Last updated: March 2026.
This document reflects our understanding of publicly available information, including industry briefings, at the time of writing. We have also consulted with the UKFT (UK Fashion & Textile Association) to help verify the accuracy of this guidance. It is provided for general information only and does not constitute legal advice.
1. Legislative Background
Digital Product Passports (DPPs) are being introduced under the Ecodesign for Sustainable Products Regulation (ESPR) adopted by the European Union.
The ESPR establishes a framework for setting ecodesign and information requirements across a range of product categories. Apparel and textiles have been identified as a priority product group in the EU’s 2025-2030 Working Plan.
Sector-specific obligations, including DPP requirements for apparel, will be defined through a future Delegated Act.
2. Expected Timeline for Apparel
Based on the EU ESPR 2025-2030 Working Plan and recent public statements from the European Comission:
- The Delegated Act covering apparel is expected to be adopted in early to mid 2027.
- Under Article 4 (4) of the ESPR, requirements introduced through a Delegated Act cannot apply earlier than 18 months after adoption.
- If adopted in early/mid 2027, compliance obligations would therefore apply no earlier than late 2028.
- A phased or staged implementation approach is possible, depending on the final structure of the Delegated Act.
At the time of writing, the detailed requirements for apparel have not yet been finalised.
3. What the Delegated Act is Expected to Cover
The Apparel Delegated Act is expected to define:
- Performance requirements (e.g. durability, or product design criteria)
- Information requirements
- Digital Product Passport obligations
The specific data fields, format, and technical infrastructure requirements (including how digital access will function) remain under development.
4. Common Misconceptions
As industry discussions continue, several assumptions are circulating that are not currently confirmed under the ESPR framework:
❌ Testing is already mandatory
At present, no specific durability or performance testing requirements have been mandated for apparel under the ESPR.
Testing requirements, if introduced, would be defined in the Delegated Act.
❌ A QR code must be included
QR codes are not currently mandatory.
The Digital Product Passport may use QR codes or other digital carriers, but the technical format has not yet been finalised.
❌ Factory details must be physically labelled on the garment
There is currently no confirmed requirement under ESPR mandating physical labelling of factory details on garments.
❌ Full supply chain traceability is already required
Supply chain traceability has not yet been confirmed as a mandatory element of the apparel DPP.
While many solution providers promote traceability systems, the EU has not yet finalised the exact data requirements.
5. Responsibility for Compliance
Under the ESPR framework, obligations are generally expected to apply to the “economic operator” placing a product on the EU market. This may include:
- Manufacturers
- Importers
- Authorised representatives
- Brand owners
Responsibility allocation will depend on the final wording of the Delegated Act and the structure of individual supply chains.
Businesses supplying into the EU should seek independent legal advice once detailed requirements are confirmed.
6. How Asquith Group is Preparing
As a supplier to customers operating within EU markets, Asquith Group is:
- Monitoring regulatory developments
- Engaging with relevant industry bodies
- Reviewing internal product data systems
- Assessing current technical documentation processes
- Preparing to support customers as requirements become clearer
We will continue to review developments and update customers accordingly.
7. Disclaimer
This document reflects our understanding of publicly available information as of March 2026. Legislative requirements may change as Delegated Acts and implementing measures are adopted. This document is provided for informational purposes only and does not constitute legal advice.
Products That Can Support Your DPP Strategy
- Woven labels with QR codes
- Printed fabric labels with scannable data
- Heat transfers for seamless branding + DPP integration
- Swing tickets for additional product information
If you have any questions about Digital Product Passports or how upcoming regulations may affect your products, get in touch with our team here.
