The digital product passport is no longer an idea: the European framework is in force, the first technical standards are published and the EU registry has a legal basis. For apparel the decisive piece is still missing: the delegated act that will set out which information becomes mandatory. Here is where things stand.
What is already decided
Regulation (EU) 2024/1781, known as ESPR, has been in force since 18 July 2024. It establishes that products subject to its requirements will have a digital passport, reached through a data carrier on the product, such as a QR code, and linked to a unique identifier.
Two important pieces have followed. Implementing Regulation (EU) 2026/1778 established the EU passport registry, which stores identifiers and reference data but not the full content of the passport. With Implementing Decision (EU) 2026/1736, in July 2026 the first harmonised standards on the digital passport (EN 18216 and EN 18219–18223) were cited in the Official Journal; they cover data formats and interoperability.
When fashion’s turn comes
The first ESPR working plan, presented by the Commission on 16 April 2025 and running to 2030, places textiles among the priorities and indicates 2027 as the expected year for adopting the delegated act on textile products. Footwear, on the other hand, was not prioritised in this first cycle.
It is an indicative date: the delegated act still has to be drafted and discussed, and after adoption there will be a transition period before the requirements become mandatory.
What we do not know yet
- The mandatory fields. Which information on materials, supply chain, durability, repairability and substances will have to appear in a garment’s passport.
- Where the data carrier goes. The position of the QR code, on the hang tag, the sewn-in label or the packaging, will be set by the delegated act.
- Environmental indicators. Which indicators will be required and with which calculation method.
How to prepare without chasing the rules
Waiting for the delegated act before starting means gathering, in a few months, data that today is scattered across emails, spreadsheets and second- and third-tier suppliers. Some things can be done now, whatever the final text says:
- map each garment’s supply chain by tier, from raw material to making;
- collect and keep certificates up to date, linked to the steps and batches they refer to;
- plan for an identifier and a QR code that last for the life of the garment;
- do not publish environmental data you cannot substantiate.
Those who reach the deadline with this data in order will only need to adapt its format. Those who start from zero will have to rebuild their supply chain under pressure.