DPP Textile Requirements: What the EU Delegated Act Is Expected to Ask For
"DPP textile requirements" is one of the most-searched phrases among small apparel and footwear brands right now — and understandably, because the honest answer is: the final list isn't published yet. Here is what is known, what is strongly expected based on the ESPR framework and reporting on the upcoming delegated act, and how to prepare without waiting for the last detail to be locked.
Why textile is first in line
The European Commission's first ESPR Working Plan 2025-2030 (COM(2025) 187, adopted 16 April 2025) explicitly names textiles — alongside furniture, mattresses, tyres, iron & steel and aluminium — as one of six priority product groups. Textile was flagged early because of its outsized environmental footprint (fast fashion waste, water use, microplastics) and because the sector was already being studied under related EU strategies, including the EU Strategy for Sustainable and Circular Textiles.
What data points are expected
While the delegated act text isn't final, the ESPR's general framework (Article 7 and related annexes) and industry analysis of the direction of travel point to a consistent set of data categories textile DPPs are expected to include:
- Fibre composition — the percentage of each fibre type used, typically expected to cover materials above a minimum threshold (commonly discussed around 1% by weight).
- Country of manufacture — where the finished product (and potentially key production stages) took place.
- Recycled content — the percentage of recycled material, where applicable.
- Durability and care information — expected garment lifespan, wash/care instructions that affect longevity.
- Repairability — for footwear in particular, information about resoling or component replacement.
- End-of-life / recyclability instructions — how to responsibly dispose of or recycle the item.
- Substances of concern — declarations aligned with REACH restricted-substance rules.
This list mirrors the categories already required for batteries under the (separate, already-confirmed) Battery Regulation (EU) 2023/1542, which gives a useful preview of the level of granularity the Commission tends to require once a delegated act is finalised.
Expected timeline
- 16 April 2025 — first ESPR Working Plan adopted, naming textiles a priority category.
- Mid-2026 (target) — central EU DPP registry targeted to become operational.
- Late 2026 (expected) — Commission proposal for the textile delegated act.
- 2027 (expected) — adoption of the textile delegated act.
- ~2028 (expected) — realistic compliance deadline, assuming the typical 18+ month transition window.
Compare that to batteries, where the equivalent obligation is already locked at 18 February 2027 under Regulation (EU) 2023/1542 — a useful reminder that once a delegated act is adopted, the compliance clock moves fast.
What to do now, without waiting for the final text
You don't need the finished delegated act to start. Almost every data point above is something a textile SME already has somewhere — supplier invoices, fabric certificates, care label text. The practical first step is consolidating it per SKU into one structured record, so that whenever the final requirements land, you're translating existing data rather than starting from zero.
That's what the CircularPass generator is built to help with: describe one product's materials, origin and recyclability, and get an example passport card plus a checklist of what's covered and what's still missing, based on the direction the regulation is heading.
Sources: First ESPR Working Plan 2025-2030, European Commission · Regulation (EU) 2024/1781 (ESPR), EUR-Lex · EU Battery Regulation (EU) 2023/1542, HSF Kramer. Requirements described here are an educational forecast based on public reporting as of mid-2026, not the final legal text — always confirm against the official delegated act once published. CircularPass is not a certification body; see our legal notice.