When a regulation enters into force, it creates obligations. When it enters into force with a framework but without the product-specific rules that define what those obligations actually require, it creates a preparation window. The EU Ecodesign for Sustainable Products Regulation, known as the ESPR, entered into force on 18 July 2024. Since that date, the ESPR has been EU law. Since that date, textiles and apparel have been identified as a priority product group within the ESPR framework. Since that date, fashion brands selling in the EU have been building toward compliance with a regulation whose textile-specific requirements do not yet legally exist.
This is not a paradox or an oversight in the regulation’s design. It is how the ESPR framework operates. The regulation establishes the structure: the requirement for a Digital Product Passport, the principles it must enable, and the obligation on economic operators to issue and maintain it. The delegated acts then fill that structure with product-specific content: the data fields a textile DPP must contain, the scope of products covered, the technical standards for the QR or digital carrier, the minimum granularity at which data must be recorded, the access rights of different parties and the SME transition arrangements. Until the textile delegated act is adopted, no textile brand has a legal obligation to issue a DPP and no regulator has a legal basis to enforce one.
The textile delegated act is planned for Q3 to Q4 2027. The mandatory textile DPP compliance date, after the minimum eighteen-month transition period that follows any delegated act adoption, is anticipated around mid to late 2028 for large enterprises and 2028 to 2029 for SMEs. The preparation window between now and those dates is real and limited, and what a brand does during it determines whether 2028 brings a compliance capability or a compliance crisis.
The EU Digital Product Passport framework is law. The textile-specific delegated act that defines what fashion brands must report is expected in Q3–Q4 2027, with mandatory compliance from 2028. This analysis explains the gap and what brands should be building during it.
What the ESPR Framework Already Establishes
The regulation and its instrument
The ESPR (Regulation EU 2024/1781) establishes the requirement for Digital Product Passports across most product categories placed on the EU market, regardless of where they are manufactured. The DPP is a structured digital record that must accompany the product and contain specific sustainability and lifecycle information. The regulation’s stated objectives are to enhance transparency, enable circular economy practices, and strengthen traceability across value chains. Importantly, it applies to non-EU brands placing products on the EU market: a fashion brand based in Nigeria, Chile, or the United States whose garments are sold in EU markets is within the regulation’s scope.
The ESPR’s structure operates through delegated acts adopted by product category. Each delegated act defines the concrete technical requirements for that category: the data fields, the carrier technology, the scope and the compliance timeline. The framework regulation itself, in force since July 2024, does not contain these specifics. It authorises the Commission to adopt delegated acts and establishes the principles they must follow. The specifics will appear in the delegated acts, and the Commission has set out a schedule for their adoption in its ESPR Working Plan.
The Working Plan 2025 to 2030 and what it confirms for textiles
On 16 April 2025, the European Commission adopted and published its first ESPR and Energy Labelling Working Plan 2025 to 2030. This document is the primary planning instrument for the sequencing of delegated acts across product categories. It confirms that textiles and apparel are a priority product group. It places the textile delegated act in the 2027 adoption window, with an indicative Q3 to Q4 2027 date as the current Commission planning position.
The Working Plan also sequences the delegated acts for other product categories, putting the textile act’s position in context. Iron and steel are expected to receive their delegated act in 2026, making them among the first product categories to define specific DPP requirements. Batteries receive their DPP mandate in February 2027, putting them ahead of textiles in the compliance sequence. Textiles and apparel are currently planned for Q3 to Q4 2027, followed by furniture in 2028, mattresses in 2029 and mobile phones and tablets in 2030.
The sequencing matters for fashion brands because the delegated acts that precede the textile act will set precedents for data granularity, carrier technology standards, SME tier structures, and access-right frameworks. Lessons from battery DPP implementation, the first major consumer product DPP mandate, will directly inform how the textile delegated act is structured. Fashion brands that track the battery DPP’s implementation in early 2027 will have a concrete preview of the administrative and technical demands the textile act will impose.
What the Textile Delegated Act Will Define
The data fields that do not yet exist in law
The most significant thing the textile delegated act will do is fix the data fields that a textile DPP must contain. Until it does, brands preparing for the DPP are working from the ESPR’s general principles and from the Joint Research Centre’s technical work, which provides the most detailed available preview of what the act will require but which is not binding law. The distinction between the JRC’s technical guidance and the delegated act’s legal text is the distinction between a well-informed anticipation of what the law will say and what the law actually says.
