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EU and Digital Product Passport

What Product Data Should Apparel Brands Prepare for a Digital Product Passport?

Last updated: October 20, 2026. The final data list will come from the EU's textile delegated act, which is not yet adopted.

Apparel brands can prepare for the EU Digital Product Passport by organizing five groups of data: product identity, materials, supply chain, chemical and safety documents, and care, durability and end-of-life information. No final list exists yet, so this guide labels each item as required today, expected or possible, and tells you where those labels come from.

How to read the status labels

  • Required today: an existing rule already demands it.
  • Expected: industry analysis of the ESPR and the Commission's consultations points to it, but the textile delegated act has not confirmed it.
  • Possible: discussed in the sector, with no clear basis yet.

Preparation should focus on required and expected items. Do not treat "possible" items as obligations.

The five data groups

Data group Examples Status
Product identity Style and SKU, variant, barcode or GTIN, brand, model name, EU importer or authorized representative Identity and operator details are partly required by existing EU product rules; unique product identifiers are expected for the DPP
Materials Fiber composition by component (shell, lining, trims), percentages, recycled content with certificates, certification numbers Fiber composition is required today for EU labeling; recycled content and component detail are expected
Supply chain Supplier and factory names, country by production stage (spinning, weaving, dyeing, cut and sew) Possible. Traceability themes are discussed, but the required depth is undecided
Chemicals and safety Restricted-substance test reports, REACH-related declarations, supplier statements Substances of concern are expected; existing chemical rules already require compliance
Care, durability, end-of-life Care instructions, repair information, expected durability, recyclability, take-back details Durability and end-of-life information are expected

Step 1: Build one product master

Keep a single record per style that links to every variant. Spreadsheets and email threads will not scale to a passport that has to stay consistent with the product. See How to Build an Apparel Compliance Matrix in Excel.

Step 2: Capture material data at component level

A garment is rarely one fabric. Record shell, lining, filling, trims and labels separately, each with its fiber percentages and supplier. Include recycled content shares with the certificate that supports them. Recycled polyester claims need the same evidence.

Step 3: Link every claim to a document

For each material or environmental statement, store the supporting document and its expiry date: test reports, transaction certificates, supplier declarations.

Step 4: Map your suppliers

Start a simple list of each style's supplier and factory for every production stage. Even if the DPP asks for less, this data helps with U.S. origin claims, California SB 707 and customer audits. See How to Collect Textile Compliance Documents from Suppliers.

Step 5: Standardize vocabulary

Choose controlled lists for fiber names, countries, certification schemes and care phrases. Note that U.S. and EU fiber names differ in places, for example spandex in the U.S. and elastane in the EU. See US vs EU Textile Compliance.

Step 6: Assign ownership and review dates

Give each data group an owner and a review cycle. A passport is only as reliable as its oldest record.

What not to do yet

  • Do not buy or build around a specific data carrier or registry format, since the technical standards have not been fixed for textiles.
  • Do not publish claims that you are "DPP compliant".
  • Do not collect data you cannot maintain.

Frequently asked questions

Is there an official DPP data list for textiles? Not yet. The delegated act is planned for 2027.

Does this data help me in the U.S.? Yes. Fiber content, origin, recycled-content evidence and supplier records support FTC rules and California SB 707 reporting.

Do I need GTINs? They are widely used as identifiers, but the textile act has not yet defined the identifier format.

Related guides

This article is general information, not legal advice.

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