DATA FIELDS GUIDE

What Will the Apparel DPP Actually Contain? The JRC Study's Proposed Data Fields, Model/Batch/Item Levels and Access Rights — and What ESPR Already Fixes

Published 20.10.2026 · Reading time ~16 min · by Lior Gabriel Graetz · LG Fashion Labs

No EU law yet lists the data fields of an apparel Digital Product Passport. ESPR, Regulation (EU) 2024/1781, fixes the framework: a delegated act for textiles will select the passport data from the elements listed in Annex III, decide whether the passport is kept at model, batch or item level, and set who may see and update which data (Article 9(2)). That act has not been adopted. The most detailed public proposal we have found is the 95-page "Study on DPP content for textile apparel products under ESPR", listed with the date 13 May 2026 on the Joint Research Centre's documents page for textile products (its cover gives only the year 2026). Its pages carry a DRAFT watermark. It is an "External Study report prepared for the Joint Research Centre (JRC)", and its disclaimer states: "The contents of this publication do not necessarily reflect the position or opinion of the European Commission." It is not legally binding.

This guide sets out what the study proposes and puts each proposal next to what ESPR already fixes. Where the study goes beyond the text of ESPR, on how long the passport must stay available and in which languages, we say so. Everything attributed to the study is a proposal, not law. Which garments are covered is explained in our scope guide, identifiers in our product-identifiers guide.

4 blocks

Product identification and classification, producer identification, product information and compliance documentation: the study's grouping of its proposed fields (section 7, Tables 5 to 8). Not law.

Batch

The study proposes batch identifiers as the minimum; item-level identifiers would be voluntary, a point it says is "currently under analysis" (section 9.1). ESPR leaves the level to the delegated act (Article 9(2)(d)).

3 access levels

Public, authority only and legitimate interest: the categories the study assigns field by field (section 9.2, Table 14). ESPR leaves access rights to the delegated act (Article 9(2)(f)).

18 months

A delegated act's date of application shall not be earlier than 18 months from its entry into force, except in duly justified cases (ESPR Article 4(4)). No textile delegated act had been adopted by 19 October 2026.

1. What ESPR already fixes, and what the textile delegated act still has to decide

Article 9(2), Regulation (EU) 2024/1781 (ESPR), points (a), (d), (f) and (i)

The delegated acts shall, as appropriate for the product groups covered, specify "the data to be included in the digital product passport pursuant to Annex III"; "whether the digital product passport is to be established at model, batch or item level, and the definition of such levels"; "the actors that are to have access to data in the digital product passport and to what data they are to have access"; and "the period during which the digital product passport is to remain available, which shall correspond to at least the expected lifetime of a specific product".

ESPR therefore fixes the frame, not the content. A passport becomes a condition for placing apparel on the market only once a delegated act requires it, and its data "shall be accurate, complete and up to date" (Article 9(1)). Annex III is a menu: the delegated act "shall specify what data are to or can be included in the digital product passport from among the following elements", points (a) to (l), from information required under Article 7 or other Union law and identifiers to compliance documentation and operator details. A few content rules already follow from ESPR whenever a product-specific delegated act sets information requirements and requires a passport, subject to the exceptions the Regulation allows (for example an exemption from the passport under Article 9(4)): information on substances of concern must include at least their name (or numerical code), location, concentration, maximum concentration or concentration range, instructions for safe use and end-of-life information, subject to the exemptions and thresholds the Commission may set (Article 7(5) and (6)); manufacturers and importers must give their name, postal address and electronic contact on the public part of the passport, where applicable (Articles 27(6) and 29(3)); and digital instructions are to be included in the passport (Article 27(7)). Data carriers and the registry are covered in our data-carriers guide.

