PRODUCT SCOPE GUIDE
Which Fashion Products Need an EU Digital Product Passport?
A textile product needs an EU Digital Product Passport if it is a finished garment made of at least 80% textile fibres by weight, falls into one of ten apparel categories the European Commission's own preparatory research has mapped out, and isn't on a short list of explicit exclusions. That's the working scope behind the first textile delegated act, drawn directly from a Joint Research Centre (JRC) study published 13 May 2026 — not yet law, but the most concrete signal available today.
This guide walks through exactly what's in, what's out, and what's still undecided, with real examples for each.
80% fibre
The textile-fibre-by-weight threshold a finished garment must meet to be in scope.
10 categories
The apparel categories the Commission's own preparatory research has mapped as in-scope.
13 May 2026
Publication date of the JRC study this working scope is drawn from — not yet law.
Not textile-covered — outside the proposed scope of the first textile delegated act
Different product group — its own scope test
PPE, medical device, toy, smart or e-textile — excluded from this scope
First textile delegated act
Not covered by this test — a separate, undecided category:
GREY ZONEFootwear (study only), home textiles (not named in the Working Plan), and customised or upcycled apparel — all still undecided.
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:
- 01T-shirts — singlets, vests, polo shirts
- 02Shirts and blouses — long-sleeved shirts, base layers
- 03Sweaters and mid-layers — pullovers, cardigans, hoodies
- 04Jackets and coats — blazers, parkas, rain jackets
- 05Pants and shorts — jeans, sports pants, capri pants
- 06Dresses, skirts and jumpsuits — wrap dresses, one-piece suits
- 07Leggings, stockings, tights and socks — pantyhose, knee socks
- 08Underwear — boxers, briefs, bras, shapewear
- 09Swimwear — bikinis, board shorts
- 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 and exploitable response as a reaction either to changes in their surroundings/environment or to an external signal/input (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
Not yet scoped by this study
Footwear, home textiles, customised and upcycled apparel
- Footwear: named alongside textiles in Article 18(5)(c) of the ESPR itself, which prioritises "textiles, in particular garments and footwear" for the first working plan — but the Commission's ESPR Working Plan document explicitly treats footwear as "a separate product category from textiles" and it is not covered by this preparatory study — only a study on footwear is planned, due by the end of 2027, so its own scope and timeline have not been fixed by a delegated act.
- Home textiles: not named anywhere in the Commission's ESPR Working Plan document, and not covered by this study or by any published preparatory study of their own.
- Customised and upcycled apparel: the JRC study explicitly defers both to the impact assessment phase that follows — how a made-to-order piece or an upcycled garment gets treated is not yet decided.
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 the Working Plan is regularly updated (Article 18(3) ESPR) and the Commission proposes to start work on some of the Article 18 products left out of the first plan through studies and then to use its mid-term review after three years to reassess the situation (Working Plan, Section 2.2.3).
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Start Your DPP AuditFrequently asked questions
What's the exact threshold for a "textile product" under this scope?
Does the EU Digital Product Passport apply to footwear?
Does a fabric or yarn supplier need to create a Digital Product Passport?
Does adding an RFID or NFC chip make a garment an excluded "e-textile"?
Sources
- JRC preparatory study — textile apparel scope & data contentJoint Research Centre, Product Bureau, "Study on DPP content for textile apparel products under ESPR" (product group 467, "Textile products"): proposed textile-apparel DPP scope and data content published 13 May 2026, including the finished-product/80%-fibre threshold, the ten in-scope apparel categories, the five explicit exclusions (smart textiles, e-textiles, PPE, medical devices/accessories, toys), and the RFID/NFC/UHF data-carrier clarification. susproc.jrc.ec.europa.eu/467 ↗
- JRC 1st Milestone report — e-textiles definitionJoint Research Centre, "Preparatory study on textiles for product policy instruments", 1st milestone working document (23 February 2024), Section 3.2.2: defines e-textiles as "textile-based systems that exhibit an intended and exploitable response as a reaction either to changes in their surroundings/environment or to an external signal/input".
- ESPR — first working plan priority listRegulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024, Article 18(5)(c): the first ESPR working plan must prioritise "textiles, in particular garments and footwear". CELEX 32024R1781 ↗
- Commission ESPR Working Plan — footwear treated as separate categoryEuropean Commission, Communication "Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030", COM(2025) 187 final (16 April 2025), Section 2.2.3: footwear is described as "a separate product category from textiles due to the distinct use of materials, product functionality and supply chains", with a study to be commissioned and completed by the end of 2027. Home textiles are not named anywhere in this document.
- Textile fibre labelling — 80% thresholdRegulation (EU) No 1007/2011 of the European Parliament and of the Council of 27 September 2011 on textile fibre names and related labelling and marking of the fibre composition of textile products; Article 2(2)(a) treats products containing at least 80% by weight of textile fibres in the same way as textile products. CELEX 32011R1007 ↗
- Exclusion categories — sector-specific regulationRegulation (EU) 2016/425 on personal protective equipment; Regulation (EU) 2017/745 on medical devices; Directive 2009/48/EC on the safety of toys — each cited by the JRC study as the reason its product category sits outside textile-apparel DPP scope.
- JRC "Preparatory study on textile products" — broader product group 467Joint Research Centre Product Bureau project plan for product group 467, covering the wider textile universe apparel was carved out from; third milestone published December 2025, with a fourth milestone on Digital Product Passport data elements scheduled but not yet dated. susproc.jrc.ec.europa.eu/467/project-plan ↗
All sources were accessed and verified directly on EUR-Lex, the European Commission's ESPR Working Plan and the JRC's Product Bureau site on 29.09.2026. This scope test is drawn from a non-binding JRC preparatory study, not a delegated act — the eventual legal scope may differ. This is general information, not legal, financial or investment advice.