The EU's ecodesign and digital product passport act for apparel has not been adopted yet. The European Commission's current timeline places adoption in the third or fourth quarter of 2027 and the passport becoming mandatory in 2029. The ban on destroying unsold apparel and footwear, however, has applied to large enterprises since 19 July 2026. A Turkish supplier will not create the passport itself, but a large part of the data that goes into it will come from its records.
What stage is the apparel passport at?
The digital product passport is part of the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. The regulation provides for a separate delegated act for each product group. As of 7 November 2026, the work on apparel stands as follows:
| Source | Date given for adoption |
|---|---|
| ESPR working plan, April 2025 | 2027 (indicative) |
| The Commission's DPP textiles page | Last quarter of 2027 |
| Commission DPP presentation, June 2026 | Third or fourth quarter of 2027 |
The initiative was opened on the Commission's Have Your Say portal in December 2025; however, the call for evidence, the public consultation and the draft text have not been published yet. Article 4 of the ESPR says the act cannot apply until at least 18 months after its entry into force. The Commission's June 2026 presentation also puts the passport becoming mandatory for apparel in 2029.
The scope is apparel and accessories. The preparatory study by the Commission's Joint Research Centre (JRC) has ten categories, from T-shirts to jackets and from underwear to hats and gloves. Footwear is not in this act; the work on it is expected to be completed at the end of 2027.
What information is being discussed for the passport?
The final list will be set by the act. Today there are two JRC documents: the third milestone summary of the preparatory study, dated December 2025, and the study on textile passport content, dated May 2026. Neither is the Commission's final position, but they show the direction:
- Durability score: A score based on spirality, dimensional change and visual inspection tests, to be given as information only. No minimum performance requirement is proposed for now.
- Recyclability score: As information. Products containing more than 15 percent elastane are proposed to score zero.
- Recycled content: An information requirement and a possible minimum share. The study modelled scenarios such as 20 percent of the cotton in denim.
- Environmental footprint: Information on the carbon or environmental footprint of production.
- Substances of concern: Disclosure above a threshold for intentionally added substances remaining in the product, with phased application.
- Fibre composition, care instructions, origin, compliance documents and operator information.
Repair information was proposed as voluntary. According to the content study, fibre composition and ecodesign data will be public. Detailed chemical concentrations and verification documents, on the other hand, will be restricted to parties with a legitimate interest, such as market surveillance authorities and recyclers.
At what level will the passport be created?
The JRC content study proposes that the apparel passport be created at model level by default. The GTIN is proposed as the model identifier, and the GTIN with a batch number for batch level where variability between products matters. Item level is left voluntary.
The other identification fields proposed in the study also concern the supplier directly:
- The manufacturer's GLN or EORI number, name and address.
- The identifier of the production facility (facility GLN).
- The importer's GLN or EORI number.
- The six-digit HS and ten-digit TARIC code.
We explain how a GTIN is obtained in our GTIN article and the difference between batch and serial numbers in our GS1 codes article.
Who does the ban on destroying unsold products cover?
Article 25 of the ESPR has prohibited large enterprises from destroying unsold apparel, accessories and footwear since 19 July 2026. For medium-sized enterprises it starts on 19 July 2030; micro and small enterprises are out of scope. The scope is defined by the customs codes in Annex VII of the regulation: chapters 61 and 62, leather apparel and accessories (4203), hats (6504, 6505) and footwear (6401-6405).
Three details are often missed:
- Unsold products are broadly defined: Surplus stock, unsold seasonal products and products returned under the right of withdrawal also fall within this definition.
- Sending to recycling also counts as destruction: Under the regulation's definition, only products sent for preparation for reuse fall outside this scope.
- Exemptions are limited: Regulation (EU) 2026/296 lists ten grounds for exemption. They include hazardous products, counterfeit products and products infringing intellectual property rights, logos and labels that cannot be removed, and donations refused by at least three social economy entities. An enterprise using an exemption must keep the documents for five years and present them within 30 days on request.
The ban applies directly to brands and retailers in the EU. The Turkish supplier, for its part, will encounter contract clauses on how returns, overproduction and end-of-season stock are to be handled.
Why does this matter for Turkish apparel suppliers?
According to İHKİB, the Istanbul Apparel Exporters' Association, Türkiye's apparel exports in 2025 were USD 16.8 billion; USD 10.2 billion of this, or about 61 percent, went to the EU. Knitted (chapter 61) and woven (chapter 62) apparel make up 88 percent of exports and fall entirely within the scope of the future act.
The obligation to create the passport and keep it accurate will sit with the operator placing the product on the EU market: the brand in the EU, or the importer if the manufacturer is outside the EU. However, fibre composition, test results, facility identity, substances of concern and recycled content information originate with the yarn spinner, the fabric maker and the garment manufacturer. Buyers will start asking for this data as a contract requirement before the passport becomes mandatory.
According to the Ministry of Trade's information note of May 2026, a draft for alignment with the ESPR has been prepared by the Ministry of Industry and Technology. Türkiye is requesting equal access to the EU's DPP registry and web portal within the framework of the Customs Union.
What can be done today?
- Bring your product and model list to GTIN level. Every model and size-colour variant should have its own number.
- Link fibre composition and test results to the model. Documents from the fabric supplier should be gathered in a single record.
- Clarify facility information. The record should show which model was made in which facility and which subcontracted workshop.
- Compile chemical data. Notifications under REACH and chemical compliance reports are the starting point.
- Document recycled content claims. Shares without a certificate cannot be used in the passport.
- Put responsibility in writing with your buyer. The contract should state who will create the passport, and in what format and how often the data will be transferred.
You can find the overall timeline in our EU digital product passport article, and the registry and unique identifier rules in our DPP Registry article.
Does the passport prove that a garment is genuine?
No. The passport carries information about the model or batch; the QR code leading to it can also be printed on another garment or label. In apparel, counterfeits often carry a copy of the genuine label. Whether the information the passport shows and the product in your hands are the same product is a separate verification question. We cover this distinction in our article on tracking and verification.
Where does Spectrace fit in this preparation?
Tagvex numbers products at batch or unit level with copy-resistant codes, fits the code into the existing label layout and records every change of hands from the line exit to the dealer. Records can be passed to ERP and warehouse systems through an API. This is the identifier and record layer. It does not replace the passport itself, DPP Registry registration or GS1 numbers.
Sources
- EUR-Lex, Regulation (EU) 2024/1781 (ESPR)
- EUR-Lex, Commission Delegated Regulation (EU) 2026/296
- European Commission, Digital Product Passport: textiles and apparel
- JRC, Study on DPP content for textile apparel products under ESPR, May 2026
- JRC, Textile products preparatory study, 3rd milestone summary, December 2025
- İHKİB, Apparel and Clothing Sector Current Status (Turkish), January 2026
- Ministry of Trade of Türkiye, Digital Product Passport Information Note (Turkish), May 2026
- Ministry of Trade of Türkiye, EU Strategy for Sustainable Textiles (Turkish)
