply Chain Tier Disclosure
The country where each major manufacturing step took place — fibre production, spinning, weaving or knitting, dyeing and finishing, cutting and sewing, final assembly — must be recorded. Full supply chain transparency to tier 4 is the direction the Commission's working documents point toward, though the initial delegated act may phase in requirements by tier over time.
This is the data point that creates the most internal complexity for fashion brands. Most companies have reasonable visibility to their tier 1 cut-and-sew suppliers. Tier 2 (fabric mills) is patchier. Tier 3 (yarn spinners) and tier 4 (fibre producers) are genuinely unknown territory for many brands, including large ones. Building that data infrastructure is not a six-month project — it is why compliance teams who have studied ESPR closely suggest starting now rather than waiting for the delegated act to be published.
Durability and Repairability Scores
Standardised durability testing — abrasion resistance, pilling resistance, colourfastness, seam strength — must be expressed as comparable scores under harmonised test methods. The Commission is working with CEN (European Committee for Standardisation) to define the testing standards that will underpin these scores. Repairability assessment includes the availability of spare components (buttons, zips, patches), the accessibility of repair instructions, and whether the garment construction allows practical repair without specialist equipment.
High durability scores are not just a compliance metric — they are a marketable differentiator. Brands that invest in genuinely durable construction and can prove it through standardised test data are positioned to convert DPP compliance into competitive advantage.
Recyclability Classification and End-of-Life Routing
The recyclability classification must specify what recycling pathway is technically available for the product: mechanical recycling (suitable for single-material or easily separable items), chemical recycling (higher-technology routes for blended fabrics), or downcycling to non-textile uses (insulation, industrial wipers). Blended fabrics — the dominant construction in fast fashion — present the hardest recyclability challenge and are expected to receive lower recyclability classifications under the scoring methodology.
End-of-life routing data must include information on the nearest take-back points and sorting facilities capable of handling the specific product type. This field connects the DPP directly to the EPR system: producers with functioning take-back infrastructure can demonstrate it through the DPP rather than relying on static website claims.
Chemical Substances
Substances of Very High Concern (SVHCs) as defined under REACH Regulation 1907/2006 must be disclosed when present above 0.1% by weight in any article. Textile dyeing and finishing involve extensive chemical use — PFAS, azo dyes, formaldehyde-based crease-resistance treatments — and the DPP will make existing REACH obligations visible to downstream operators including sorters, recyclers, and consumers in a way that current compliance documentation does not.
For recyclers specifically, chemical substance data is operationally critical: a fabric contaminated with certain PFAS compounds cannot enter certain recycling streams without creating regulatory liability for the recycler. The DPP closes an information gap that has structurally impeded textile recycling at scale.
Carbon Footprint
Lifecycle carbon data, expressed in kg CO2 equivalent, covering at minimum cradle-to-gate (raw material extraction through final product manufacture) and ideally cradle-to-grave. The Product Environmental Footprint (PEF) methodology — specifically the PEF Category Rules for apparel and footwear published by the Commission — is the expected calculation standard. PEF-compliant carbon data is significantly more demanding than the carbon footprint figures that brands currently disclose voluntarily, because it requires third-party verified primary data from suppliers rather than industry-average factors.
| Data Category | Specific Fields | Verification Level |
|---|---|---|
| Material composition | Fibre type %, recycled content %, feedstock origin | Supplier declarations, third-party certification |
| Manufacturing geography | Country per production step, tier 1-4 supplier IDs | Audit trail, supplier self-declaration |
| Durability | Abrasion score, pilling score, colourfastness, seam strength | Accredited lab test reports |
| Repairability | Spare part availability, repair instruction access, disassembly index | Brand declaration, verifiable via DPP link |
| Recyclability | Recycling pathway classification, compatible facilities | Technical assessment per CEN standard (pending) |
| Chemical substances | SVHCs above 0.1% per REACH, PFAS declaration | Chemical testing, REACH supply chain communication |
| Carbon footprint | Cradle-to-gate CO2e (kg), PEF methodology | Third-party verified (high-value categories) |
| Care and use | Wash instructions, expected use cycles, microplastic release | Standardised test methods |
Implementation Timeline: When Does This Become Mandatory?