QuestionFixed in ESPR todayProposed by the JRC study (not law)
Which dataSelected by the delegated act from Annex III, points (a) to (l); substances-of-concern information as in Article 7(5), subject to Article 7(6).Four blocks of fields (section 7, Tables 5 to 8).
Model, batch or itemDecided and defined by the delegated act (Article 9(2)(d)); the data must refer to that level (Article 10(1)(f)).Batch identifiers as the minimum; each field at model or batch level; item-level identifiers voluntary (section 9.1, Table 13).
Who sees whatDecided by the delegated act (Article 9(2)(f)); free of charge and easy access based on those rights (Article 11(b)); manufacturer and importer contact on the public part, where applicable (Articles 27(6) and 29(3)).Three categories (public, authorities only, persons with a legitimate interest), assigned field by field (section 9.2, Table 14).
Who creates and updatesDecided by the delegated act (Article 9(2)(g) and (h)).An importer of a non-EU manufacturer's product would act as custodian of supplier data (section 9.3.2).
How longSet in the delegated act; at least the expected lifetime of a specific product (Article 9(2)(i)), "including after an insolvency, a liquidation or a cessation of activity in the Union" of the operator responsible for its creation (Article 11(e)).Section 9.3.2 attributes a ten-year minimum to ESPR; the Regulation has no such rule for the passport (see section 5 of this guide).
FootprintA delegated act may require carbon or environmental footprint information (Article 7(2)(b)(i); Annex I, points (m) and (n)).Class of performance public, absolute value restricted, model level, default values allowed (sections 7.3, 9.1, 9.2).

The timing is open. The table shows what each official source said on 19 October 2026; the full chronology is in our DPP master timeline.

ItemStatus on 19 October 2026
ESPR delegated act for textiles (apparel)Not adopted; no draft published. A search of the EU Publications Office records found no such act.
Commission DPP page (updated 15 October 2026)Lists "Q3–Q4 2027" for the adoption of the ESPR delegated acts for textiles, aluminium and tyres, in a timeline it describes as indicative.
Commission textile-apparel page (updated 7 August 2026)"Q4 2027: Planned adoption of the ESPR Delegated Act for textiles", in an indicative implementation timeline.
Have your say, initiative 16116 (last modified 12 December 2025)Adoption planned for the first quarter of 2027; a public consultation planned for the fourth quarter of 2025 has not been launched, and no call for evidence has been published.
JRC preparatory study, 4th milestone"Policy scenarios, and elements to be included in the Digital Product Passport": "To be communicated" (JRC project plan).
Date of applicationNot earlier than 18 months from the delegated act's entry into force, "except in duly justified cases" (Article 4(4)).

The study describes its own role modestly: it "forms part of the preparatory study supporting the future delegated act on textiles apparel products", and "The findings presented require validation through extensive stakeholder consultation and subsequent refinement during the impact assessment phase of the delegated act." (section 1). The Commission's textile-apparel page says the impact assessment and delegated act are "supported by a technical study, including stakeholder consultation, performed by the Joint Research Centre (JRC)". The study's title page is headed JRC Science for Policy Report and carries the subtitle "JRC recommendations to support DPP requirements in the framework of the ESPR Regulation"; its JRC number, ISBN and DOI are still placeholders.

2. The data fields the study proposes, block by block

Section 7 of the study lists the proposed fields in four tables, with a reference methodology, data type, ESPR provision and readiness rating for each. Section 9 assigns each field a level (Table 13) and an access category (Table 14). The table combines Tables 13 and 14 in the study's wording, grouped by the ten data categories those tables use. None of these fields is a legal requirement today.

