The short version
If your company exports textiles or apparel to the European Union, every product you ship will soon need a Digital Product Passport — a structured digital record containing verified data about what's in the product, where it was made, and how it should be recycled. No passport, no EU market access.
This isn't a proposal. The Ecodesign for Sustainable Products Regulation (ESPR) entered into force in July 2024. The working plan confirming textiles as a priority category was adopted in April 2025. The delegated act defining exact requirements for textile DPPs is expected in late 2026 or early 2027, with enforcement roughly 18 months later.
Indian textile exporters account for over $4 billion in annual trade with the EU. Over 4,000 Indian companies export apparel and fabrics to European markets. Every single one of them will be affected.
What is a Digital Product Passport, exactly?
A Digital Product Passport is a digital record linked to a physical product — usually through a QR code on the garment label or packaging. When someone scans that code, they see verified information about the product.
Think of it as an Aadhaar card for your product. It has a unique identity, it contains structured data, and it's accessible digitally by anyone who needs to verify it.
For textiles, the expected data fields include:
- Fibre composition — percentage by weight for all fibres above 1%
- Country of origin — where the product was manufactured
- Carbon footprint — expressed as kg CO2e per unit
- Substances of concern — chemicals regulated under REACH
- Care and repair instructions — washing, maintenance, expected lifespan
- Recyclability — end-of-life processing instructions
- Certifications — GOTS, OEKO-TEX, Fairtrade, BCI, and others
- Manufacturer identification — who made the product and where
This data must be machine-readable — not just a PDF or a webpage, but structured information that regulators can process automatically.
Why should Indian exporters care right now?
Three reasons, and they're all urgent.
1. Your EU buyers are already asking
Major European retailers — H&M, C&A, Zara, Decathlon, Primark, Next — are not waiting for the legal deadline. They're already requesting sustainability data, supply chain documentation, and compliance readiness from their suppliers. If you can't provide structured product data when your buyer asks, you lose the order to a competitor who can.
This is happening today, not in 2028.
2. The regulation applies to you, not just EU brands
A common misconception is that DPP is "a European thing" that only affects European companies. Wrong. The ESPR applies to all products placed on the EU market, regardless of where they were manufactured. If your garments are sold in Germany, France, Spain, or any EU member state, they need a compliant Digital Product Passport — and the responsibility sits with whoever places the product on the market. In practice, EU importers will push this obligation upstream to their suppliers. That's you.
3. Early movers gain a competitive advantage
The Indian textile export market is intensely competitive. Bangladesh, Vietnam, Turkey, and Cambodia are all competing for the same EU buyers. The exporters who can demonstrate DPP readiness in 2026-2027 — before the mandate is enforced — will have a tangible differentiator in buyer conversations. "We're already DPP-ready" is a procurement advantage that translates directly into retained and new business.
The timeline you need to plan around
Here's what's confirmed and what's expected:
Already done:
- July 2024 — ESPR regulation entered into force
- April 2025 — Working plan adopted, textiles confirmed as priority
Happening now (2026):
- EU central DPP registry being built (expected live by July 2026)
- Preparatory studies for textile delegated act being completed
- Harmonised technical standards being finalised
Coming next:
- Late 2026 / Early 2027 — Textile delegated act adopted (defines exact data fields)
- Mid 2028 (estimated) — Enforcement begins (18 months after adoption)
The gap between "delegated act adopted" and "enforcement" is typically 18 months. That sounds like a lot of time. It isn't. Building DPP infrastructure requires collecting data from your entire supply chain — every fabric supplier, every dyeing unit, every certification body. That process alone can take 6-12 months for a mid-sized export house.
What most exporters get wrong
"We'll deal with it when the rules are final"
By the time the delegated act is published and the exact requirements are known, you'll have 18 months to build everything from scratch — while also running your regular operations. Companies that start now will have a tested, operational DPP system by the time enforcement begins. Companies that wait will be scrambling.
"Our EU buyer will handle the compliance"
No. Your EU buyer will handle their own compliance — by requiring you to provide the data. If you can't, they'll find a supplier who can. The supply chain pressure flows downward, not upward.
"We already have certifications, so we're covered"
Having GOTS or OEKO-TEX certification is excellent — it means you already care about compliance and have some of the data DPPs require. But a certification is not a Digital Product Passport. A DPP is a structured, product-level record that covers every item you produce, not a company-level certificate. Your GOTS certification proves your processes are compliant. A DPP proves each specific product is compliant. You need both.
"This is just for big companies"
The ESPR does not have a size exemption. A 50-person export house in Tiruppur shipping t-shirts to Primark faces the same DPP requirement as Arvind Limited shipping denim to Levi's. The regulation covers the product, not the producer.
What you actually need to do
Step 1: Audit your product data
For your top 10 EU-bound product lines, check whether you have fibre composition data documented and verified, country and facility of origin for each manufacturing step, certifications currently valid with expiry dates tracked, and supplier information structured and accessible (not buried in emails).
Most exporters find they have 60-70% of the required data — but it's scattered across spreadsheets, WhatsApp messages, email attachments, and paper files. The first step is knowing what you have and what's missing.
Step 2: Build a supplier data collection process
The hardest part of DPP compliance isn't the technology — it's getting accurate data from your suppliers. Your Tier 1 fabric supplier needs to provide fibre composition. Your dyeing unit needs to declare chemicals used. Your certification body needs to confirm validity dates.
If you're currently collecting this via email and WhatsApp, it doesn't scale. You need a structured process where each supplier knows exactly what data you need, can submit it in a consistent format, and you can review and approve before it goes into the passport.
Step 3: Create your first Digital Product Passport
Don't try to create passports for your entire catalogue at once. Pick one product line — your highest-volume EU export — and build a complete DPP for it. This pilot will teach you where the data gaps are, which suppliers are responsive and which need follow-up, and what the process looks like end-to-end.
Step 4: Share it with your EU buyer
Once you have a working passport, share it with your primary EU buyer. This does two things: it demonstrates DPP readiness (competitive advantage), and it gets real feedback on whether the data meets their expectations.
How Passiris helps
Passiris is a DPP platform built specifically for manufacturers and exporters. It's designed for the mid-market — export houses that need EU compliance without enterprise complexity or enterprise pricing.
Template engine — define your passport structure once, apply it to every product line. When the textile delegated act defines exact fields, update the template. Your data stays.
Supplier collaboration portal — assign specific data fields to specific suppliers. They submit via a dedicated portal. You review, approve, and track everything. No more chasing emails.
Evidence vault — attach certificates, lab reports, and test results to the specific passport fields they support. When an auditor asks for proof, it's one click away.
Three-layer visibility — control who sees what. Consumers see public data via QR code. EU buyers see additional compliance data via secure link. Your team sees everything internally.
Audit trail — every change logged with who, when, and what. Built for the kind of accountability regulators expect.
Plans start at ₹9,999/month for Indian exporters. No enterprise sales cycle. No 18-month implementation. Create your first passport this week.
The EU Digital Product Passport mandate is coming. The question isn't whether your company will need to comply — it's whether you'll be ready when your buyer asks. Book a demo to see how Passiris works for your products and supply chain.