ESPR and the Digital Product Passport: explained.

ESPR in brief

What changes compared with the previous rules

ESPR repeals the 2009 Ecodesign Directive, which only covered energy-related products (washing machines, light bulbs, motors…). It now applies to almost all physical goods, components and intermediate products included. Only food, medicines, living organisms and vehicles are excluded.

A framework, then rules for each product family

The regulation does not itself set the requirements for a pair of jeans or a chair. It lays down a framework; the Commission then adopts a delegated act per product category (textile, furniture, steel…), which defines two kinds of requirements: performance requirements (minimum durability, minimum recycled content…) and information requirements, carried by the Digital Product Passport. Except in duly justified cases, each act applies no earlier than 18 months after it enters into force.

Four levers

What is a Digital Product Passport?

The DPP is not one more document. It is a digital identity record, kept at model, batch or item level depending on the delegated act, and readable by the whole chain: brand, retailer, repairer, recycler, customer, customs. The data carrier is a barcode, a QR code or another machine-readable carrier, affixed to the product, its label, its packaging or its documentation.

What a DPP contains

The exact content is set by the delegated act for each category, from the information listed in Annex III of ESPR:

DPP, label, certificate of authenticity

Textile and furniture: who is concerned, and what data?

For apparel, the Commission’s preparatory work already outlines the scope and content of the future passport. These are working options: the delegated act will decide.

Which garments?

The proposed scope: apparel containing at least 80% textile fibres by weight, ready-to-wear as well as workwear and sportswear.

• T-shirts and polo shirts
• Shirts and blouses
• Sweaters, sweatshirts and knitwear
• Jackets and coats
• Trousers, jeans and shorts
• Dresses, skirts and jumpsuits
• Tights and socks
• Lingerie and underwear
• Swimwear
• Textile accessories: scarves, ties, belts, gloves, hats

Outside the proposed scope: PPE, smart textiles, medical devices, toys, as well as fabrics, yarns and fibres. Footwear is the subject of a separate study due by the end of 2027; household linen is not covered at this stage. Source

Who does what in the chain?

The brandplacing on the market

It is the “manufacturer” under ESPR as soon as it has products made and sells them under its own name. It ensures a passport is available and entrusts a backup copy to a DPP service provider.ESPR, Art. 27

The importerbrand based outside the EU

It checks that a passport exists before placing the product on the European market.ESPR, Art. 29

Distributors and retailersboutiques, department stores, e-commerce

They check that each product is linked to its passport and make it accessible to the customer, including for distance sales.ESPR, Art. 30-31

Marketplacesonline sales, new and second-hand

They cooperate with the authorities, who can have a non-compliant offer removed. Selling under their own brand makes them a manufacturer.ESPR, Art. 34-35

Makers and supplierstiers 1, 2 and 3

No direct obligation, but the data comes from them. The delegated act may require them to pass on the information they hold free of charge.ESPR, Art. 38

SMEs

No exemption from the passport, but adapted application deadlines and support provided for by the regulation.ESPR, Art. 4 and 22

What data should you prepare?

Part of it already sits in your tech packs, your PLM or your ERP. The rest is held by your suppliers: a garment involves at least fifteen operators, and information is often lost beyond tier 1.

• Fibre composition in % by weightAlready on the label
• Care instructionsAlready on the label
• Model GTIN and batch numberCommon practice
• Brand, importer and manufacturing siteCommon practice
• Recycled content, pre- or post-consumerUnder study
• Durability score, after 5 washesUnder study
• Recyclability score, based on compositionUnder study
• Substances of concern presentUnder study
• Carbon footprint, as a performance classUnder study · early stage

The recyclability score under study rates each item from 0 to 10: above 15% elastane, the item would be labelled “non-recyclable”; mono-material items and blends with more than 60% cotton earn points. Source

Per model, per batch or per item?

The option under study: a passport filled in at model level (same pattern, same construction, without necessarily distinguishing colours and sizes) for most data, and at batch level for the manufacturing site, chemicals and quality checks. A unique identifier per item would remain voluntary: it is the one luxury houses favour, for resale and authentication.

What about furniture and art?

Getting ready in four steps

The delegated acts will set the details. The method will not change: supplier data is what takes the longest.

1. Choose the identifier and the carrier

   Model, batch or item; QR code using the GS1 Digital Link standard, NFC chip or RFID, depending on the value of the piece and your production lines.

2. Map your data

   Start from your tech packs, your PLM and your certificates (GRS, OEKO-TEX…); identify what is missing and what sits with a maker or a tier-2 supplier.

3. Contract and secure

   Write data sharing into your supplier specifications, link each data point to a source and timestamp it. A passport without proof is just a claim.

4. Publish and maintain

   Make the passport accessible by scan and on the e-commerce product page, share it with your retailers, and keep it up to date throughout the product’s life.

Frequently asked questions