Based on the JRC’s work and the general ESPR framework, the textile DPP is expected to require data across several categories: product composition (fibre types and percentages), country or region of manufacture, durability information (care instructions, repair information, expected lifespan), end-of-life information (recyclability, disassembly instructions), sustainability claims substantiation (any claims about recycled content, sustainable sourcing or circular design must be supported by the DPP data), and chemical composition data relevant to recycling and reuse. None of these fields is legally confirmed for textiles until the delegated act is adopted.
Minimum data granularity: batch, not item
One of the most practically significant decisions the Textile Delegated Act will confirm is the minimum granularity for recording DPP data. Current guidance indicates that the minimum granularity is the production batch rather than the individual item. This means a brand does not need to issue a unique DPP for each garment within a batch; it needs to issue one DPP for the batch, whose data records apply to all items within it. Item-level tracking remains voluntary and may be adopted by brands seeking additional traceability capability. Still, it is not expected to be mandatory in the first wave of textile DPP obligations.
The batch-level granularity decision has significant implications for the operational complexity of compliance. A brand producing ten thousand units of the same style in the same production run from the same materials need only produce and register one DPP for that batch. A brand producing fifty distinct styles across fifteen production facilities faces a more complex data management challenge but still one defined by batch rather than by unit. Understanding the batch granularity requirement allows brands to estimate the volume of DPPs they will need to manage and to design their data infrastructure accordingly.
Scope: what is covered and what is not yet confirmed
The first wave of textile DPP obligations is expected to focus on apparel, which is clothing items. Home textiles, footwear and accessories may be added through subsequent delegated acts that the Working Plan positions in later years. The exact scope will be confirmed in the textile delegated act itself. A brand that produces both clothing and home textiles should plan for clothing to fall within the first wave and home textiles to follow, but should not treat this as a confirmed boundary until the delegated act defines it.
The Public Consultation Period and What It Offers
The second half of 2026 is expected to see the public consultation on the textile delegated act. The impact assessment has been running through 2026 as the technical groundwork for this consultation. The public consultation is a formal step in the European Commission’s process for adopting delegated acts, during which stakeholders, including fashion brands, trade associations, environmental organisations, and supply chain actors, can submit views on the draft requirements. Fashion brands that engage with the consultation have a direct way to influence which data fields are required, what the SME thresholds are, and how the transition period is structured.
Participation in the consultation does not require a legal team or a Brussels office. The Commission publishes consultation documents and accepts written submissions from any stakeholder during the defined consultation window. Fashion brands with practical experience of the data they can and cannot collect from their supply chains have information that the Commission’s technical working groups value: a brand that demonstrates that a specific required data field cannot be supplied by 90% of independent brands in a given market has made an argument the Commission will have to engage with.
The consultation window is the moment at which the regulation’s requirements are still open to influence before adoption. Once the delegated act is adopted, the field list, granularity requirements, and compliance timeline are fixed. The period between now and the second-half-2026 consultation is when industry engagement can shape what the regulation will require. The period between the consultation and the 2027 adoption is the period for understanding and planning. The period between adoption and the 2028 operative deadline is for implementation.
What Fashion Brands Outside the EU Need to Know
Scope applies regardless of where you are based.
The ESPR’s scope applies to products placed on the EU market, not to brands based in the EU. A brand based in Lagos, Bogotá, Kingston, or Auckland whose garments are sold in EU retail channels or through an EU e-commerce shopfront is within the regulation’s scope. The obligation to issue a DPP falls on the economic operator responsible for placing the product on the EU market, which in many cases is an importer or distributor rather than the brand itself. A brand that sells through an EU-based distributor should confirm with that distributor who bears the DPP compliance obligation before assuming the distributor will manage it.
For brands from the Global South whose EU export market is a significant proportion of their revenue, the DPP is not a future consideration. It is an active planning requirement whose data demands will arrive at a point determined by the 2027 delegated act and the 2028 operative deadline. Internal preparation for DPP compliance requires supply chain data that typically takes twelve months or more to collect and verify across the full depth of the supply chain: not only Tier 1 garment assembly but also fibre composition, the dyeing and finishing process, and the country of origin for each material input.
