The LIFE DPP-TEX project has published its Initial Regulatory Analysis Report, it maps existing and forthcoming EU and national legislation relevant to Digital Product Passports (DPPs) for textiles. It examines the regulatory framework in the context of the Ecodesign for Sustainable Products Regulation (ESPR) and identifies the implications for the project’s two industrial pilots in Spain and Bulgaria.

Key takeaways

• Textile-specific DPP requirements are still under development. The ESPR establishes the horizontal framework for Digital Product Passports, but product-specific obligations will be introduced through delegated acts. The textile delegated act is indicatively expected in 2027, with requirements applying no earlier than 18 months after its entry into force. Until then, the report’s textile-specific analysis is anticipatory.
• The DPP is connected to a wider regulatory framework. The report examines legislation including REACH, the Classification, Labelling and Packaging Regulation, the amended Waste Framework Directive, the General Product Safety Regulation and the General Data Protection Regulation. These instruments affect areas such as chemical information, extended producer responsibility, responsible economic operators and personal data. A structured product data set could support compliance with several regulatory requirements.
• The technical foundations for DPPs are taking shape. Six harmonised European standards for digital product passports were cited in the Official Journal of the European Union in July 2026. The report also notes that the EU DPP Registry became operational in July 2026. Together, these developments provide an emerging technical and operational framework for product identification, data carriers, storage and interoperability.
• The proposed textile delegated act is expected to focus on apparel. Based on the Joint Research Centre’s preparatory work, the report identifies a proposed scope limited to textile apparel, with batch-level identification as a minimum and three access tiers: public, authorities and legitimate interest. These proposals remain subject to stakeholder validation and an impact assessment.
• The regulatory analysis has specific implications for the two project pilots. The Bulgarian pilot’s home textiles and recycled fibres would fall outside the proposed apparel delegated act, making their DPP a voluntary, forward-looking demonstration. The Spanish pilot’s workwear needs to be classified as personal protective equipment or non-personal protective equipment to determine the relevant requirements. The report also considers how transformed and upcycled products may require linked passports.
• National implementation differs across Spain, Bulgaria and the Netherlands. The report compares the three countries’ approaches to relevant EU legislation and textile extended producer responsibility. The Netherlands has operated a textile EPR scheme since 2023, while Bulgaria has a statutory basis for textile EPR, but its implementing ordinance remains in draft. Spain has a draft Royal Decree on textile and footwear products. All three countries must transpose the EU textile EPR rules by 17 June 2027 and have schemes operating by 17 April 2028.
• The report provides practical tools for project implementation. It translates legal requirements into elements of the DPP architecture, outlines responsibilities across the work packages and identifies regulatory developments to monitor. It also includes a DPP timeline, an overview of relevant legislation and a compliance checklist containing 91 verifiable actions.

The report concludes that DPP readiness cannot be treated as a standalone obligation. Its future content and operation will depend on a wider and evolving network of EU and national legislation. The analysis provides a regulatory basis for the project’s technical development, pilot activities and compliance work, and is intended to be updated as the project and the underlying legislation progress.

Please read the entire report HERE.