PRODUCT SCOPE GUIDE

Which Fashion Products Need an EU Digital Product Passport?

Published 24.09.2026 · Reading time ~4 min · by Lior Gabriel Graetz · LG Fashion Labs

1. The scope test: 80% textile fibres, finished products only

Two conditions define scope, both from the JRC's preparatory study, which explicitly aligns its threshold with the existing EU Textile Labelling Regulation (EU) No 1007/2011:

• 80% textile fibres by weight. A leather jacket with only 30% textile content falls outside this delegated act's scope entirely — not into some other DPP requirement instead. Leather goods aren't currently a named category anywhere in the EU's ESPR Working Plan.
• Finished apparel only. Fabric rolls, yarn and raw fibre are explicitly excluded from the DPP obligation itself, even though their sourcing data — fibre composition, recycled content — still needs to flow into the finished garment's DPP. A denim mill selling fabric to a jeans brand has no direct DPP obligation; the jeans brand placing the finished jeans on the market does.

Everything below assumes both conditions are already met.

2. The 10 in-scope categories

The JRC study defines ten textile apparel categories as in scope for the first delegated act:

1. 01T-shirts — singlets, vests, polo shirts
2. 02Shirts and blouses — long-sleeved shirts, base layers
3. 03Sweaters and mid-layers — pullovers, cardigans, hoodies
4. 04Jackets and coats — blazers, parkas, rain jackets
5. 05Pants and shorts — jeans, sports pants, capri pants
6. 06Dresses, skirts and jumpsuits — wrap dresses, one-piece suits
7. 07Leggings, stockings, tights and socks — pantyhose, knee socks
8. 08Underwear — boxers, briefs, bras, shapewear
9. 09Swimwear — bikinis, board shorts
10. 10Textile apparel accessories — hats, scarves, belts, gloves

Technical apparel counts too: workwear and sportswear are in scope as long as they're genuinely textile apparel and don't land on the exclusion list below.

3. What's excluded — and why

Five categories are explicitly excluded, because each is regulated elsewhere or differs too much in function from ordinary apparel:

• Smart textiles — garments that sense and react to conditions via embedded sensors (e.g. a jacket that adjusts insulation to temperature)
• E-textiles — textile-based systems with an intended electronic response to a signal (e.g. a shirt with integrated LED lighting)
• Personal protective equipment (PPE) — regulated instead under Regulation (EU) 2016/425 (e.g. a high-visibility safety vest)
• Medical devices or accessories — regulated instead under the Medical Devices Regulation (EU) 2017/745 (e.g. a compression garment classified as a medical device)
• Toys — regulated instead under the Toy Safety Directive 2009/48/EC (e.g. a costume classified as a toy)

One clarification worth knowing, stated explicitly in the JRC study: attaching an RFID, NFC or UHF chip to carry the DPP itself does not make a garment an "e-textile." The exclusion is about the garment's own function, not the technology used to carry its passport.

4. Still undecided: the grey zone

This isn't pure silence, though: a separate, broader JRC "Preparatory study on textile products" (product group 467) already covers the wider textile universe that apparel was carved out from as the priority subgroup. That study is at its third milestone (December 2025); a fourth milestone explicitly covering "elements to be included in the Digital Product Passport" is scheduled, though not yet dated.

5. What this means for your brand

If your range matches the ten categories above, plan as if DPP obligations will apply once the textile delegated act lands. If your range is mostly footwear, home textiles, or genuinely smart or technical garments on the exclusion list, don't assume you're covered by this specific study — but don't assume you're exempt long-term either, since Working Plan scope tends to expand over successive updates rather than shrink.