The data collection challenge in non-EU supply chains
As Omiren Styles established in its field-by-field analysis of fabric provenance claims, geographic origin claims for textiles require documentation at multiple supply chain tiers: country-level is the floor, regional and cooperative-level require more specific evidence. The DPP will require equivalent or more specific documentation, recorded in a structured machine-readable format rather than asserted in marketing language. A brand that currently operates with informal sourcing relationships where fibre origin, processing location and chemical composition are not formally documented will face the greatest compliance challenge when the textile delegated act’s data fields are confirmed.
The preparation window is the time to close this data gap. A brand that starts in 2026 building the supplier documentation relationships, data management infrastructure, and material traceability systems it will need for DPP compliance arrives at the 2028 operative deadline with a compliance capability. A brand that waits for the delegated act to be adopted in 2027 before starting this work has compressed twelve months of supply chain documentation into an eighteen-month compliance window, which is a stressful and more expensive build than a measured approach.
What the Preparation Window Requires
Three categories of preparatory work are appropriate during the period before the textile delegated act is adopted:
- Supply chain data audit: map what fibre, composition, processing and origin data you currently hold for each product line, in what format, from what supplier, and with what verification. The gaps between what you hold and what a textile DPP will likely require are the gaps you need to close before 2028.
- Supplier relationship development: identify which suppliers in your chain can provide structured, verifiable data on fibre origin, chemical composition and manufacturing location, and which cannot. Suppliers that cannot provide this data will need to change their relationship with the brand before DPP compliance becomes mandatory.
- Consultation engagement: identify the EU textile trade associations and stakeholder bodies that will participate in the 2026 public consultation and determine whether your brand’s interests are represented in their submissions, or whether you will submit independently.
- Platform monitoring: the market for DPP technology platforms is developing ahead of the delegated act, with multiple providers offering DPP issuance infrastructure. Evaluating these platforms before the mandatory requirement arrives allows a brand to make a considered technology selection rather than an emergency one.
The textile delegated act will not tell a brand what its supply chain looks like. It will require the brand to document its supply chain and make that documentation available in a structured digital format accessible to regulators, recyclers, and, in some cases, consumers. Brands that do not know what their supply chains look like cannot comply with a requirement to document them.
The Omiren Argument
The Digital Product Passport for textiles is the regulatory instrument that converts the fashion industry’s sustainability claims from marketing language into a structured, auditable legal requirement. The framework is already law. The specific requirements are not. The gap between now and the 2027 delegated act is the period in which a brand can build its compliance capability at reasonable cost and in a considered sequence—waiting for the delegated act to be adopted before starting changes the calculation: the same capability built in a shorter time, at a higher cost, against a compliance clock that cannot be extended.
For brands from the Global South whose production is in markets with less developed supply chain documentation infrastructure, the DPP represents a significant compliance challenge whose consequences depend on how long before 2028 the preparation begins. It also represents an opportunity: a brand that can document its supply chain to DPP standard has built the same evidence base that buyers, press and consumers are increasingly asking for on provenance, sustainability and traceability grounds. The DPP does not create a new evidence requirement. It formalises one that the market has been informally imposing for years.
As Omiren Styles has argued throughout its coverage of material intelligence and the Global South, the Global South made fashion and never got credit. The DPP’s supply chain transparency requirement, implemented without adjustment for the data infrastructure realities of Global South production contexts, risks becoming another mechanism by which the compliance burden falls disproportionately on the supply chain tiers that are least resourced to meet it. Participating in the 2026 consultation is the mechanism to place those realities on the record before the regulation’s requirements are fixed.
KEY DATES AT A GLANCE
18 July 2024: ESPR entered into force. The DPP framework is EU law.
16 April 2025: ESPR Working Plan 2025–2030 adopted. Textiles confirmed as a priority product group.
Second half of 2026: Public consultation on the textile delegated act. The textile delegated act is expected.
February 2027: Battery DPP mandate (first major consumer product DPP).
Q3–Q4 2027: Textile delegated act is planned for adoption. Data fields legally fixed.
Mid- to late 2028: First operative DPP deadline for large textile enterprises (18-month transition).
2028–2029: SME compliance window.
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EXPLORE MORE
Read the full Regulatory Intelligence and Material Intelligence coverage at Omiren Styles for ongoing analysis of EU textile regulation, supply chain transparency requirements and what the DPP means for independent fashion brands. Discover travel and heritage intelligence across Africa, the Caribbean and Latin America at Rex Clarke Adventures.
