ESPR Compliance Checklist for Fashion Brands (2027)

What ESPR Requires from Fashion Brands

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, entered into force on July 18, 2024. It replaces the older Ecodesign Directive and extends mandatory sustainability requirements to virtually all physical products sold in the EU.

The regulation's primary enforcement tool is the Digital Product Passport (DPP): a structured digital record linked to a physical product via QR code. For fashion and textile brands, the DPP must contain verified data about the product's composition, manufacturing origin, chemical substances, and end-of-life handling.

Textiles are among the first product categories in scope. The European Commission's first working plan identifies them as a priority, with delegated acts (the detailed category-specific rules) expected in late 2026 or early 2027. The typical compliance window after a delegated act is published is 18 months. That puts the hard deadline for most textile brands at mid-to-late 2027.

There is no grace period for non-compliant products. Under ESPR, products without valid DPPs can be refused entry at EU borders. Online sellers shipping to EU customers are subject to the same requirements as EU-based brands.

The authoritative source is the full regulation text at eur-lex.europa.eu: Regulation (EU) 2024/1781 of the European Parliament and of the Council.

The 7 DPP Data Sections (With Field Examples)

Every DPP for a fashion product must cover seven distinct data areas. These map directly to the sections you fill in when creating a passport in Passtiq.

1. Manufacturer
Who made the product and where they can be reached. Required fields: manufacturer name, manufacturer address, EU representative name, EU representative email, EU representative address.

Example: "Manufacturer: Textil Factory SRL, Str. Industriei 14, Cluj-Napoca, Romania. EU Contact: Marco Bianchi, hello@brandname.eu, Via Roma 8, Milan, IT."

2. Materials
Full fiber or material composition, broken down by component. Each component (shell fabric, lining, fill, trim) needs its own breakdown, with percentages summing to 100%.

Example: Shell - 72% organic cotton, 28% recycled polyester. Lining - 100% recycled nylon. Trim buttons - 100% corozo nut.

3. Manufacturing
Country where the garment was physically produced. This is the country of manufacture, not the brand's country of registration.

Example: "Country of manufacturing: Portugal."

4. Care
Washing, drying, ironing, and storage instructions. Can include standard care symbols plus written instructions.

Example: "Machine wash cold 30°C, do not tumble dry, hang to dry, warm iron on reverse."

5. End of Life
Recycling and disposal guidance. Which components can be separated for recycling, whether the product is designed for disassembly, and how to properly dispose of it.

Example: "Remove metal buttons before recycling. Shell and lining can be deposited at textile collection points. Buttons: household waste."

6. Substances
Declaration of whether the product contains substances of concern as defined under REACH regulations. If yes, details about which substances, their concentrations, and where in the product they appear.

Example: No substances of concern. Or: "Contains formaldehyde in finish coating: 0.08% by weight, located in outer shell fabric."

7. Sustainability
Environmental performance data: recycled content percentage, carbon footprint (kgCO2e), certifications. Optional but increasingly expected by retail buyers and consumers.

Example: "Recycled content: 28%. Carbon footprint: 4.2 kgCO2e. Certifications: GOTS, Bluesign."

Which Products Are in Scope for 2027

The 2027 deadline applies to textile and garment products placed on the EU market. The ESPR scope covers:

1. Clothing and apparel (all categories: tops, bottoms, outerwear, underwear, activewear)
2. Footwear
3. Home textiles (bed linen, towels, curtains, rugs)
4. Fashion accessories made primarily from textile materials (scarves, hats, bags)

Products not covered by the 2027 textile delegated act include medical devices, protective equipment governed by separate regulations, and products already covered by other EU product passports.

A note on batteries: battery passports under the EU Battery Regulation became mandatory in February 2027. If your products include rechargeable components (heated jackets, wearable tech), those components may require a separate battery passport alongside the textile DPP.

If you sell multiple product categories, prioritize textiles and garments for the first round of DPP creation. Furniture, electronics, and other categories are scheduled for later delegated acts, generally 2028-2030.

What You Need from Your Suppliers Before You Start

Most brands discover their data gaps when they try to fill in a DPP for the first time. The fields that typically require supplier input are:

1. Fiber composition by component - not just "the fabric" but every component, including interlinings, zippers, buttons, threads, and decorative trims. Request a material composition certificate per component, not just the main fabric.

2. REACH substances declaration - a written statement from your supplier confirming whether any restricted substances under Annex XVII or the SVHC candidate list are present, their concentrations, and their location in the product. Most factories in regulated supply chains already produce these for other buyers.