Data category (Tables 13 and 14)Field (study's wording)Proposed level (Table 13)Proposed access (Table 14)
Identification and classificationUnique product ID (voluntary)ItemPublic
Batch IDBatchPublic
Model ID; ESPR and PEFCR product category; commodity codeModelPublic
Producer identificationUnique operator identifier; operator name and address (manufacturer, importer, other); unique facility identifierBatchPublic
Operator contact (manufacturer, importer and other)BatchAuthority only
MaterialFibre composition; components specificationModelPublic
Mechanical propertiesRobustness scoreModelPublic
Visual inspection; spirality; dimensional changeBatch (self-declaration) or model (third-party certified)Public
Conformity certificationBatch (self-declaration) or model (third-party certified)Authority only
Chemical propertiesSubstances of concern; concentration of SoC; relevant instructions for the safe useBatchPublic
Location of the SoC; information relevant for disassembly, reuse, recycling and management at end of lifeBatchLegitimate interest
RecyclabilityRecyclability scoreModelPublic
Conformity certificationModelAuthority only
Recycled contentRecycled content (%)ModelPublic
Type of wasteBatchPublic
Weight (excluding trims)BatchLegitimate interest / authority only
Amount of recycled materialModelLegitimate interest / authority only
Conformity certificationBatchAuthority only
Other EU law (organic content, ecolabel)Organic content (%) (voluntary); EU Ecolabel (voluntary)ModelPublic
Amount of organic material (voluntary)ModelLegitimate interest / authority only
Conformity certification (voluntary)BatchAuthority only
Product footprintProduct carbon/environmental footprint, class of performance; weightModelPublic
Product carbon/environmental footprint, absolute value; carbon footprint calculation parametersModelLegitimate interest / authority only
Conformity declarationModelAuthority only
Manuals and instructionsCare instructions; repair instructions (voluntary); contact of repair services offered by brand (voluntary); warranty durationModelPublic

Beyond the fields marked voluntary in Table 13, other voluntary entries would be allowed only if they do not duplicate or overlap regulated fields, and they would stay unrelated to sustainability unless an indicator is defined in the preparatory study and taken into the delegated act; the study's examples are logistical codes, payment terms and technical specifications, and access to such entries would be restricted to parties with a legitimate interest (section 7).

Identification and producer data (Tables 5 and 6). The study proposes a serialised GTIN for the item-level product ID, a GTIN plus lot number for the batch ID and a GTIN-13 for the model ID, or equivalents, each "compliant with prEN18219". That draft is now EN 18219:2026 "Digital product passport – Unique identifiers", one of six DPP standards whose references were published by Implementing Decision (EU) 2026/1736 (see our DPP standards guide). Classification would combine an ESPR product category, the PEFCR product category and the HS or TARIC code. Producer data covers the manufacturer, the importer (only where the manufacturer is not established in the EU) and the operator responsible under Article 4 of Regulation (EU) 2019/1020 or similar rules, mirroring Annex III, points (g) to (k); the facility identifier refers to the place where the product was manufactured.

Product information and compliance documentation (Tables 7 and 8). Fibre composition follows the Textile Labelling Regulation. The robustness score, recyclability score and recycled content are among the potential information requirements of the ESPR preparatory study for textiles, of which the DPP study forms part; their methods are left "to be proposed" in the delegated act. The substances-of-concern fields copy the five elements of ESPR Article 7(5); the study notes that concentration data is generally not reported today and location data is not reported. Table 8 adds the evidence: a conformity certification (third-party verification) or conformity declaration (self-declaration) for each claim and, in the self-declaration scenario only, test results, weights and amounts in kilograms and footprint values. For environmental performance data, the study sets out two scenarios: a third-party verified claim, where the passport shows only the certification, or a self-declaration with calculation parameters and technical documentation that let market surveillance authorities recalculate the result (section 7.4).

3. Model, batch or item: ESPR leaves the choice open, the study proposes batch identifiers

Recital 33, ESPR

"The term ‘model’ usually refers to a version of a product of which all units share the same technical characteristics relevant for the ecodesign requirements and the same model identifier, the term ‘batch’ usually refers to a subset of a specific model composed of all products produced in a specific manufacturing plant at a specific moment in time and the term ‘item’ usually refers to a single unit of a model."

In law the level is open: the delegated act decides it and defines the levels (Article 9(2)(d)), and recital 33 asks the impact assessments to weigh the costs and benefits of each level. The study further specifies the descriptions for apparel. A model shares "the same technical characteristics, pattern and construction, not necessarily requiring colour and size distinctions"; a batch is all products of a model made in one plant at one time "under the same conditions, using the same materials and processes"; an item is a single unit.

