Does the digital product passport apply to my clothing and textiles?
Textiles and clothing are in principle covered by the regulation
Clothing and textile products fall within the scope of the ESPR (Regulation (EU) 2024/1781), the European regulation that establishes the basis for the digital product passport. This does not mean there is already an obligation to have a passport today. The ESPR is a framework regulation: it determines which types of products can in principle fall within its scope, but the concrete obligation — which product passport, with which data, from which moment — is worked out separately for each product group. For textiles and clothing, that elaboration has not yet been published.
Who this applies to, and what it does not apply to
The ESPR is designed as a broad regulation that in principle applies to physical goods placed on the European market, with a number of specifically named exemptions (such as food, medicines and living organisms). Clothing, footwear and other textile products do not fall under those exemptions and therefore fall within the group of products for which the regulation enables a digital product passport. This applies both to brands that design and have products manufactured themselves, and to importers and parties working under private label — the regulation is directed at whoever places a product on the market, not at the question of who actually made it.
What it does not currently apply to: there is not yet any concrete obligation for a passport for textiles or clothing. Article 9 of the ESPR describes what a digital product passport must contain and how it must work, but whether and when those requirements will actually apply to a particular product group is laid down in a separate decision for that group. That decision has not yet been adopted for textiles and clothing. There is therefore a distinction between "falls within the scope of the ESPR" and "is now required to have a passport" — the first applies to clothing and textiles, the second does not yet.
When this will apply is not yet fixed
There is no fixed date on which the obligation for textiles and clothing comes into force. That date will only be determined once the specific elaboration for this product group has been published. Until then, nothing changes for current collections and existing products: there is no legal obligation to have a digital product passport for clothing or textiles now.
What is fixed is the mechanism in the ESPR itself: the regulation provides the framework (what a passport must be able to do, how the data carrier — such as a QR code — must work, who may access it) and leaves the elaboration for each product group to a separate process. Once that process for textiles has been completed and published, it will be clear exactly which products fall within that group, which data are mandatory and from which moment. Until that publication, any date circulating here and there is an expectation, not a legal fact.
What this means for your approach
For anyone now working with clothing or textiles and wanting to prepare for this, the most logical sequence is: first check whether your own assortment falls within the common definitions of textiles and clothing (almost always the case with clothing, regardless of fibre composition), and then map out which data on origin, material and production are already available from the manufacturer or supplier. This is the work that will be needed anyway once a passport becomes mandatory, and it can be built up without hurry while the regulation is still taking shape.
After that, it is a matter of following the publication of the specific decision for textiles — only then will it become clear which products within the group will be first in line and what exactly must be in the passport. Until then, no action is required, but it is wise to have your own product data (material composition, origin, supplier details) in order, so that when the requirements are published, no backlog needs to be caught up.
What this is based on
That textiles and clothing are in principle covered by the ESPR follows from Article 1 of the ESPR (Regulation (EU) 2024/1781), which sets out the subject matter and scope of the regulation and does not exclude textiles. What a digital product passport entails and how the obligation is established per product group follows from Article 9 of the same regulation. For the specific implementation for textiles and clothing — which products, which data, from which date — a separate, yet to be published elaboration is required; at the time of writing, this had not yet been established.
What you can do now
This page will be updated as soon as the specific elaboration for textiles and clothing is published, with the applicable date and requirements at that time. Until then, it is worthwhile to document your own product data — material, origin, supplier — in an organized manner, so that this foundation is in place when the obligation becomes concrete.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 1 (subject matter and scope)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
The regulation itself is available on EUR-Lex. We provide references for each statement; you do not need to take our word for it.
What you must do concretely
What is expected of you
The ESPR is a framework regulation: Article 1 makes clear that the regulation itself does not impose a digital product passport on any specific product group, but rather sets out the framework within which that framework is to be filled in per product group. For clothing and textiles, that further specification has not yet been published. What is already certain: Article 9 describes what a digital product passport must contain once it applies to a product group. This means there are in practice two things you can already do now, even without the obligation yet in force.
Check whether your product falls within the scope
Article 1 of the ESPR (Regulation (EU) 2024/1781) describes the scope broadly: physical goods placed on the market or put into service. For a company with 10 to 100 employees, this means above all: checking under which category your own collection falls, and whether that category is mentioned in the plans for the first delegated act. Clothing with a high percentage of textile fibres is first on the agenda; other textile products may follow later, via a separate delegated act. Which products exactly may fall under the ESPR is elaborated on the page about which clothing and textile products fall under the ESPR.
Understand what the passport must contain in future
Article 9 of the ESPR (Regulation (EU) 2024/1781) describes the structure of the digital product passport: a unique identification, a link to data about the product, and accessibility via a data carrier such as a QR code. For a medium-sized clothing company, this means that its own product administration — material composition, origin, production process — must at some point be structured and linkable to such a passport. This is not an obligation that applies now, but something for which the foundation can already be laid now. A more detailed explanation of what exactly goes into such a passport can be found on the page what a digital product passport for clothing and textiles is.
Follow when the obligation becomes concrete
The obligation only arises with the delegated act for the specific product group, not with the ESPR itself. This distinction is important: the ESPR is the framework, the delegated act is the key that opens the door for a particular product group. How that process works and why its date depends on this is explained on the page about what a delegated act is and why it determines what must be done. As long as that act has not been published, there is no date to act on — but a moment to pay attention.
Where things go wrong in practice
Assuming that "clothing" covers everything. A company that sells handbags, belts or shoes alongside its main collection sometimes assumes that those products automatically fall under the rules for clothing. Whether and when that is the case is not yet established; the question of whether the product passport will also apply to accessories and shoes deserves a separate answer, which can be found on the page about accessories and shoes.
Overlooking workwear or incorrectly including it. Work clothing and uniforms are sometimes forgotten in communications about textile regulations, or incorrectly lumped in with consumer clothing. This distinction is addressed on the page about workwear and occupational clothing.
Thinking small companies are exempt. The assumption that an obligation like this applies only to large brands is a recurring misunderstanding. A company's size is not automatically a ground for exemption; what can be said about this is on the page whether the product passport also applies to small companies.
Forgetting household textiles in your planning. Brands that sell curtains, bedding or other interior textiles alongside clothing often focus their attention only on the clothing line. Whether that distinction is sustainable is discussed on the page about textiles for interiors.
Counting samples and showroom models that are not sold. Some companies want to label everything as a precaution, including items that never reach the market. Whether this is necessary depends on what falls under "placing on the market" — a question that is addressed separately on the page about samples and showroom models.
What you can record
- An overview of your own product categories (clothing, accessories, household textiles, workwear) with a note per category on whether it falls within the first delegated act or will be addressed later.
- A list of the material data already available per product (fibre composition, origin, supplier information), so it is clear which basic data are already in place and which are still missing.
- An internal responsible person or contact who monitors developments around the delegated act, including a fixed review moment (for example every quarter) to check whether there is news about publication or date.
- A brief note on the relationship between the product passport and other ongoing obligations, such as extended producer responsibility — which you can read more about on the page about extended producer responsibility for textiles — so that these subjects are not tackled separately from each other.
- A file per supplier with the data currently being exchanged (certificates, test reports, composition labels), as a basis for what can later be included in a passport.
These steps do not establish an obligation that does not yet exist, but ensure that the company does not start from scratch once the date and details become known.
This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections are given priority.