ESPR Deep-Dive

The Textile Delegated Act: What Becomes Mandatory, and When

6 July 2026 · By Nazrul Islam, Founder, DPPLive

ESPR Regulation (EU) 2024/1781 is a framework: it says textiles will need Digital Product Passports, but the product-specific rules arrive in a delegated act — secondary legislation the Commission adopts for each product group. For textiles and apparel, that act is the document every exporter is waiting for.

The expected timeline

The Commission's ESPR working plan puts textile ecodesign requirements among the first priorities. Adoption of the textile delegated act is expected around late 2026 to 2027, followed by a transition period of roughly 18 months before obligations apply — which is why most analysts point to 2028–2029 as the date textile DPPs become mandatory at EU borders.

What the act will pin down

The framework regulation (Articles 7–13 and Annex I & III) already tells us the categories of data a passport must carry. The delegated act will make them concrete for textiles: which fibre-composition detail, which durability and recyclability parameters, whether carbon footprint is declared per garment, at what level (model, batch or item) the passport applies, and which actors along the chain may update it.

Expect mandatory entries around: unique identifiers (product, operator, facility), fibre composition, chemicals of concern under REACH Article 33, country-of-origin information, care instructions, recyclability and end-of-life guidance, and substantiated environmental claims.

Why waiting for the final text is a mistake

Roughly 80% of the data a textile DPP will require is already knowable from the framework regulation — and it is data buyers increasingly demand in audits anyway. Factories that build their data pipeline now (supplier declarations, chemical inventories, per-style bills of material) will treat the delegated act as a formatting exercise. Factories that wait will be reconstructing two years of production records under deadline pressure.

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