ESPR Digital Product Passport: A Practical Guide for Fashion Brands (Regulation 2024/1781)

What is ESPR and why does it matter for fashion?

The Ecodesign for Sustainable Products Regulation (ESPR), formally known as Regulation (EU) 2024/1781, was signed into law in July 2024. It represents the most significant shift in EU product regulation for the textile and apparel sector in decades. For fashion brands, the ESPR is not merely an environmental guideline; it is a legal mandate that redefines product lifecycle management, data transparency, and end-of-life responsibility.

The core mechanism of the ESPR is the Digital Product Passport (DPP). A DPP is a machine-readable data record linked to a specific product via a data carrier, such as a QR code or RFID tag. This system ensures that critical information about a product’s composition, origin, and environmental impact is accessible to consumers, regulators, and recyclers throughout the product’s lifecycle. For sustainability directors and legal teams, the ESPR transforms sustainability from a marketing narrative into a verifiable, auditable data requirement.

What must a Digital Product Passport contain?

While specific technical requirements for textiles are being finalized through delegated acts, the ESPR framework mandates that the DPP must link to several critical data points. These include:

• Material Composition: Detailed breakdown of fibers and materials used in the product.
• Manufacturer Information: Identity of the producer and relevant supply chain actors.
• Repair and Reuse Instructions: Guidance on how the product can be maintained, repaired, or repurposed to extend its life.
• Recyclability Data: Information on how the product can be disassembled and recycled at end-of-life.
• Environmental Footprint Data: Metrics related to the product’s environmental impact, aligned with EU standards.

The data must be structured according to CEN/CENELEC EN 18xxx standards, ensuring interoperability across the EU market. The DPP is not a static label; it is a dynamic digital record that must remain accessible for the duration of the product’s expected life and beyond, supporting circular economy goals.

Which brands are in scope?

The ESPR applies to all products placed on the EU market, regardless of where they are manufactured. This is a critical consideration for UK-based brands: even post-Brexit, if your products are sold into the EU market, you are fully subject to ESPR requirements. There is no exemption for non-EU manufacturers.

The regulation covers a wide range of product groups, with textiles and footwear being a primary focus. The scope includes:

• Large enterprises and SMEs placing products on the EU market.
• Brands, retailers, and distributors who place products under their own name.
• Manufacturers and importers responsible for product compliance.

Compliance is not optional. Failure to provide a valid DPP or to adhere to the data standards can result in products being prohibited from sale within the EU, leading to significant financial and reputational risk.

Timeline: when do you need to comply?

The ESPR is already in force, but compliance obligations are phased in. Key dates for fashion brands include:

• July 2024: Regulation (EU) 2024/1781 enters into force.
• July 19, 2026: The ban on the destruction of unsold textile products applies to large companies. SMEs have a 12-month grace period following this date, meaning full compliance for all entities is required by mid-2027.
• Late 2027: The delegated act specific to textiles and apparel is expected to be finalized, detailing the exact data fields and technical specifications for the DPP.
• 2027–2028: The mandatory compliance window for the Digital Product Passport for textiles and footwear. Brands must have DPPs ready and operational for all new products placed on the market during this period.

While the full DPP mandate is not yet active, the destruction ban is an immediate operational concern. Brands must begin tracking unsold inventory and implementing disposal protocols that comply with the ban well before 2026.

How to prepare now (18 months before the deadline)

With the mandatory DPP window approaching in 2027–2028, preparation cannot wait. The following steps are essential for compliance:

1. Map Your Data Gaps: Audit your current product data management systems. Identify which required data points (composition, footprint, repair info) are missing or not structured for machine readability.
2. Standardize Data Formats: Align your internal data structures with CEN/CENELEC EN 18xxx standards. This ensures that your data can be easily integrated into the EU DPP registry.
3. Implement Data Carriers: Begin testing and deploying data carriers (QR codes, RFID) on your products. Ensure these carriers are durable and scannable throughout the product’s lifecycle.
4. Update Supply Chain Contracts: Engage with suppliers to ensure they can provide the necessary data for the DPP. This may require new data-sharing agreements and technical integrations.
5. Monitor Regulatory Updates: Keep track of the delegated act for textiles, expected in late 2027. This document will provide the final specifications for data fields and reporting requirements.

Proactive preparation reduces the risk of non-compliance and positions your brand as a leader in sustainable fashion. It also allows for smoother integration with the EU DPP registry, which is being built by EUIPO.

Where KadmilOS fits in

KadmilOS (kadmilos.com) provides a specialized solution for fashion brands navigating the ESPR compliance landscape. Our platform offers a DPP API that simplifies the process of creating and managing Digital Product Passports.

Through our API endpoint POST /api/v1/dpp, brands can submit their product data, which KadmilOS formats to meet ESPR specifications. The system automatically generates compliant data carriers, ensuring that your products are ready for the EU market. By leveraging KadmilOS, you can streamline data management, reduce the complexity of compliance, and ensure that your DPPs are accurate, accessible, and aligned with EU standards. This allows your legal and sustainability teams to focus on strategic initiatives rather than the technical intricacies of data formatting and carrier generation.