Why Fashion Merchants Need to Act Now
The EU Commission selected textiles as a priority product category in the first ESPR Working Plan (April 2025). With implementation expected in 2027-2028, fashion brands have less than 3 years to prepare. This guide covers actual regulatory requirements based on draft delegated acts.
What You'll Learn
- Official 2027 timeline and phased implementation for textiles
- Exact data requirements: materials, composition, traceability
- Step-by-step compliance checklist for fashion brands
- How to automate DPP creation for your Shopify store
Timeline: When Textile DPPs Become Mandatory
Based on the EU Commission's ESPR Working Plan and industry consultations, here's the official timeline for textile Digital Product Passports:
The European Commission published its first ESPR Working Plan, identifying textiles and apparel as one of the first product groups for DPP implementation. This triggered the regulatory drafting process.
Expected publication of draft delegated acts specifying exact data requirements for textile DPPs. This includes material composition thresholds, traceability requirements, and environmental metrics. Public consultation period follows.
Final textile DPP delegated acts adopted by the European Commission. Regulations enter into force with an 18-24 month transition period for industry implementation.
All textile and apparel products sold in the EU must have compliant Digital Product Passports. This applies to:
- Clothing and apparel (shirts, dresses, pants, jackets, etc.)
- Footwear and accessories
- Home textiles (bedding, curtains, towels)
- Bags and luggage made from textile materials
Required Data for Textile Digital Product Passports
Based on draft ESPR regulations and the EU Textile Strategy, textile DPPs must contain the following information categories. While final requirements may vary slightly, these represent the consensus from industry consultations:
Mandatory disclosure: Complete breakdown of all materials and fibers by weight percentage.
Required Information:
- Fiber type and percentage: Must list all fibers above 1% by weight (e.g., "60% Organic Cotton, 35% Recycled Polyester, 5% Elastane")
- Material origin: Country or region where raw materials were sourced
- Processing information: Manufacturing location and key processing steps
- Certifications: Organic, GOTS, OEKO-TEX, or other sustainability certifications
Critical requirement: The EU is pushing circular economy practices. Recycled content disclosure is mandatory for textile DPPs.
Must Include:
- Post-consumer recycled content: Percentage of materials from consumer waste (e.g., recycled plastic bottles, textile waste)
- Pre-consumer recycled content: Manufacturing waste repurposed into new products
- Virgin material percentage: New, non-recycled materials used
- Verification method: Third-party certification or testing methodology used
Regulatory Context: The EU Textile Strategy aims for 25% recycled fiber content in new textiles by 2030. DPP requirements support this goal by making recycled content transparent and verifiable.
Sustainability metrics: Textile DPPs must include environmental footprint data based on Product Environmental Footprint (PEF) methodology.
Required Metrics:
- Water consumption: Liters of water used per kg of textile (production phase)
- Carbon footprint: kg CO₂ equivalent emissions (cradle-to-gate or cradle-to-grave)
- Chemical usage: Disclosure of hazardous substances above threshold levels (REACH compliance)
- Durability indicators: Expected lifespan, wash cycles, or usage duration
Transparency requirement: DPPs must provide visibility into the textile supply chain for consumer trust and regulatory enforcement.
Supply Chain Data:
- Manufacturer details: Company name, location, and facility information
- Production country: Where the garment was manufactured/assembled
- Unique product identifier: SKU, GTIN, or batch number for traceability
- Certifications & audits: Factory compliance certifications (e.g., Fair Trade, SA8000)
Circular economy focus: DPPs must support product longevity and proper disposal/recycling.
Must Provide:
- Washing instructions: Temperature, detergent type, drying method
- Repair guidance: How to repair, alter, or extend product life
- Recycling information: Whether product is recyclable and how to dispose properly
- Take-back programs: Information on brand's textile collection or recycling initiatives
Step-by-Step Compliance Checklist for Fashion Merchants
Start preparing now: Gathering supply chain data takes time. Most fashion brands report 6-12 months needed to collect all required information from suppliers. Don't wait until 2027.
- Review existing product information in your Shopify store
- Identify data gaps (missing material compositions, supplier info, etc.)
- Create inventory of which products will require DPPs by 2027
- Request detailed material composition data for all products
- Obtain recycled content certifications and verification documents
- Collect environmental impact data (water usage, carbon footprint)
- Document supply chain locations and manufacturing facilities
- Create standardized data templates for all textile products
- Store documentation (certificates, test reports) in accessible format
- Ensure data accuracy and verification for regulatory compliance
- Choose DPP software solution (manual vs automated like GreenPass)
- Generate unique QR codes for each product or SKU
- Create digital passport pages with all required information
- Test QR code scanning and passport display functionality
- Add QR codes to hang tags, labels, or packaging
- Coordinate with printing vendors to update label designs
- Plan rollout timeline to phase in new labeling before 2027 deadline
- Subscribe to EU Commission updates on ESPR implementation
- Review final delegated acts when published (expected 2025)
- Adjust DPP data as requirements are finalized
Automate Textile DPP Creation with GreenPass
GreenPass DPP is the easiest way for fashion and textile Shopify merchants to create compliant Digital Product Passports. Skip the manual data entry and spreadsheet management.
Built for Fashion Brands:
- Pre-built textile DPP templates with all required fields
- Material composition tracking and recycled content management
- Automatic QR code generation for product labels
Shopify Native Integration:
- Pull product data directly from your Shopify store
- Bulk DPP creation for entire product catalogs
- Automatic updates when regulations change
Join the Waitlist - Lock in €79 Lifetime Access
Be among the first fashion merchants to get GreenPass DPP. Early access members get lifetime access for a one-time payment of €79 (monthly subscription pricing starts later).
✅ Textile DPP templates included • ✅ Priority support • ✅ Early access to new features
Key Takeaways for Fashion Merchants
- 2027-2028 is the compliance deadline for textile and apparel Digital Product Passports in the EU
- Material composition, recycled content, and environmental data are mandatory disclosures
- Start supplier data collection now - most brands need 6-12 months to gather all required information
- Automated solutions like GreenPass save 100+ hours vs manual DPP creation for textile catalogs
- DPPs are also a marketing opportunity to showcase your brand's sustainability story
Sources & References
• European Commission ESPR Working Plan (2024) - Textile product category designation
• EU Textile Strategy for Circular Economy and Sustainable Textiles
• Draft EU regulations on textile product passport data requirements
• Product Environmental Footprint (PEF) methodology for textiles
• Industry consultations and stakeholder feedback on textile DPP implementation