How the EU’s new digital passport rule could reshape clothing labels

Key takeaways

• The EU’s central Digital Product Passport registry went live on July 20, 2026, a day after its July 19 legal deadline, though textiles are not yet required to use it.
• Textile apparel is a priority category for its own passport rule, expected via a delegated act sometime in 2027, covering fibre content, recycled material and other data.
• An EU-commissioned study found raw materials cause 60 to 63 percent of a garment’s lifecycle impact, but the study’s proposal would require environmental disclosure only for manufacturing, about a fifth of that impact.

On July 20, 2026, the European Commission opened a central registry for a new digital record it calls the Digital Product Passport, a day after the July 19 deadline set in EU law for building it. For now, only large batteries face a concrete compliance deadline under the system. But under the Commission’s ecodesign work plan, textile apparel sold in the EU is next in line for its own passport requirement, expected to arrive through a delegated act sometime in 2027.

The passport is meant to travel with a garment from factory to closet to recycling bin, accessed through a QR code or similar tag and carrying data from fibre composition to an environmental footprint score. Brands, regulators and advocacy groups are now arguing over exactly what should go inside it, and a fair-trade group has told the Commission its current proposal skips the industry’s biggest environmental problem.

A registry goes live, with fashion watching

The registry the Commission launched in July is the infrastructure layer of the passport system: a secure place where businesses register unique product identifiers and related metadata for goods covered by the Ecodesign for Sustainable Products Regulation, which took effect on July 18, 2024. Alongside the registry, the Commission opened a testing environment, technical documentation, implementation guidance and a dedicated helpdesk for businesses.

The categories covered so far include textiles, steel, aluminium, tyres, furniture, information and communications technology products, energy-related products, batteries, construction products, toys, detergents and surfactants. But coverage does not mean an active requirement yet. The first hard deadline tied to the registry is February 18, 2027, and it applies only to certain large batteries. No compliance date has been set for textile apparel.

The environmental math behind the proposal
Raw material production accounts for 60 to 63 percent of a garment’s lifecycle environmental impact, according to the EU’s own research, but the current proposal would require environmental footprint disclosure only for the manufacturing stage, which covers roughly a fifth of that impact.

Why clothing is next in line

Textile apparel was named a priority category in the Commission’s first ecodesign working plan, alongside furniture, tyres, iron and steel, aluminium and certain electronics. A preparatory study commissioned by the Commission’s Joint Research Centre defines the scope as garments made of at least 80 percent textile fibres by weight, in line with the EU’s existing Textile Labelling Regulation, and lists ten covered categories, from t-shirts and sweaters to swimwear and accessories. Smart and electronic textiles, personal protective equipment, medical devices and toys are excluded.

The duty to create and keep a passport current would fall on whichever company places the garment on the EU market — generally the manufacturer, or the importer if the manufacturer is based outside the EU — regardless of where the brand is headquartered. Notably, the obligation would apply only to the finished garment. Fabrics, yarns and raw fibres further up the supply chain would not themselves require a passport, even though their properties feed directly into what the finished garment’s passport must say.

Sources disagree on exactly when the textile delegated act will be adopted. The Commission’s own guidance page for the sector lists the fourth quarter of 2027 for adoption of the delegated act. A 2026 Joint Research Centre report describes adoption as happening only “tentatively” in 2027. And an April 2026 submission from an EU-focused advocacy group anticipated adoption “early” in the same year. None of these sources gives a firm date, and no compliance deadline for garments has been published.

What could end up on the label

The Commission’s public guidance says a textile passport is likely to include product and operator identification, fibre composition, repair and maintenance guidance, end-of-life and recycling information, and origin data, though it stresses that “the exact information requirements will be defined through the relevant delegated acts.”

A more detailed proposal comes from the 2026 Joint Research Centre study, which recommends the delegated act require minimum shares of recycled content for fibres such as polyester, nylon and wool, and a score for a garment’s environmental footprint — but limited to the manufacturing stage of a garment’s life.

Raw material production accounts for 60 to 63 percent of a garment’s lifecycle impact, yet the current proposal would require environmental disclosure only for manufacturing.

Where critics say the draft falls short

That manufacturing-only limit is the central objection raised by the Fairtrade Advocacy Office in its April 8, 2026 submission responding to the Joint Research Centre’s preparatory study. The submission cites the JRC’s own analysis that raw material production accounts for 60 to 63 percent of a garment’s total lifecycle environmental impact, while the proposed footprint metric would cover only manufacturing — about 20 percent of that impact under the same measurement standard. The group argues the current approach “would mainly be used by frontrunners, leaving much of the market unchanged,” since the footprint disclosure is voluntary rather than mandatory.

The submission also flags a gap in the recycled-content proposal: it does not specify that recycled fibres must come from textile waste. If feedstocks such as recycled plastic bottles are allowed to count, brands could meet recycled-content targets without doing anything to address the buildup of textile waste itself. The advocacy group recommends the Commission add a distinct “sustainably sourced renewable materials” category and require disclosure covering both manufacturing and raw-material sourcing, rather than manufacturing alone.

A long, opaque supply chain

Making the passport’s data reliable is complicated by how the apparel industry actually works. The Joint Research Centre study estimates that producing a single item of clothing typically involves at least 15 separate economic operators across raw material production, manufacturing and retail, and that companies can generally trace only their immediate supplier — information about the tiers beyond that is often lost. About 80 percent of garments sold in the EU are imported, according to an estimate from the industry group EURATEX’s Reach4Textiles project cited in the same study, adding cross-border tracking to the challenge. Small and medium-sized enterprises make up more than 99 percent of companies in the EU’s textile supply chain, and the study found many lack the digital systems needed to produce structured, machine-readable data.

Some brands have moved ahead of any mandate. The UK label Nobody’s Child began issuing its own digital product passports in September 2023, tracking data from raw material processing through yarn and fabric mills to garment factories, plus a carbon footprint spanning materials, manufacturing, logistics, packaging, care and end of use, built with technology partners Fabacus and Xelacore. At the time, the brand said it was aiming for a full rollout across its garments by the end of 2024.

Even once a mandatory passport exists, its influence on shopping decisions may be limited. A YouGov survey of 11,483 people across ten European countries, cited in the Joint Research Centre study, found consumers weigh price (68 percent) and perceived quality (61 percent) far more heavily than a garment’s environmental impact (15 percent) when deciding what to buy.

Photo: KenSwe72 · CC BY 4.0 · via Wikimedia Commons