Its central proposal is "to require batch identifiers as the minimum requirement", each passport being filled with batch or model data depending on the field (section 9.1). Item-level identifiers would stay voluntary and are "currently under analysis"; an item-level passport could inherit batch or model data, with item-specific data added later. The study's reasons:

Field groupProposed levelThe study's reasoning (section 9.1)
Classification, fibre composition, components, robustness score, recyclability score, EU Ecolabel, care, repair and warranty informationModelConstant within a model or fixed by design; the recyclability score depends solely on composition, and the EU Ecolabel is awarded per model.
Operators and manufacturing facilityBatchThe facility can differ within a model, and only the exact facility allows footprint parameters to be validated; one model may be placed on the market by several importers.
Mechanical testsBatch under self-declaration; model if third-party certifiedTests run per batch in practice; requiring third-party certification would substantially increase costs, so a model level is considered for certified results.
Chemical propertiesBatch as the minimumDyes can change the chemistry even within a batch, so "all chemicals associated with all possible colours within that batch" should be included, "reflecting a worst-case scenario".
Recycled and organic contentShares at model level; verification at batch levelShares follow from the model specification; verification follows current third-party certification practice.
Environmental and carbon footprintModel, as a baselineBatch differences exist but are hard to capture; operators could use default values, averages or worst-case scenarios to fill data gaps.

For online sales, ESPR requires the delegated act to set "the manner in which the digital product passport is to be made accessible to customers before they are bound by a contract for sale, hire or hire purchase, including in the event of distance selling" (Article 9(2)(e)). Once a delegated act requires a passport, ESPR itself obliges the economic operator placing the product on the market to give dealers and online marketplace providers a digital copy of the data carrier or unique product identifier, as relevant, so that they can make it accessible to potential customers who cannot physically access the product, and to provide that copy or a webpage link free of charge, promptly and at the latest within five working days of a request (Article 10(3)); see our online-selling guide. Because a marketplace cannot guarantee which batch a customer receives, the study suggests allowing model-level data or a representative batch passport at the offer stage, with the full data once a physical product is assigned to the order.

4. Who would see what: the study's three access levels

ESPR does not define access levels. It leaves the delegated act to specify "the actors that are to have access to data in the digital product passport and to what data they are to have access" (Article 9(2)(f)), guarantees free of charge and easy access based on those rights (Article 11(b)), restricts update rights accordingly (Article 11(f)), and names the protection of confidential business information among the grounds for exempting substances-of-concern information elements (Article 7(6)(b)). The legal side is set out in our access-rights guide.

The study distinguishes three categories (section 9.2): information "available to any user without authentication"; information for notified bodies, market surveillance authorities, customs and the Commission, "including compliance documentation, test results and other information required for regulatory purposes"; and information for persons with a legitimate interest, such as recycling operators. It cites confidential business information as a reason to restrict some fields: suppliers treat technical data on fibre properties and chemical usage as confidential, and footprint calculation parameters may reveal production details (section 9.2.1). Table 14 nevertheless keeps fibre composition and the substances of concern and their concentration public, and restricts the calculation parameters. Public product information at the point of sale should in its view be at model level, except for substances of concern. Field by field (see the table in section 2), most fields would be public; the location of substances of concern and end-of-life information would be for persons with a legitimate interest; conformity documents and operator contact for authorities only; and the weight excluding trims, the amounts of recycled and organic material, absolute footprint values and calculation parameters for persons with a legitimate interest or authorities. The product weight used for the footprint would be public.

Three points need care. First, the study is not consistent on chemical data: Table 14 lists the concentration of substances of concern as public, while the conclusions name "detailed chemical concentration ranges or verification documentation" as sensitive data to be restricted (section 10). Second, the category description puts test results under authorities, while Table 14 lists the three test fields as public. Third, Table 14 puts operator contact under authorities only, but ESPR already requires manufacturers and importers to indicate their name, registered trade name or trade mark, postal address and electronic contact "on the public part of the digital product passport, where applicable" (Articles 27(6)(a) and 29(3)(a)); the study does not discuss this provision. The delegated act will decide which data falls into which category; Table 14 binds no one.