The honest answer to "when is the textile DPP mandatory?" is: not yet fixed in law, but close enough that brands who treat this as a distant future problem are making a strategic error.
The Delegated Act Window: 2025-2026
The Commission's Ecodesign Working Plan prioritised textiles as one of the first categories for delegated act development. The preparatory study was completed in 2023. The stakeholder consultation process ran through 2024. Publication of the textile delegated act is expected in 2025 or 2026 — the exact date depends on the Commission's internal prioritisation and the state of trilogue negotiations on related textile legislation.
Once the delegated act is published in the Official Journal, the compliance clock starts. The ESPR framework gives economic operators a transition period — for textiles, the expected window is 18 to 36 months from delegated act publication. A 2025 publication would mean mandatory compliance arriving in 2027 at the earliest, or 2028 if the transition period runs to 36 months. A 2026 publication shifts that range to 2028-2029.
Why 2027-2028 Is the Working Planning Assumption
Most compliance consultants and industry associations working on ESPR textiles are aligning their clients around a 2027 compliance target for larger enterprises. This reflects the practical reality that building the data infrastructure from scratch — onboarding suppliers to data-sharing systems, commissioning chemical testing, establishing carbon measurement processes, implementing DPP-compatible labelling and IT systems — takes 18 to 24 months even for well-resourced organisations.
SMEs in the textile sector have raised concerns through industry associations about disproportionate compliance costs. The Commission has indicated awareness of this, and the delegated act is expected to include phased or simplified provisions for smaller operators. But "simplified" is not "exempt" — some form of DPP compliance will apply across the sector.
| Milestone | Expected Date | Status |
|---|---|---|
| JRC preparatory study published | 2023 | Complete |
| Stakeholder consultation process | 2023-2024 | Complete |
| Commission delegated act draft published | 2025-2026 | Pending |
| Delegated act enters into force (Official Journal) | 2025-2026 | Pending |
| Transition period (18-36 months) | Post-publication | Pending |
| Mandatory compliance date (large enterprises) | 2027-2028 (expected) | Pending |
| Mandatory compliance date (SMEs) | 2028-2029 (expected) | Pending |
Technical Implementation: QR Codes, Data Carriers, and Registries
The technical requirements for textile DPPs follow the same architecture as other ESPR categories, which is intentional — the Commission wants interoperability across product categories so that single-platform compliance is possible for manufacturers working across multiple sectors.
Data Carriers on Textile Products
For consumer-facing textiles, the QR code is the dominant expected data carrier. It is low-cost to print, works with standard smartphone cameras without a dedicated app, and can be placed on swing tags, care labels, or woven labels sewn into the garment. The data carrier must remain legible throughout the product's expected useful life — a care label that survives 50 washes is more durable than a paper swing tag that a consumer discards at point of sale.
The GS1 Digital Link standard is the recommended encoding approach under ESPR. It encodes a URL directly into the barcode — the URL resolves to different data layers depending on the actor scanning: a consumer sees care instructions and recyclability guidance; a repair technician sees disassembly notes; a recycler sees fibre composition and chemical substance data; a market surveillance inspector sees the complete compliance record. One physical code, multiple data views, controlled by access permissions in the backend system.
RFID and NFC tags are applicable for higher-value garments where the cost of embedding a chip is proportionate to the product value. Luxury fashion brands that already use RFID for inventory management can extend those same tags to serve the DPP function — provided the backend system meets ESPR data storage and accessibility requirements.
Data Storage and Registry Requirements
ESPR requires that DPP data is stored in systems that are reliable, accurate, and accessible for the product's useful life plus a defined post-end-of-life period. For textiles, where useful life may be 5 to 20 years depending on the product, this creates a long-term data stewardship obligation that most brands' current systems were not designed to meet.
