The EU is changing what it takes to sell a physical product in Europe. At the centre of that change are two things every brand will need to understand: the Ecodesign for Sustainable Products Regulation (ESPR), and the Digital Product Passport (DPP) it introduces. This guide explains both in plain English: why they exist, what they require, who they affect, and when.
The ESPR is part of the European Green Deal, the EU's 2019 plan to reach climate neutrality, and the 2020 Circular Economy Action Plan that followed it. The reasoning is simple: how products are designed, made, used, and discarded is a major driver of climate change, pollution, and waste. If you want a circular economy, you have to change the product, not just how it is recycled at the end.
So the ESPR is built to make sustainable products the norm rather than the exception. The Commission frames it as a tool to help the EU double its rate of circular material use and meet its energy efficiency targets by 2030. It also has commercial weight behind it: the EU spends around 1.8 trillion euro a year on public procurement, and the regulation steers that spending toward products that meet its standards.
The ESPR replaces the Ecodesign Directive 2009/125/EC. Two changes matter most.
First, scope. The old directive only covered energy-related products such as fridges, boilers, and lighting. The ESPR extends the same approach to virtually all physical goods placed on the EU market. A few categories are excluded, notably food, feed, and medicinal products.
Second, ambition. The old rules were mostly about energy use. The ESPR can set requirements across a product's whole life, including:
That last point is where the Digital Product Passport comes in.
The Commission describes a DPP as a digital identity card for products, components, and materials. It is a structured digital record, reached from a data carrier such as a QR code on the product, that holds the information needed to support sustainability, circularity, and legal compliance.
The passport is designed to be read by everyone in the chain. A shopper can scan it to understand what they are buying. A repairer or recycler can see how the product is built and how to handle it at end of life. And crucially, customs authorities will be able to run automatic checks on whether a product's passport exists and is authentic before it enters the EU market. That makes the DPP a border control mechanism, not just a marketing label.
To make that work, passport data is meant to be machine-readable and held in an EU registry, so it stays accessible and verifiable even if a brand changes its own systems.
The exact fields are set per product category, but the regulation points to a consistent core:
For textiles specifically, that means data drawn from across the supply chain, from the garment factory back to the fabric mill and the fibre itself.
Because the ESPR covers almost all physical goods, the Digital Product Passport is arriving sector by sector. The Commission sets priorities in a working plan and then issues a delegated act for each product group. The first working plan, adopted in April 2025 and covering 2025 to 2030, prioritises textiles, furniture, and tyres, along with the intermediate materials iron, steel, and aluminium. Textiles, and apparel in particular, are at the front of the queue.
The ESPR itself entered into force on 18 July 2024, but it is a framework. The rules that bite arrive through delegated acts, each with its own timeline.
For textiles, the delegated act is expected around 2027, with Digital Product Passport requirements applying roughly from 2028. Treat these as planning estimates: the exact dates are confirmed only when each act is published.
One related measure is already close. The ESPR bans the destruction of unsold textiles and footwear, and requires large companies to disclose how many unsold products they discard and why. The implementing and delegated acts for this measure were adopted in February 2026, with the ban applying first to large companies and longer transition periods for smaller ones.
Responsibility sits with the economic operator placing the product on the EU market. For most brands that means the company whose name is on the product, regardless of where it was manufactured. If you sell into the EU, the obligation is yours, and so is the job of gathering the data behind the passport from suppliers you may not directly control.
Creating the passport record is straightforward. Filling it with trustworthy data is not. A compliant DPP needs verified information from every tier of a supply chain, and because customs can check authenticity at the border, weak or invented data is a real risk, not just a reputational one.
There is also a quality gap. Brands that collect primary data, the actual energy, water, and material figures from their factories, get accurate environmental scores. Brands that cannot, fall back on secondary data, which uses industry averages and usually produces worse results, because averages include the least efficient operators. Better data is not only safer, it often looks better too.
Collecting that primary data from factories, mills, and material suppliers takes 12 to 18 months in practice. That is why the real deadline is not 2028. It is now. Brands that start mapping suppliers and collecting verified data this year will have an accurate, defensible passport ready when the rules apply. Brands that wait will be forced onto worse data under time pressure.
Is the ESPR the same as the Digital Product Passport? No. The ESPR is the regulation. The Digital Product Passport is one of the tools it introduces, alongside ecodesign performance rules and the ban on destroying unsold goods.
Does the ESPR only apply to EU manufacturers? No. It applies to any product placed on the EU market, wherever it was made. The obligation falls on whoever places it on the market.
What happens if a product has no compliant passport? Once requirements apply to a category, a product without a compliant DPP cannot be lawfully placed on the EU market, and customs can flag it at the border.
Pasera