5. Custodians, updates, retention and language: the study's governance ideas against the law

Section 9.3 of the study deals with who keeps passport data correct over time, and its conclusions (section 10) add a point on language. Some statements restate ESPR, some are proposals, and two go beyond the Regulation: the ten-year retention period the study attributes to ESPR (section 9.3.2), and the statement that the passport must be available in all official EU languages, which it makes without citing a provision (section 10).

TopicFixed in ESPR todayProposed or stated by the JRC study (not law)
ResponsibilityManufacturers placing products on the market, and importers before placing them, must ensure a passport is available, including a back-up copy (Articles 27(1)(c) and 29(2)(c)).An importer of a non-EU manufacturer's product would create the passport entry and "function as a custodian of data that it did not generate itself", verifying it first; liability would be shared with the manufacturer (section 9.3.2).
Modified productsA new passport for a product that already has one must be linked to the original (Article 11(d)). Whoever manufactures a product, or has it designed or manufactured, and markets it under their name or trademark is the manufacturer (Article 2(42)); an importer or distributor that places a product on the market under its own name or trademark, or modifies it in a way that affects compliance, is considered a manufacturer (Article 34).Where a downstream operator prints or embroiders a garment and places it on the market under its own name or trademark, upstream data would be inherited where still valid and modified parameters (e.g. newly added substances of concern) newly declared; delegated acts and technical standards would need to set the rules for linking upstream and downstream passports (section 9.3.1).
StorageBy the operator responsible for creating the passport or by DPP service providers (Article 11(c)); the registry stores at least the unique identifiers (Article 13(1)).Only identifiers and a limited set of reference data in the EU registry, the content in decentralised systems (section 9.3.3).
RetentionSet by the delegated act; it "shall correspond to at least the expected lifetime of a specific product" (Article 9(2)(i))."The ESPR requires that the DPP remains available for at least ten years after the product has been placed on the market, unless the delegated act specifies otherwise." (section 9.3.2). Not in ESPR; see below.
Language"in a language which can be easily understood by customers, as determined by the Member State on whose market the product is to be made available" or put into service (Article 7(8))."The DPP must be available in all official EU languages." (section 10).
Integrity"data authentication, reliability and integrity shall be ensured" (Article 11(g)).Verification by tests on the product, by chain-of-custody evidence for recycled or organic content and footprints, and by correct identifiers (section 9.3.4).

On retention, the ten-year sentence does not match the Regulation, and the study's own section 2.1.3 states the correct rule (at least the expected lifetime, period set in the delegated act). The wording "10 years after a product covered by a delegated act adopted pursuant to Article 4 has been placed on the market or put into service, unless a different period has been specified in that delegated act" is in Article 27(3) and concerns the technical documentation and the EU declaration of conformity. A separate floor applies to digital instructions, which the manufacturer includes in the passport: accessible online "during the expected lifetime of the product, but in any event for at least 10 years" (Article 27(7)).

On language, "all official EU languages" is the study's reading; ESPR leaves the language to each Member State where the product is made available. On custodianship, the study writes about importers, but the point is wider. A "manufacturer" under ESPR includes a person that "has a product designed or manufactured, and markets that product under their name or trademark" (Article 2(42)). An EU brand that has its garments made by third-party factories and sells them under its own name is the manufacturer, and most of its passport data will come from suppliers. Our manufacturers and private-label guide explains this role.

6. Environmental footprint fields: what the study proposes, and what the PEF method is

ESPR makes no footprint mandatory for apparel. A delegated act may require information on the product's performance, "including a repairability score, a durability score, a carbon footprint or an environmental footprint" (Article 7(2)(b)(i)), and the Commission "may base" classes of performance on single parameters or on aggregated scores (Article 7(4)). ESPR defines the environmental footprint by reference to "the Product Environmental Footprint method established by Recommendation (EU) 2021/2279 or other scientific methods developed by international organisations, widely tested in collaboration with different industry sectors and adopted or implemented by the Commission in other Union law" (Article 2(24)).

