Fashion and footwear brands selling into the European Union have roughly a year before the bloc finalises the data rules for textile digital product passports, and industry surveys suggest most are not ready.
The European Commission says the passport, a digital record linked to each product by a QR code or similar data carrier, will be introduced progressively under the Ecodesign for Sustainable Products Regulation. Batteries come first, with the requirement becoming mandatory on Feb. 18, 2027. The Commission’s indicative timeline puts adoption of the textile rules in the third and fourth quarters of 2027, followed by a transition period of at least 18 months. Furniture is slated for 2028 and mattresses for 2029.
The EU’s central DPP Registry became operational on July 20, 2026. Once a product is registered, the registry issues a unique identifier, and the Commission says imported goods can be checked against it at customs. Products made inside the EU must be registered before they reach the market. Consumers, repairers, recyclers and public authorities will see different layers of information depending on their role.
Although exact textile data fields are not yet fixed, compliance vendors say waiting is risky. Supply chain software firm TrusTrace said a pilot working group involving Swedish brands, including Kappahl and Marimekko, identified 126 likely data points for textiles, of which about 25 to 30 would be visible to consumers. The rest would be restricted to brands, suppliers and recyclers, according to the company. The protocol is available as a free, open-source download, which TrusTrace says lets brands without existing supply chain data start pilots.
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The same pilots exposed costly mistakes. TrusTrace said one brand created QR codes at batch level and had to rework its serialisation system, because item-level identifiers are expected for most products to support repair, resale and recycling. Suppliers, often being asked for such data for the first time, frequently responded with a “why?”, the company said.
The rules will apply to any brand placing goods on the EU market, wherever it is based, TrusTrace said, a point with particular weight for non-EU garment makers that supply European retailers. Laura Milillo of GS1 UK has said the consequences of non-compliance could range from heavy fines to goods being blocked from the EU market, according to ACCA’s Accounting and Business magazine.
Preparedness appears limited. Carlo Giardinetti, a director at Deloitte, said in March that relatively few organisations had set up end-to-end DPP systems, citing bottlenecks that made full implementation difficult and resource-intensive. Software provider Inspectorio has said only 6% of brands report full traceability across all supply chain tiers, though the figure is the company’s own and its blog gave a 2026 start for enforcement that does not match the Commission’s timeline.
Researchers have questioned whether the system is ready. Li Yuan of the University of Helsinki argued that the legal, technological and policy infrastructure remains underdeveloped and that, without inclusive consultation and capacity-building, DPPs could disproportionately burden smaller suppliers or non-EU partners.
Supporters see a payoff. The Commission says passports will improve traceability, support circular business models and help authorities act against non-compliant goods. The same ACCA article noted that EU research found more than half of the environmental claims examined were vague, misleading or unfounded, and the World Economic Forum has called passports a promising answer to opaque materials supply chains.
The advice from vendors and advisers is consistent: audit existing product data, pilot with the best-documented product lines, plan item-level serialisation from the start and begin educating suppliers now. Data that conflicts with marketing claims could raise red flags in audits, consultancy Renoon has warned, and incorrect information can create more risk than missing data. Martina Sattanino of Renoon said data must be consistent across systems.