3. Country of origin documentation - the actual country of manufacture, confirmed in writing. For brands sourcing from multiple countries, this needs to be product-specific, not factory-wide.

4. Manufacturer details - full legal name, registered address, and contact information. If you use a trading company rather than dealing directly with the factory, you need the factory's details, not the trading company.

5. Certifications - if your products have GOTS, Oeko-Tex, Bluesign, or similar certifications, collect the certificate numbers and validity dates. These go in the sustainability section and strengthen the passport's credibility.

Requesting this data takes time. Suppliers who already work with European retailers often have it ready. Suppliers who primarily serve non-EU markets may need to produce it for the first time.

Build a simple supplier questionnaire and send it now. The answers you receive determine how quickly you can complete DPPs.

Your Compliance Timeline: 2025 Checkpoints, 2026 Prep, 2027 Go-Live

Use this table as a working timeline:

| Period | Milestone | Action |
|---|---|---|
| Now - Q3 2025 | Data audit | Map your product catalog. Identify which products need DPPs. Send supplier questionnaire for fiber composition, REACH declaration, manufacturer details. |
| Q4 2025 | Tool setup | Install a DPP solution. Create draft passports for your top 20 products. Identify data gaps per product. |
| Q1 2026 | Gap fill | Follow up with suppliers on missing data. Aim for "complete" status on your top 50 products by end of Q1. |
| Q2 2026 | Packaging prep | Brief your packaging supplier on QR code integration. Update label and hang tag artwork with DPP QR placement. Lead time for packaging changes is typically 12-16 weeks. |
| Q3 2026 | Monitor delegated act | The textile delegated act is expected in late 2026. When published, review for any field requirements beyond the ESPR baseline and update your passports accordingly. |
| Q4 2026 | Full catalog | Target 100% DPP coverage for all textiles in your active catalog. Archive passports for discontinued products (must remain accessible for product lifetime plus 10 years). |
| Q1 2027 | QR codes live | New and restocked products ship with QR codes on tags or labels. Existing stock can be handled with removable QR stickers or inserts where reprinting isn't feasible. |
| Mid-2027 | Enforcement live | DPP compliance enforced. Products at EU border checked for valid passport. Market surveillance authorities can request passport data for products already in circulation. |

The delegated act publication date is the critical variable. If it publishes in Q4 2026, the 18-month window lands around Q1 2028 - giving you more runway. If it publishes earlier, the window closes sooner. Plan for mid-2027 and you will be safe regardless of the exact date.

How to Publish a DPP: The 3-Step Process

For Shopify merchants using Passtiq, the publishing workflow has three stages:

Step 1: Sync products
Passtiq connects to your Shopify store via standard OAuth. After installation, it pulls your product catalog automatically: titles, SKUs, barcodes, images, variant data. You don't enter basic product information manually.

Each synced product gets a DPP record in draft state. A completion score shows how many of the 7 sections are filled.

Step 2: Fill the 7 sections
Open any product and work through the 7 data sections: manufacturer, materials, manufacturing, care, end of life, substances, sustainability. Each section shows which fields are required and which are optional. You can save progress at any time.

For products that share manufacturers or materials (a common pattern in fashion), you can fill common data once and copy across similar products.

Step 3: Publish QR code
When a product reaches complete status, hit Publish. This creates a public passport page at a unique URL, generates a downloadable QR code (SVG for print, PNG for digital), and writes the passport URL back to your Shopify product as a metafield.

Your Shopify storefront can then display a DPP badge on product pages via Passtiq's theme extension - no code changes required.

For physical placement, download the SVG QR code and hand it to your label or packaging supplier. QR codes are typically placed on the main care label, a separate hang tag, or the product packaging.

Start with Your First 5 Products on Passtiq

The most effective way to understand what your DPP data gaps are is to start creating passports.

Pick your 5 best-selling textile products. Open Passtiq. Fill in what you already have. The completion score will show you exactly which sections are missing data - that becomes your supplier questionnaire.

Passtiq's free plan covers up to 5 products. There is no time limit on the free plan and no credit card required to install. For brands with larger catalogs, paid plans start at $29/month for up to 100 products.

Starting with 5 products takes less than an hour if you have your supplier data. The output is a working passport, a QR code ready to print, and a clear picture of what you still need to collect before your full catalog is compliant.

The brands that begin the data collection process now will have a straightforward path to compliance in 2027. Those that wait until the delegated act is published will face compressed timelines, rushed supplier outreach, and packaging rework under deadline pressure.

Install Passtiq from the Shopify App Store and create your first 5 passports. You will know within an hour what your compliance gap actually looks like.