QuestionFixed in ESPR todayProposed by the JRC study (not law)
Is a footprint required?Only if the delegated act sets an information requirement (Article 7(2)(b)(i); Annex I, points (m) and (n)).Class of performance, absolute value, comparison with the PEFCR benchmark (Table 8 only), calculation parameters, weight, and a conformity certification or declaration (Tables 7, 8 and 13; Tables 13 and 14 list only the declaration).
MethodPEF method of Recommendation (EU) 2021/2279 or other scientific methods developed by international organisations, widely tested with industry and adopted or implemented by the Commission in other Union law (Article 2(24)); carbon footprint based on life cycle assessment using the single impact category of climate change (Article 2(25)).A method to be proposed in the delegated act, based on the PEFCR (climate change for the carbon footprint, a single score for the environmental footprint), with partial consideration of life-cycle stages as described in the ESPR preparatory study (Table 7).
LevelDecided by the delegated act (Article 9(2)(d)).Model level as a baseline; default values, averages or worst-case scenarios for data gaps; calculation rules to be defined in the delegated act (section 9.1).
Who sees itDecided by the delegated act (Article 9(2)(f)).Class of performance public; absolute value and calculation parameters for persons with a legitimate interest or authorities (Table 14).

Recommendation (EU) 2021/2279 defines the PEF method as a "general method to measure and communicate the potential life cycle environmental impact of a product as laid down in Annex I" and adds: "If a PEFCR exists, this should be used for calculating the environmental footprint of a product belonging to that product category." (point 2(a) and (e)). It "does not apply to the implementation of EU mandatory legislation that foresees a specific methodology" (point 1.3), which is what the study expects the delegated act to lay down. The Commission's PEF method page (updated 9 October 2026) lists Apparel and Footwear among the existing PEFCRs.

The study does not propose a full life-cycle PEF score per garment. Its method entries refer to partial consideration of life-cycle stages without listing them in the DPP study itself, it rates readiness for the footprint values as very low, and it says the classes of performance "should be developed considering the efforts, costs and administrative burdens related to the data collection and calculation of footprint indicators" (Table 7). Its industry review found footprint data typically calculated at model level, with batch-level footprints considered impracticable by stakeholders (section 5.2.1).

7. What brands can prepare now: practical suggestions, not legal duties

Nothing below is required by law today. The suggestions follow the study, the most detailed public indication we have found, and may change when the delegated act is drafted. Where a point rests on ESPR itself, the table says so.

AreaWhat to prepare (suggestion)Basis
IdentifiersModel identifiers (GTIN or equivalent) and batch or lot identifiers in PLM or ERP, linked to production orders; keep the option to serialise items later.Study, sections 7.1 and 9.1 (proposal); ESPR Article 9(2)(d) and Annex III, points (b) and (c) (open); EN 18219:2026 (harmonised standard; a passport that conforms is presumed to meet ESPR Articles 10 and 11 to the extent the standard covers them, Article 41(2)).
Factory per batchA record of which facility produced which batch, with a facility identifier, and of the importer per batch where you import.Study, Table 6 and section 9.1 (proposal); ESPR Annex III, points (g) to (k) (menu).
ChemicalsSupplier declarations per batch covering every colourway: substances of concern, location in the garment and concentration (or maximum concentration or concentration range).ESPR Article 7(5) (minimum content once a delegated act applies); study, section 9.1 (worst case across colours).
Recycled and organic contentShares per model; certificates, weights and the type of waste per batch.Study, Tables 8 and 13 (proposal).
Quality testsVisual inspection, spirality and dimensional-change results per batch, with the test method used.Study, Table 8 and section 9.1 (proposal).
Footprint inputsModel-level data and average product weight including trims, noting where default values would be used.Study, Table 8 and section 9.1 (proposal); Recommendation (EU) 2021/2279 (not legally binding).
Supplier contractsDuties to supply, update and correct data, to mark confidential data, and to allow its disclosure to authorities.Study, sections 9.2.1, 9.3.2 and 9.3.4 (proposal); ESPR Articles 9(1) and 11(g).
Contact data and languageTreat manufacturer and importer contact details as public; plan translation for the markets you sell in.ESPR Articles 27(6), 29(3) and 7(8) (law).

