EU Product Passports and Textile EPR: What Fashion Brands Need to Know

Two rules, two timelines

Two pieces of EU policy are reshaping how fashion brands handle product information and end-of-life costs. They are often discussed together, but they are at very different stages:

• Extended producer responsibility (EPR) for textiles is adopted law, with set deadlines.

• The digital product passport (DPP) for textiles is planned, but its detailed requirements have not yet been written.

Confusing the two leads to bad planning. Here is where each stands as of November 2026.

Textile EPR: adopted and on the clock

The revised Waste Framework Directive entered into force on 16 October 2025. It requires every EU member state to set up EPR schemes for textile and footwear products under common EU rules. In practice, that means brands that put these products on the market will pay fees towards collecting, sorting and recycling them.

According to the European Commission, member states have 20 months to bring the revised directive into national law and 30 months to establish their textile and footwear EPR schemes. Counted from entry into force, that points to roughly mid-2027 and spring 2028; check national rules for exact dates.

Three details matter for brands:

• Eco-modulation. Fees are to be adjusted using sustainability criteria, including durability and recyclability. Products designed to last and to be recycled should cost less.

• What the fees fund. Beyond collection, the Commission says the money will also support consumer information and research and development in design, waste prevention and waste management.

• The scale of the problem. The Commission estimates the EU generated around 12.6 million tonnes of textile waste in 2019, with only about one-fifth collected separately for reuse or recycling.

The digital product passport: still being defined

The DPP comes from a different law, the Ecodesign for Sustainable Products Regulation (ESPR). The Commission's ESPR working plan for 2025–2030, published on 16 April 2025, makes textiles and apparel a priority and gives 2027 as the indicative timing for adopting the relevant measure.

The Commission's textile DPP page says the passport requirements for textiles will be set in the same future delegated act as the ecodesign requirements. So 2027 is the target for adopting the rules, not a date by which every garment must carry a passport. The act itself will set when its requirements apply. Footwear is treated separately: the working plan says a study of possible footwear ecodesign requirements should be completed by the end of 2027.

What brands are already doing

Some brands are not waiting:

• Coachtopia, Coach's circular sub-brand, says each product has a unique digital passport reached through an NFC chip, with details on materials, impacts and circular design. It says the passport updates when the product is repaired, traded in or recycled.

• Chloé uses a Digital ID to pre-fill listings for its instant resale service with Vestiaire Collective.

These are voluntary programmes and the brands' own descriptions. They do not show compliance with rules that have not been written yet, and they are not independent environmental audits.

What it means for brands and suppliers

This section is Style Serum's analysis, not reported fact.

• Start with data you already control. Fibre composition, supplier and factory details, and care information are the likely foundations of any passport. Get them accurate and consistent now.

• Design for lower fees. Eco-modulated EPR fees reward durability and recyclability, which makes material choices a cost question, not only a sustainability one.

• Watch national rules. EPR schemes will be run country by country, so obligations, fees and reporting may differ between markets.

• Don't overclaim. Avoid marketing a voluntary passport as "EU compliant" before the requirements exist.

Mills and manufacturers will be key data partners. Find suppliers in our Business Directory, follow Textile Manufacturers and Sustainable Fashion, and see the sourcing fairs in our events calendar.

Sources

• European Commission: revised Waste Framework Directive enters into force, 16 October 2025

• European Commission: ESPR and Energy Labelling working plan 2025–2030, 16 April 2025

• European Commission: digital product passport for textiles and apparel, accessed 8 November 2026

• Coachtopia: connect your product, accessed 8 November 2026