Brands have three practical options: build proprietary registry infrastructure (only viable for the largest enterprises), work through industry consortia data platforms (several are under development for the textile sector), or use a purpose-built DPP platform like DPP-Tool that handles the registry, API layer, access control, and data versioning as a managed service. The DPP software comparison guide breaks down the tradeoffs between these approaches across cost, implementation time, and long-term maintenance burden.
Impact on Fashion Brands and Fast Fashion
The textile DPP will affect fashion companies in proportion to how far their current practices are from what the regulation demands. Brands with strong supply chain transparency programs, durable product construction, and low reliance on blended synthetics face a data-gathering challenge that is difficult but manageable. Brands whose business model depends on high-volume, low-price, low-durability production with opaque supply chains face a structural challenge that the DPP merely makes visible.
Fast Fashion's Specific Exposure
The ESPR textile framework was explicitly designed with fast fashion's externalities in mind. Three specific DPP data requirements create direct pressure on the fast fashion model:
First, the durability score. Products that score poorly on standardised durability testing cannot be marketed as sustainable regardless of other claims — the DPP makes the test results part of the public product record. A T-shirt that pills after five washes will have a published pilling resistance score attached to it permanently.
Second, recyclability classification. Blended fabrics — polyester-cotton mixes, polyester-elastane blends, and similar combinations that dominate fast fashion construction — are the hardest textile category to recycle. Under the expected DPP scoring methodology, these products will receive lower recyclability classifications than single-material alternatives, creating visible differentiation at point of sale that current labelling rules do not produce.
Third, supply chain tier disclosure. Fast fashion's commercial model depends partly on maintaining distance between brands and deep-tier manufacturing conditions. The DPP's supply chain traceability requirements create a legal obligation to know and disclose that information — and to verify it, not just self-attest.
Luxury and Premium Segments
Premium and luxury fashion brands are not exempt from textile DPP requirements, but they are better positioned to navigate them. Higher price points typically correlate with better material quality, longer product lifespans, more knowable supply chains, and greater capacity to absorb compliance costs. For luxury brands that have invested in supply chain transparency programmes — partly for ethical sourcing reasons, partly to protect brand reputation — the DPP represents a compliance requirement they are structurally better equipped to meet than mass market competitors.
The strategic opportunity for this segment is to use DPP compliance as a provenance verification tool. A QR code that proves a cashmere sweater's wool came from a specific certified flock in Mongolia, processed at a specific certified mill in Italy, with a documented carbon footprint below sector average, is a storytelling asset as well as a compliance artefact.
Importers and Non-EU Brands
Non-EU brands selling into the European market face identical DPP obligations. ESPR applies based on where a product is placed on the market, not where it is manufactured or where the brand is headquartered. A US, Chinese, or Turkish brand selling garments in the EU must have compliant textile DPPs just as a French or German brand does. The importer of record carries primary legal responsibility where no EU-established responsible person exists.
Supply Chain Transparency Requirements
The textile DPP effectively legislates supply chain transparency obligations that voluntary industry schemes like the Fair Wear Foundation, Better Cotton, and Higg Index have been encouraging on a non-mandatory basis for years. The practical difference is enforcement: ESPR compliance will be checked by national market surveillance authorities with the power to block market access for non-compliant products.
Tier 1 to Tier 4 Data Collection
Collecting supplier data to the depth the textile DPP requires is a data governance challenge that most brands have not previously had to solve. The typical information flow looks like this:
Tier 1 cut-and-sew suppliers know who they buy fabric from (tier 2) but rarely track fibre origin (tier 3) or fibre producer details (tier 4). The DPP requirement pushes brands to change their supplier contracts to mandate data disclosure as a condition of continued business — and to give tier 1 suppliers the systems and incentives to collect data from their own supply chain.
Industry consortia, including those operating under the Sustainable Apparel Coalition's Higg platform and the Fashion for Good initiative, are developing shared supplier data repositories that would allow a supplier to fill in a data profile once and share it across multiple brand relationships. This "enter once, use many" model reduces the per-brand cost of supplier data collection and is the direction the Commission's technical working groups have indicated they would like to see.