Our DPP readiness checklist lists what to have ready before the textile delegated act, our readiness-audit guide shows how to measure where your product data stands today, our provider guide covers the back-up copy and contract points for whoever hosts the passport, and our substances-of-concern guide explains the chemical rules.

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Frequently asked questions

Does the JRC study decide what goes into the apparel DPP? +
No. It is an external study prepared for the Joint Research Centre, listed by the JRC with the date 13 May 2026 and watermarked as a draft, and its disclaimer says its contents do not necessarily reflect the position or opinion of the European Commission. It says its findings require validation through stakeholder consultation and refinement during the impact assessment. The content of the apparel passport will be fixed only by the ESPR delegated act for textiles, which selects the data from Annex III and sets the level and access rights under Article 9(2). That act had not been adopted by 19 October 2026.
Will the apparel DPP have to be at item level? +
ESPR leaves this open: the delegated act decides whether the passport is established at model, batch or item level and defines those levels (Article 9(2)(d)). The study proposes batch identifiers as the minimum, with each field filled at model or batch level, and item-level identifiers on a voluntary basis, which it says are still under analysis. That is a proposal, not law.
Will chemical data in the passport be public? +
Once a delegated act sets information requirements, ESPR requires the information on substances of concern to include at least their name (or numerical code), location, concentration (or maximum concentration or concentration range), instructions for safe use and end-of-life information, subject to exemptions and thresholds the Commission may set (Article 7(5) and (6)), and leaves access rights to the delegated act. In the study's Table 14 the substances, their concentration and the safe-use instructions are public, their location and the end-of-life information for persons with a legitimate interest. Its conclusions, however, name detailed chemical concentration ranges as sensitive data to be restricted, so the study is not consistent on this point. The delegated act will decide.
How long must the apparel DPP stay available? Is it ten years? +
Under ESPR the delegated act sets the period, which shall correspond to at least the expected lifetime of a specific product (Article 9(2)(i)), and the passport must remain available even after the insolvency, liquidation or cessation of activity in the Union of the operator that created it (Article 11(e)). ESPR has no general ten-year rule for the passport. The ten-year period in Article 27(3) applies to the technical documentation and the EU declaration of conformity, unless the delegated act sets another period, and digital instructions must stay accessible online for at least 10 years (Article 27(7)). The study's statement of a ten-year passport minimum is not supported by the text.
Will the DPP have to be available in all EU languages? +
That is the study's reading, not a rule in ESPR. Article 7(8) requires information to be provided in a language which can be easily understood by customers, as determined by the Member State on whose market the product is made available or put into service. What the apparel delegated act will say is open.
When will the apparel DPP become mandatory? +
No date has been set. On 19 October 2026 no textile delegated act had been adopted. The Commission's DPP page lists adoption of the delegated acts for textiles, aluminium and tyres for Q3 to Q4 2027 and its textile-apparel page for Q4 2027, both as indicative timelines; the Have your say record, last modified in December 2025, still shows the first quarter of 2027. Under Article 4(4) of ESPR, the date of application shall not be earlier than 18 months from the act's entry into force, except in duly justified cases.

Sources

ESPR, Implementing Decision (EU) 2026/1736 and Recommendation (EU) 2021/2279 were read in their Official Journal versions published by the EU Publications Office (EUR-Lex), with corrigenda checked; the Publications Office records were last searched on 20.10.2026 and showed no ESPR delegated act for textiles; the JRC study, the JRC project plan and documents page, the Commission's DPP, textile-apparel and PEF pages and the Have your say record were accessed on 19.10.2026. The JRC study is a non-binding external study: everything this guide attributes to it is a proposal. Re-check this guide when Have your say initiative 16116 opens a consultation or publishes a draft, or when the JRC schedules its 4th milestone. This is general information, not legal, financial or investment advice.