Textile DPP — from ESPR delegated act to production data
Textiles are expected to be the largest DPP category by SKU count. No textile product has to carry a passport today: the obligation will come from an ESPR delegated act for textiles, which has not been adopted.
This guide covers where that act stands, the regulations that already shape textile product data, and the implementation choices a brand can make now.
Regulatory anchor
ESPR textile delegated act. The Commission's ESPR working plan (COM(2025) 187, April 2025) names textiles, in particular apparel and footwear, as a priority product group, with adoption of the act indicated for 2027. No draft has been adopted, the scope (which CN codes, which product types) is not fixed, and the act will apply only after a transition period once adopted. Bags, backpacks and accessories are not named in the working plan.
AGEC (French Law 2020-105). France's anti-waste law already requires consumer information on textiles sold in France, applied in phases since 2023 by company size: Décret 2022-748 sets the product information (for example recycled content, traceability of key manufacturing steps, presence of microplastic-releasing fibres), and Décret 2021-835 the Triman sorting logo. The information is published on a product sheet; a passport is a natural place to carry the same data, but AGEC does not require a DPP.
REACH Regulation (EC) 1907/2006 Article 33. Suppliers of articles containing substances of very high concern above 0.1 % weight by weight must pass that information on. SCIP notifications are made to ECHA; a passport can carry the substance list and reference the notification.
Additional regulations frequently in scope: PPE Regulation (EU) 2016/425 for protective clothing, the EU Ecolabel Regulation (EC) 66/2010 if the brand claims the Ecolabel, and certification schemes such as OEKO-TEX, GOTS or Textile Exchange standards where the brand claims them.
Passport data model
Until the act is adopted, nobody can say which fields it will list. DPP Agent's textile schema follows the information ESPR names for passports in general and what textile brands publish today. Its groups:
- Passport header — identifier, granularity, status, schema version, last updated (the attributes EN 18223 sets for every passport)
- Product identification — GTIN, product name, Combined Nomenclature code, brand, model, colour, size
- Economic operator — name, country, role and identifier of the operator placing the product on the market, and the facility
- Material composition — fibre composition and recycled content
- Substances — substances of concern and REACH information
- Manufacturing and supply chain — country of origin and first-tier supplier
- Environmental footprint — carbon footprint and the method used
- Durability and repair — repair instructions and spare parts
- Care — washing, drying and ironing, with ISO 3758 care symbols stored as codes
- End of life — recyclability and disposal guidance
- Compliance — declarations and certifications
- Protective equipment — for PPE garments, the protection classes and the notified body
The validator shows, for any passport URL, which of these a passport carries and which are missing.
Sourcing the data
Most textile brands do not have all of this data in one system. Typical stack:
- Fibre composition + care symbols — PIM (Akeneo, Centra, inriver) or fabric-supplier bill of materials
- Country of origin + HS/TARIC — ERP or customs/broker system
- Certifications — certificate bodies (OEKO-TEX, GOTS, Textile Exchange, Nordic Swan) — often only in PDF form
- SVHC/SCIP — supplier declarations, sometimes in XLSX
- Carbon footprint — PEFCR methodology tools, external LCA consultants
- AGEC-specific fields — French-market compliance system, in-house or via a French PLM provider
DPP Agent's textile onboarding is designed for this reality. The Akeneo, Centra, inriver and Delogue adapters handle the PIM-side data. The certificate-catalogue system ingests uploaded PDFs and matches them to issuing-body registries (OEKO-TEX and GOTS lookup are live; Textile Exchange Hub in progress). The file-upload path handles XLSX / CSV / JSON for supplier data. The AI-Suggest system proposes mappings from brand-private PIM attributes to canonical fields.
Consumer-facing considerations
A consumer scanning a textile DPP typically wants to know:
- What is it made of, and how much is recycled?
- How do I wash it?
- Where and how do I recycle it when I'm done?
- Is the brand's sustainability claim actually certified?
The DPP Agent textile template surfaces exactly this: composition and recycled content at the top, ISO 3758 care symbols with plain-language translation, EOL/take-back instructions, and cert badges that link to the issuing-body verification pages. Regulator-facing content (economic operator, HS/TARIC, SVHC declarations) is present but audience-scoped so it doesn't distract the consumer view.
Multi-language support matters for textiles more than most categories: fast-fashion products are sold across 20+ EU markets simultaneously. The resolver serves the passport in the visitor's browser language when available, falling back cleanly to the passport's default with a "translation missing" affordance.
Common pitfalls
- Recycled content declared without a source methodology (ISO 14021, GRS, RCS)
- OEKO-TEX certificate uploaded but not verified against the issuing body's registry
- French-market products missing the AGEC product information or the Triman logo
- SVHC substances present but not passed on under REACH Article 33
- Care instructions in only one language on multi-market SKUs
- Fibre composition summing to something other than 100%
Practical checklist
- Fibre composition data extracted from PIM at variant level (colour + size can differ)
- Recycled content claims backed by an ISO 14021 or GRS/RCS certification
- All active certifications registered in DPP Agent's cert catalogue and verified against the issuing body
- REACH SVHC information present, with the SCIP notification referenced where one exists
- AGEC fields populated for French-market products (Triman, Info-tri, EPR registration)
- ISO 3758 care symbols encoded structurally (not just as an image)
- PEFCR-textile carbon footprint calculated and stored per SKU
- Take-back / EOL instructions with a working URL
Regulatory reference
- ESPR — Regulation (EU) 2024/1781
- ESPR working plan — COM(2025) 187 (textile act indicated for 2027, not adopted)
- AGEC — French Law 2020-105, Décret 2022-748 and Décret 2021-835 (Triman)
- REACH — Regulation (EC) 1907/2006 Article 33 + ECHA SCIP
- ISO 3758:2012 — Care labelling using symbols
- ISO 14021:2016 — Self-declared environmental claims
- PEFCR — Product Environmental Footprint Category Rules for apparel and footwear
- PPE Regulation — Regulation (EU) 2016/425 (for protective textiles)