Supplier Onboarding Realities
Brands who have started supplier DPP data collection programmes report that the hardest part is not the technology — it is supplier capacity. Tier 2 and tier 3 suppliers in major manufacturing regions often lack the digital infrastructure, English-language regulatory literacy, or internal compliance resources to complete complex data requests without support. Brands that treat supplier onboarding as a pure data extraction exercise tend to get poor-quality data. Those that invest in supplier training, simplified data templates, and joint problem-solving tend to get data that is usable for compliance purposes.
How to Prepare for Textile DPP Compliance
The delegated act is not yet published, which means any preparation programme must be designed to be adaptable as the final requirements crystallise. That uncertainty is not a reason to wait — the preparatory work that creates value regardless of how the final text reads can start immediately.
Step 1: Conduct a Data Gap Assessment
Map what data your organisation currently holds against the expected DPP data categories: fibre composition (probably available), manufacturing geography to tier 1 (usually available), tier 2 and beyond (often gaps), chemical substance declarations (variable), carbon footprint (rarely available to PEF standard), durability test data (sometimes available for technical products, rarely for fashion). The gap assessment tells you where to prioritise collection effort and where you need supplier engagement programmes.
Step 2: Engage Tier 1 Suppliers on DPP Data Commitments
Revise supplier contracts to include DPP data provision as a contractual obligation — ideally before the compliance deadline creates urgency that weakens your negotiating position. The contract clauses should specify data format, update frequency, and the requirement for suppliers to obtain equivalent commitments from their own supply chain. The DPP requirements checklist provides a field-level reference that can be adapted for supplier contract annexes.
Step 3: Select a DPP Technology Platform
Choosing between proprietary build, industry consortium, and third-party platform is a significant technology decision. The evaluation criteria should include: ESPR technical standard compliance (particularly GS1 Digital Link and the data storage requirements under Article 9 of ESPR), data model flexibility to accommodate textile-specific fields, access control granularity, cost per SKU or product model, and the platform's ability to handle the data updates that will be required as supplier data changes. The DPP generation tool at DPP-Tool covers these requirements for textile and other ESPR product categories, with DPP plans scaled from SME to enterprise volumes. For a side-by-side comparison of the main platforms available, see the DPP software comparison.
Step 4: Implement Data Carrier Infrastructure
Work with your label and packaging suppliers to integrate DPP-compatible QR codes into swing tags or care label specifications. For brands already using GS1 barcodes on products, extending to GS1 Digital Link is a relatively contained change to existing processes. For brands without a GS1 registration, obtaining a GS1 company prefix and implementing the Digital Link standard is a prerequisite — the guide on GS1 Digital Link covers the registration and encoding process in detail.
Step 5: Build the Carbon Measurement Programme
PEF-compliant carbon data for textiles requires primary activity data from suppliers — energy consumption at the mill, transport distances, water use — not just industry-average factors. Building that measurement capability takes 12 to 18 months minimum. Start with a representative sample of core products to understand the data collection process and establish supplier cooperation, then scale before the compliance deadline.
For a structured overview of the complete data collection and implementation process, the guide on how to create a DPP provides a step-by-step walkthrough applicable to textile product passports. The battery sector, which faces a 2027 hard deadline, has developed implementation patterns that textile teams can learn from — the EU battery passport guide documents those patterns in detail.
Connection to the Broader ESPR Framework
Textile companies that operate across multiple product categories — a sportswear brand making both garments and footwear, a home goods retailer selling bedding alongside electronics — should be building DPP capability as a shared infrastructure rather than a product-category-specific solution. The ESPR framework is deliberately architected for interoperability: the identifier scheme, data carrier standards, access control layers, and registry requirements are common across all product categories.
A platform that handles textile DPPs should be the same platform that handles footwear DPPs, furniture DPPs, and eventually electronics DPPs as those delegated acts come into force. Building separate systems per product category — or per regulation — creates technical debt that compounds as more categories go live through 2027 to 2030.
