Digital product passports: what suppliers will be asked for

What a digital product passport is

The European Commission describes the digital product passport (DPP) as a digital container for information about a product, its parts and its materials. It brings together facts that help with repair, recycling and checking that the product follows the law.

Each passport is linked to the physical product through a data carrier, such as a QR code. Scanning it opens the information that the person scanning is allowed to see. A shopper might see repair tips and material content. A recycler might see how to take the product apart. A market inspector might see compliance documents.

The passport is tied to a unique product identifier. Depending on the product rules, it can describe a whole model, a production batch or each single item.

The law behind it

The main legal basis is Regulation (EU) 2024/1781, the EU's ecodesign regulation, often shortened to ESPR. It was adopted on 13 June 2024 and published in the Official Journal on 28 June 2024.

ESPR is a framework. It does not set rules for any product on its own. Instead, the Commission adopts a separate delegated act for each product group, which sets that group's design rules and decides exactly what its passport must hold. Until the act for your product exists, there is no passport duty for it under ESPR.

Other EU laws can also require passports. The Commission's DPP page names, among others, the Batteries Regulation, the Packaging and Packaging Waste Regulation and the Toy Safety Regulation. For packaging suppliers, that means passport rules may come from packaging law as well as from ESPR.

Which products come first

ESPR required the Commission to adopt its first working plan by 19 April 2025. The Commission adopted the plan for 2025 to 2030 in April 2025. Its priority products are:

• Steel and aluminium
• Textiles, with a focus on apparel
• Furniture
• Tyres
• Mattresses
• A number of energy-related products

When the textile rules are planned

The Commission's DPP pages give an indicative timeline. For textiles, the delegated act is planned for 2027: the main DPP page lists it for Q3 to Q4 2027, and the textile apparel page says Q4 2027. The same act will set the passport requirements for clothing.

These are plans, not deadlines. The Commission says the timeline may change as legislative and technical work goes on. It also says that once a delegated act is adopted, companies will have a transition period of at least 18 months before it applies.

Footwear is not named as a priority group on the Commission pages we read. Do not assume a date for shoes until the Commission publishes one.

The registry

ESPR told the Commission to set up a central digital product passport registry by 19 July 2026. The Commission's DPP page says the registry became operational on 20 July 2026, starting with a testing environment.

The registry does not hold the whole passport. It stores the product's unique identifier and a set of registration data, so that customs and inspectors can check that a passport exists. The Commission notes that imported products can be checked at customs against it.

What data a passport may hold

Annex III of ESPR lists the kinds of information a passport can include. Each delegated act picks from this list for its product group. In plain terms:

• Identifiers: the unique product identifier and, where relevant, a GTIN barcode number.
• Customs codes, such as the TARIC commodity code.
• Compliance documents, such as the declaration of conformity and technical documentation.
• Instructions and safety information required by other EU law.
• Who made it: the manufacturer and its unique operator identifier, and identifiers for other operators.
• Where it was made: unique facility identifiers for the sites involved.
• The importer, including its EORI customs number.
• Product information set by the delegated act, which ESPR says can include performance on parameters such as durability, recycled content and carbon footprint.
• Substances of concern: their names, where they sit in the product and in what concentration.

What the textile passport is likely to cover

The Commission's textile apparel page lists the kind of information under discussion: product identification, fibre composition, use and repair guidance, end-of-life information, origin and the identity of the companies involved. It stresses that the exact requirements will be set later in the delegated act.

A study by the Commission's Joint Research Centre supports this work. Until the act is adopted, nobody can tell you the final list of fields for a garment passport.

Where suppliers fit

The Commission says passport duties fall mainly on the economic operator that places the product on the EU market, such as the manufacturer, brand or importer. Shops and distributors must make sure a passport is available.

If you are an Indian garment, footwear or packaging maker selling to an EU brand, you will probably not hold the legal duty. But the brand cannot fill in the passport without you. Expect to be asked for:

• Bills of materials per style: fibres, fabrics, trims and their weights.
• Facility details for your own sites and, often, your fabric mills and dye houses.
• Origin data for key materials.
• Chemical information, including any substances of concern.
• Care, repair and end-of-life facts you know as the maker.
• A carbon footprint per product, if the delegated act or the brand asks for one.

Carbon footprint in the passport

ESPR defines a product's carbon footprint as the total greenhouse gas emissions and removals of the product system, expressed in CO₂ equivalent, based on a life cycle assessment of climate change only. It lets each delegated act decide whether carbon footprint information is required and which method to use.

For textiles, that method has not yet been set. What you can do now is build footprints on a recognised basis. ISO 14067 is the international standard for product carbon footprints, and the PACT data file is a common format for sharing them with buyers. Neither is named in ESPR, so treat them as good preparation rather than a guarantee of what the textile act will require.

Buyers often shorten product carbon footprint to PCF. Our guides on what a product carbon footprint is and how to calculate one explain the basics.

A related rule: unsold clothes and shoes

ESPR also bans destroying certain unsold consumer products. Annex VII lists apparel and clothing accessories and footwear. The ban applies from 19 July 2026, with medium-sized companies covered from 19 July 2030 and micro and small companies exempt. This duty sits with the brands and retailers, but it adds to the pressure on them to know exactly what each product is made of.

Timeline at a glance

Dates marked as planned or indicative come from the Commission's own pages and can move. Legal dates come from the text of Regulation (EU) 2024/1781.

• 28 June 2024: ESPR published in the Official Journal.
• April 2025: the Commission adopts the 2025 to 2030 working plan, with textiles (apparel) among the priorities.
• 19 July 2026: the ban on destroying unsold apparel and footwear starts to apply, for large companies (micro and small companies are exempt).
• 20 July 2026: the Commission says the DPP registry is operational, with a testing environment.
• 2027 (Q3 to Q4, indicative): planned adoption of the textile delegated act, including passport rules.
• At least 18 months later: the textile rules start to apply, according to the Commission.
• 19 July 2030: the unsold-products ban extends to medium-sized companies.

Common misunderstandings

Getting these points straight early helps you answer brand questions without over-promising, and without spending money on systems before the rules for your product are known.

• "Every product needs a passport now." No. A passport is needed only once a delegated act for that product group applies.
• "The passport is just a QR code." The code is only the data carrier. The passport is the data behind it, which must stay available and up to date.
• "Suppliers will have to register every product." The duty sits mainly with the company placing the product on the EU market. Suppliers mostly provide data to it.
• "The registry holds all the product data." It holds identifiers and registration data. The full passport sits with the company or a passport service provider.
• "A carbon footprint will be required for every garment." That depends on the textile delegated act, which has not been adopted yet.

What to prepare now

None of this is wasted if the final rules change, because brands are already asking for the same data in their supplier requests; see how to answer a customer carbon footprint request.

This guide explains the rules in plain words. It is not legal advice; check the delegated act for your product and talk to your buyer about what they need.

• Organise product data by style. One clean record per product, with materials, weights, suppliers and sites, is the core of any passport.
• Give each site an identity. Keep legal names, addresses and any registered identifiers for every factory you use.
• Ask your own suppliers early. Fibre origin and chemical data sit with mills and dye houses; see primary vs secondary data.
• Start carbon footprints now. A footprint per product answers today's buyer requests and gives you data for a passport later. Try our analyser or upload a product list.
• Keep sources. Record every emission factor and data source so a brand can trace the numbers.
• Watch the textile act. Follow the Commission's DPP pages and our compliance overview for the adoption date.

Questions