The Digital Product Passport entered EU law in June 2024, as part of the Ecodesign for Sustainable Products Regulation. It requires a product to carry structured, standardised data about itself, reachable through a QR code, NFC tag or RFID chip attached to the item, its packaging or its documents.
For textiles the sequence is: an ESPR working plan indicating a delegated act in 2027, and a rule in the regulation that a delegated act cannot apply until eighteen months after it enters into force. That puts mandatory compliance for apparel realistically in 2028.
Two years out is exactly the point at which an industry decides the deadline is somebody else's problem. That would be a mistake this time, and the reason is what happened in May.
The specification is now written down
On 13 May 2026 the Joint Research Centre, the Commission's own science service, published a Science for Policy report containing the first complete specification of what a textile passport has to contain.
That is not law and it is not final. It is better than that for planning purposes: it is the document the delegated act will be drafted from, published by the body drafting it, two years early.
The phasing it sets out is the part that matters commercially:
- Phase 1, 2026 to 2027: fibre composition, country of manufacture, chemical compliance, certifications.
- Phase 2, 2027 to 2028: carbon footprint and water consumption.
Phase 1 is a records problem, Phase 2 is a supplier problem
Fibre composition and country of manufacture sound trivial. For a brand with a settled supply chain they nearly are. For anyone buying through agents, or switching mills by season, or working with a factory that subcontracts when it is busy, they are not, because the honest answer to "where was this made" is often "at whichever of four sites had capacity that week".
The passport does not accept that answer. It wants one, per item, and it wants it to survive the item.
Phase 2 is a different order of difficulty. A carbon and water figure per product cannot be reconstructed from invoices. It has to be collected upstream, by suppliers, in a form that is comparable, and the suppliers in question are mills and dye houses in countries that have no obligation to the EU at all. Their incentive to produce that data is entirely the purchasing power of the customer asking.
Which means the large groups will get it and the small brands will buy an approximation. That is not a prediction about who cares more. It is arithmetic about who places orders big enough to make a mill answer a questionnaire.
Scope: it does not matter where you are
Any economic operator placing textile products on the EU market is covered, regardless of where the brand is based or how small it is. A brand outside the EU selling in through distributors is in scope.
This is the same extraterritorial shape as the rest of the recent European rulebook, and it works for the same reason: nobody gives up the EU market over a data requirement. It is also why the passport will end up as a de facto global standard for anyone with European ambitions, in the way that European privacy rules did.
The clause the rest of the industry has not noticed
The passport must remain available throughout the product's life, including resale and end-of-life.
That single line moves the passport out of compliance and into commerce, because it hands the secondhand market a permanent, brand-independent record of what a garment is. We have written about what that does to the platforms whose business is proof, and it is the most consequential thing in the regulation for anyone who is not a compliance officer.
What to watch
The delegated act. Until it is adopted, the May specification is guidance and the 2028 date is an estimate. If the act slips past 2027, everything moves with it, and the brands that started building supplier data in 2026 will have spent two years being early, which in this particular case is a much cheaper mistake than being late.
Regulation, timeline, phasing and scope per the ESPR working plan and the JRC specification, summarised by TrusTrace. Dates for the textiles delegated act are indicative and not yet law.