The battery sector's experience is instructive. Manufacturers who invested early in ESPR-compatible DPP infrastructure found that their battery passport programme, while technically demanding, shared roughly 60% of its architecture with what they needed for other product categories. Companies that built bespoke battery-only solutions are now facing the cost of either rebuilding or integrating those systems as textile and electronics obligations come into scope.
Frequently Asked Questions
What is a textile product passport?
A textile product passport is a digital data record, mandated by the EU's Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), that stores verified information about a garment or textile's fibre composition, country of manufacturing, carbon footprint, durability, repairability, chemical substances, and recyclability. It is linked to the physical product via a QR code or RFID tag, enabling consumers, repair operators, recyclers, and market authorities to access relevant product data. The textile DPP is not yet mandatory — the specific delegated act is expected in 2025-2026, with mandatory compliance following 18 to 36 months after publication.
When will the textile digital product passport be mandatory?
The textile DPP is not yet mandatory. The European Commission's delegated act specifying exact textile requirements is expected to be published between 2025 and 2026. After publication, the ESPR framework provides a transition period of 18 to 36 months. For large enterprises, mandatory compliance is expected to arrive in 2027-2028; for SMEs, 2028-2029 is the working planning assumption. Companies should treat these as working estimates and monitor the Commission's Ecodesign Working Plan for updates.
What data does a textile product passport require?
The expected textile DPP data requirements include: fibre composition and percentage breakdown; recycled content percentage and feedstock origin; country of manufacturing for each production step; supply chain tier 1-4 supplier disclosure; standardised durability scores (abrasion, pilling, colourfastness); repairability assessment including spare part availability; recyclability classification and compatible end-of-life facilities; chemical substance declarations including SVHCs under REACH; and lifecycle carbon footprint calculated to PEF methodology. The exact fields and verification requirements will be specified in the delegated act when published.
Does the textile product passport apply to fashion brands outside the EU?
Yes. ESPR obligations apply to any product placed on the EU market, regardless of where the brand is headquartered or where the product is manufactured. US, Chinese, Turkish, and other non-EU fashion brands selling garments or textiles in the EU face identical textile DPP requirements as EU-based brands. The importer of record carries primary legal compliance responsibility where no EU-established responsible person exists. Non-EU brands should engage with the ESPR compliance timeline as if they were EU companies — the obligations are the same.
How will the textile DPP affect fast fashion?
The textile DPP creates specific pressure on the fast fashion model in three ways: first, standardised durability testing will produce publicly visible scores that expose products designed for short useful lives; second, blended synthetic fabrics that dominate fast fashion construction will receive lower recyclability classifications under the expected scoring methodology, making recyclability claims harder to sustain; third, supply chain tier disclosure requirements will oblige brands to know and publish information about their deep-tier manufacturing conditions that was previously deliberately obscured. The DPP does not ban fast fashion practices, but it makes the environmental performance gap between durable and disposable products measurable and public.
What is the technical format of a textile product passport?
A textile DPP uses a data carrier on the physical product — typically a QR code on a swing tag or care label — linked to a backend digital registry. The QR code is encoded using the GS1 Digital Link standard, which resolves to different data layers depending on who scans it: consumers see recyclability and care information, repair operators see disassembly data, recyclers see chemical substance and fibre composition data, and market authorities access the complete compliance record. The registry must be hosted in systems meeting ESPR data accessibility and longevity requirements, covering the product's useful life plus a post-end-of-life period defined in the delegated act.
Are SMEs exempt from the textile digital product passport?
SMEs are not expected to be fully exempt from textile DPP requirements, but the delegated act is expected to include simplified obligations or extended transition periods for smaller operators. Micro-enterprises (fewer than 10 employees, under €2 million annual turnover) may receive specific accommodations. Industry associations representing SME textile manufacturers have been active in the consultation process to ensure proportionate implementation. SMEs should monitor the delegated act development and engage with their national competent authorities and industry associations for SME-specific guidance once the text is published.