The collection you are designing now is the first one that will need a passport

Fashion runs two to three seasons ahead. Design happens eighteen months to two years before a garment reaches a shop floor, sourcing is locked long before that, and material decisions are made earlier still.

Which means the digital product passport (DPP) requirements expected for textiles are not a future problem. They apply to the products on your desk this month.

The dates, and what is actually fixed

The ESPR Working Plan 2025-2030 schedules textiles and apparel for a delegated act indicatively in Q3 to Q4 2027, with compliance following after the transitional period, so around 2029. Footwear is handled separately.

Those are indicative dates from a working plan, not legal deadlines, and no compliance year for textiles is settled until the delegated act is adopted. What is already fixed in law is different and often overlooked: since 19 July 2026, large companies may no longer destroy unsold textiles and footwear in the EU, with an annual public disclosure duty attached. That obligation is in force today and it runs on the same product data the passport will need, which we cover in the unsold stock ban.

Why the lead time inverts the deadline

Take a collection landing in 2029 and work backwards. Design and material selection happen in 2027. Supplier nomination happens in 2027. Fabric is bought in 2027 and 2028.

If passport data has to describe fibre composition, recycled content, production facilities and substances of concern for that collection, then the data decisions are made at material selection, not at launch. A brand that starts collecting evidence when the delegated act is published will be chasing documentation for garments that have already shipped, from suppliers who have moved on to other orders.

This is the practical reason fashion cannot treat the DPP as a compliance task at the end of the process. It is a sourcing decision at the start of it.

The tier problem

Textile supply chains are the reason the passport is harder here than in metals. A garment brand typically has a direct relationship with a Tier 1 manufacturer, a weaker one with the Tier 2 mill, and often no relationship at all with the Tier 3 spinner or the Tier 4 fibre producer.

Passport fields on fibre origin and recycled content live at Tier 3 and Tier 4. The brand carries the legal responsibility for data it cannot see. Closing that gap is a commercial exercise involving contracts, nomination and, sometimes, changing suppliers. None of that happens in a quarter.

What to do in this design cycle

Add passport data to the material approval process now, so a fabric cannot be approved without the evidence its passport will need. Ask your Tier 1 suppliers to name their Tier 2 and where possible Tier 3, since visibility precedes evidence. Pick one product line and take it end to end as a pilot exercise for your own team, so the gaps surface on one line rather than on the whole catalogue at once.

The brands that start the data work in this design cycle will have a passport. The others will have a deadline.

Sources

• ESPR Working Plan 2025-2030, COM(2025) 187 final, adopted 16 April 2025. Textiles and apparel
• delegated act indicatively Q3-Q4 2027. Indicative dates are not compliance dates.
• Regulation (EU) 2024/1781, Article 22: ban on destroying unsold textiles and footwear for large
• companies from 19 July 2026, extended to medium enterprises from 19 July 2030.