The EU's newly published DPP data specification methodology includes the most detailed picture yet of which textile products will be covered by Digital Product Passport requirements under the ESPR. Textiles are confirmed in the 2027 wave, with preparatory work already underway. For brands selling apparel into the EU market, the scope is now concrete enough to start planning against.
The Timeline
The ESPR Working Plan, published in April 2025, sets out an indicative timeline for delegated acts by product group. Iron and steel come first (2026). Textiles follow in 2027, alongside tyres, aluminium and energy-related products. Furniture arrives in 2028, with mattresses and ICT products in 2029.
The word "indicative" matters. These timelines are subject to change depending on the pace of preparatory studies and the adoption of each delegated act. But the preparatory study for textiles is already active, and the methodology report includes textile-specific examples throughout, suggesting the work is well advanced.
What's in Scope
The textile preparatory study defines the product scope with specificity that most brands have not yet seen. The methodology report reproduces this scope in full, covering the following garment categories:
- T-shirts, singlets, vests, polo shirts and other short-sleeved shirts
- Shirts, blouses and long-sleeved base layers
- Sweaters, pullovers, cardigans, hoodies and sweatshirts
- Jackets, coats, blazers, parkas, rain jackets and outdoor vests
- Pants, jeans, shorts, outdoor pants and sports pants
- Dresses, skirts and jumpsuits
- Leggings, stockings, tights and socks
- Underwear including bras and body-shaping suits
- Swimwear including bikinis, bathing suits and board shorts
- Accessories: hats, scarves, ties, belts, gloves and mittens
The scope is broad. It covers most of what a typical apparel brand produces.
What's Not in Scope
The exclusions are equally important for brands to understand. The following are explicitly out of scope:
Smart textiles that sense and react to environmental conditions through embedded sensors. Electronic textiles (e-textiles) with intended electronic functionality. PPE textiles falling under Regulation (EU) 2016/425. Medical device textiles falling under Regulation (EU) 2017/745.
For brands producing performance wear with electronic components, or textiles classified as PPE, these exclusions matter. Standard activewear and outdoor clothing without electronic functionality remains in scope.
What This Means for Brands
The scope confirms that the DPP requirement will apply to the vast majority of apparel categories. Brands cannot assume their products will be excluded unless they fall into one of the specific carve-outs listed above.
The methodology also makes clear that the DPP applies to all products placed on the EU market, regardless of where they are manufactured. A garment produced in Bangladesh, Vietnam or Turkey and sold in the EU will need a DPP just the same as one produced in Portugal or Italy. The importer assumes the manufacturer's compliance obligations where the manufacturer is not established in the EU.
This is a critical point for brands with international supply chains. Compliance is determined by where the product is sold, not where it is made.
The Data That Will Be Required
While the final data requirements will be defined in the textile delegated act, the methodology identifies the categories of information that preparatory study teams must assess. These include product and producer identification, environmental footprint data, material composition, substances of concern, durability and repairability information and end-of-life treatment guidance.
The methodology also references use cases specific to textiles, including a detailed self-repair scenario where a consumer accesses a DPP to find repair instructions, compatible replacement parts and care guidance. This signals that the textile DPP is expected to go beyond simple compliance data and provide useful information for extending garment life.
How ENVRT Approaches Textile DPP Readiness
ENVRT LAB™ generates climate impact (CO₂e) and water scarcity impact at the product level, on a cradle-to-gate basis and aligned with ISO 14040 and PEFCR methodology. The data ENVRT produces covers the core environmental categories that the textile DPP is expected to require: carbon footprint, water scarcity impact and material composition.
Brands building product-level environmental data now are not guessing at what will be required. They are preparing against the methodology the EU has published.
If you want to understand how your collection data maps to the emerging DPP requirements for textiles, get in touch with the ENVRT team.
