What Fashion Brands Need to Know About the DPP Timeline

The fashion industry is entering a period of significant regulatory transformation. With the European Union’s Ecodesign for Sustainable Products Regulation (ESPR) now in effect, the Digital Product Passport (DPP) is no longer a distant concept. It is a rapidly approaching requirement. For brands operating within the EU, the question is not whether DPPs will become mandatory, but when. This overview outlines the key developments and steps that fashion brands must understand to remain compliant and competitive. 

What is the Digital Product Passport? 

The Digital Product Passport is a digital record that accompanies a product throughout its entire lifecycle. It includes essential information such as material composition, country of origin, environmental footprint, repairability, and more. 

For consumers, the DPP offers greater transparency. For regulators, it supports monitoring and compliance. For brands, it introduces a new standard of accountability across supply chains and product lifecycles. 

ESPR Timeline: Key Milestones 

The ESPR formally entered into force on 18 July 2024, replacing the earlier Ecodesign Directive. It establishes the legal foundation for implementing Digital Product Passports and other sustainability measures across various industries. 

April 2025: The European Commission adopted the 2025–2030 ESPR Working Plan, which identifies textiles and apparel as priority categories for early regulation. 

Early to mid-2026: The Joint Research Centre completes the preparatory studies for the delegated act on apparel.  

Early 2026: Publication on standard CN JTC 24. 

Late 2026: KOM proposal delegated act for apparel. Act on DPP: registry, service providers, data carriers, digital credentials.  

Late 2026 / Early 2027: Adoption of delegated act on apparel.  

Mid 2028 (18 months): Companies need to comply with the ESPR. DPPs are expected to become mandatory for textiles, including garments and accessories. 

What Will the Delegated Act for Textiles Cover? 

The upcoming Delegated Act for textiles, expected between 2026 and 2027, will define the technical and regulatory parameters for DPPs in the fashion sector. While details may still evolve, the current draft scope includes: 

• Included product categories: T-shirts, shirts, sweaters, jackets, trousers, dresses, underwear, socks, and accessories like scarves and gloves. 
• Exclusions: smart textiles, PPE, medical devices, and raw textile materials.   

DPP data will likely be accessed via QR codes or NFC chips embedded in the product or label, linking to a secure digital profile hosted by a certified service provider. 

What Does “Placed on the Market” Mean? 

In the context of EU regulation, “placed on the market” refers to the first time a product is made available on the EU market, whether through sale or free distribution. This applies equally to domestically produced goods and imports. 

Products that have already been placed on the market before the DPP enforcement date may be exempt. However, any new production or imports introduced after the effective date must fully comply with all applicable DPP requirements. 

What Data Fields Will the DPP Include? 

While the final list of mandatory data fields will be defined in the upcoming Delegated Act for textiles, brands can already anticipate the core categories: 

• Material composition – including fiber types and recycled content 
• Substances of concern – such as regulated chemicals or allergens 
• Environmental impact indicators – like carbon footprint and water usage 
• Traceability identifiers – unique codes for product, batch, or item level 
• Production details – including manufacturing date and location 
• Repair and maintenance history – especially for item-level DPPs 
• Recyclability and end-of-life instructions – to support circularity 
• Access method – typically via QR code or NFC chip linked to a secure digital profile 

Preparing for these data requirements now will help brands streamline compliance and unlock new opportunities for transparency and circularity. 

What Should Fashion Brands Do Now? 

To prepare for the coming changes, fashion brands should take the following actions: 

1. Align leadership strategy: Ensure that digital transformation and DPP implementation are championed from the top. Executive buy-in is essential for long-term success.   
2. Map existing product data: Assess what information is already available internally and identify any gaps. 
3. Define your data priorities: Clarify which data fields are essential for compliance, operational efficiency, and strategic value creation.   
4. Engage with suppliers: Begin tracing raw materials, certifications, and environmental data throughout the supply chain. 
5. Select a DPP service provider: Choose a provider that meets EU standards for data interoperability, security, and reliability. This will avoid siloing and enable seamless integrations between systems. 
6. Pilot and test: Use 2025 and 2026 to conduct pilot projects, validate processes, and prepare internal systems. Use the piloting phase to train and engage teams, giving them the knowledge and incentives to support DPP goals. 
7. Stay informed: Track regulatory developments and updates to the Delegated Acts as they are finalized. 

Acting Early Creates Strategic Advantage 

The Digital Product Passport is more than a regulatory obligation. It represents a strategic opportunity for fashion brands to lead with transparency, build trust with consumers, and future-proof their operations. 

Brands that invest early in understanding and implementing the DPP framework will not only ensure compliance but also position themselves at the forefront of sustainable innovation in fashion. 

The Digital Product Passport is coming. Preparation today will determine competitiveness tomorrow. 

Sources:

DM&T | Home  

EU Digital Product Passport: What it means for the textile industry 

The Clock is Ticking: Get Ready for the EU's Ecodesign & Digital Product Passport 

EU Digital Product Passport for Textiles to be mandatory in 2028 - Asquith Group 

Digital Product Passport (DPP) in the EU - Full Guide (2025) 

ESPR Delegated Acts for DPP for Textiles and Footwear 

The Latest Updates on the ESPR Digital Product Passport (DPP) Regulation in EU: What You Need to Know in 2025