The ESPR textile delegated act, tracked

Current status

The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, entered into force on 18 July 2024 and created the Digital Product Passport as a framework obligation. It deliberately left the substance to product group rules: which fields a passport must carry, who may read each of them, and from when. For textiles, that substance arrives in a delegated act, and the working expectation, restated in the Commission's ecodesign work programme, is adoption in 2027.

Status pages about EU law tend to rot quietly, which is why this one is built the way it is. The updated date in the header band moves whenever a development changes the picture, the change log at the foot of the file records what moved and when, and a claim that cannot be tied to a public instrument does not appear here at all.

What is already binding

Most of the textile DPP regime is already binding: ESPR has been in force since 18 July 2024, the central passport registry and the destruction ban went live on 19 July 2026, and the work programme naming textiles is adopted. Only the delegated act itself, the textile field list, is still pending.

The registry going live before the act is adopted is the detail worth pausing on. It means the resolution machinery is fixed first: a passport will be addressable through a registered identifier whatever the final field list says. Data requirements can still move; the plumbing no longer can.

How a delegated act becomes binding

1. The Commission drafts the act, consulting the Ecodesign Forum, where member states and stakeholders review the requirements for the product group.
2. The Commission adopts the act. This is the date the expectation of 2027 refers to.
3. The European Parliament and the Council have a scrutiny period in which they may object. If neither does, the act enters into force.
4. Application follows after a transition period written into the act itself, so the market has time to build against the final field list before it binds.

The practical consequence of that sequence: adoption in 2027 does not mean passports are demanded of every garment in 2027. It means the field list stops moving in 2027, and the clock to application starts. Anyone who begins building when the act applies has spent the transition period standing still.

What the act is expected to fix

• The data requirements: which attributes a textile passport must carry, drawing on the minimum viable Textile DPP that the CIRPASS-2 project has piloted in public.
• The access split: which fields sit in the public tier anyone can read by scanning the item, and which sit in the restricted tier for authorities and credentialed operators.
• The technical anchors: identifiers, data carriers and access rights management, where the act is expected to lean on the European standards being produced by CEN and CENELEC in JTC 24.
• The application dates: from when passports are demanded, and for which placements on the market.

None of this is speculation about substance, which is exactly why the sources below are the projects and committees doing the work rather than commentary about them. Reading the CIRPASS-2 pilot outputs and the JTC 24 work programme is the closest available view of the requirements before they are law.

What to watch

• Ecodesign Forum agendas and minutes: the textile requirements will be consulted there before adoption.
• The CIRPASS-2 textile pilot outputs: the data model the act is most likely to inherit.
• The JTC 24 standards deliverables: identifiers, carriers and access rights, the parts an implementation has to get right regardless of the final field list.
• The DPP registry's technical documentation: the interface every passport, however specified, will have to register against.
• The German Textilgesetz, due by 17 June 2027: not part of ESPR, but it lands producer responsibility for textiles in the same year and the same operations will answer to both.

What this means while the act is pending

While the act is pending, brands should build the parts that cannot change: identifiers, carriers, event vocabularies and evidence links. Sorters, recyclers and resale operators should originate records for the untagged stock the regime will never cover, because no delegated act creates data for garments whose producers never issued any.

For new production, that makes the pending act a data engineering project with a known shape and an unknown deadline: the attributes are visible in draft form, and the transition period will decide the pace. For the stock already moving through sorting lines, which predates item level identifiers and will keep arriving for years after the act applies, the record has to be originated where the material is, from the documentation the garment already carries, whatever the final field list turns out to demand.

Change log

Common questions