Textiles go first — and for imported apparel, the DPP is your job.

The first ESPR working plan (April 2025) put textiles and apparel at the front of the Digital Product Passport queue. The delegated act for textiles is indicatively expected in 2027, with company obligations biting roughly 18 months later. Most apparel sold in the EU is made outside it — and for imported goods, the obligation to place a compliant product on the market does not stay with the factory in Dhaka or Guangzhou. It lands on the EU importer: you.

In one line: textiles are the flagship first-wave ESPR product group, and when the textile DPP arrives, the importer placing non-EU-made garments on the EU market — including private-label brands — carries the compliance duty, so the data-gathering has to start well before the delegated act does.

Why textiles are first in line

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) entered into force in July 2024, but its DPP obligations phase in product group by product group through delegated acts — there is no single go-live date. The first working plan, published in April 2025, names textiles (apparel) among the priority final products, alongside furniture, mattresses and tyres. The textile delegated act is indicatively expected in 2027, and obligations typically bite around 18 months after a delegated act enters into force — which puts real textile DPP duties indicatively in the late-2020s, close enough that sourcing decisions made this year will still be on shelves when the rules apply.

Imported garments: the duty follows the importer

ESPR obligations attach to the economic operator placing the product on the EU market. For garments manufactured outside the EU, that operator is the EU importer — not the overseas factory. Two situations deserve special attention:

Classic import: you buy finished apparel from a non-EU manufacturer and sell it in the EU. You must ensure a compliant DPP exists, is accurate and stays accessible.
Private label: you sell non-EU-made garments under your own brand. In the eyes of the regulation you step into the manufacturer's shoes and carry manufacturer-level duties — the fullest set of obligations, not a lighter importer subset.

Penalties are set by member states ("effective, proportionate, dissuasive"), customs can detain non-compliant goods, and market withdrawal is possible. The commercial exposure — a container of seasonal stock that cannot clear — is usually the bigger number.

What a textile DPP will likely carry

The exact data fields will be fixed by the delegated act, but the direction of travel is clear from ESPR itself and the preparatory work. Expect a textile DPP to cover:

Fibre composition — what the garment is actually made of, at a finer grain than today's care label.
Recycled content — claimed percentages backed by evidence, not marketing copy.
Chemicals and substances of concern — dyes, finishes and treatments used in production.
Supply-chain information — where and by whom the garment was made, supporting traceability and durability or recyclability claims.

Every one of these is data your suppliers hold today in spec sheets, test reports and declarations — scattered across emails and PDFs in a dozen formats.

Why data readiness starts now, not in 2027

The hard part of a textile DPP is not the QR code — it is assembling verifiable data from a long, non-EU supply chain, garment by garment, season after season. Suppliers change, fabrics change, and every purchase order can change the answers. Importers who wait for the delegated act will be chasing certificates for products already on the water. The sensible sequence: inventory what supplier documentation you already hold, identify the gaps per product line, and build the collection routine into your buying process now. PassPer's AI extraction reads the documents your suppliers already produce and turns them into structured passport data with human review — and a free readiness check shows where your current documentation would fall short.

Frequently asked questions

When exactly will apparel need a Digital Product Passport?

There is no fixed date yet. The textile delegated act under ESPR is indicatively expected in 2027, and obligations typically apply around 18 months after a delegated act enters into force. Treat the exact timing as indicative — but the direction is settled: textiles are in the first wave.

We import finished garments from Asia. Whose job is the DPP?

Yours. ESPR duties attach to the economic operator placing the product on the EU market, and for non-EU-made apparel that is the EU importer. Your manufacturer holds much of the data, but the legal responsibility for a compliant, accurate passport sits with you.

We sell under our own brand but manufacture nothing. Does that change anything?

Yes — it makes your position stronger, not weaker, in obligation terms. Private-label sellers of non-EU-made goods carry manufacturer-level duties under the regulation, the fullest set of obligations, because you present the product to the market as your own.

What should a textile importer actually do in 2026?

Start with data readiness: map which supplier documents you already hold (fibre composition, test reports, chemical declarations, recycled-content evidence), find the gaps per product line, and make document collection part of every new purchase order. The EU DPP Registry opens for registration on 19 July 2026, so the infrastructure is arriving ahead of the textile rules.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

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