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PRODUCT SCOPE GUIDE

Which Fashion Products Need an EU Digital Product Passport?

by Lior Gabriel Graetz LG Fashion LabsPublished 24.09.2026Updated 20.10.2026Short version ~2 minFull guide ~4 min

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Under the proposed working scope, a product needs a Digital Product Passport if it is a finished garment of at least 80% textile fibres by weight, falls into one of ten apparel categories and is not on a short exclusion list. The scope comes from a draft, non-binding study prepared for the JRC: not yet law.

The proposed scope test

  1. Finished garmentNot fabric or yarn
  2. 80% textile fibresBy weight
  3. 10 categoriesApparel list
  4. Not excluded5 exclusions
  5. In scopeProposedFirst textile act

Grey zone: footwear, home textiles, custom and upcycled

Source: external study prepared for the JRC (watermarked draft, listed 13 May 2026), non-binding. Simplified; the full guide below is authoritative.

What you need to know

  1. 1

    Two conditions come first.

    At least 80% textile fibres by weight, and finished apparel only. A leather jacket with 30% textile content falls outside the proposed scope of the first textile delegated act. §1

  2. 2

    Fabric and yarn suppliers are not directly covered.

    Fabric rolls, yarn and raw fibre are excluded from the obligation itself, but their data, such as fibre composition and recycled content, still has to flow into the finished garment’s passport. §1

  3. 3

    Ten apparel categories.

    T-shirts, shirts, sweaters, jackets, pants, dresses and skirts, leggings and socks, underwear, swimwear, and textile accessories such as hats, scarves, belts and gloves. Workwear and sportswear count if they are textile apparel and not excluded. §2

  4. 4

    Five exclusions.

    Smart textiles, e-textiles, “personal protective equipment”, medical devices and toys. An RFID, NFC or UHF chip that carries the passport does not make a garment an “e-textile”. §3

  5. 5

    Still undecided.

    Footwear is a separate category in the Commission’s Working Plan, with only a study planned, due by the end of 2027. Home textiles are not named there. Customised and upcycled apparel are deferred to the impact assessment. §4

  6. 6

    Don’t assume you’re exempt long-term.

    If your range matches the ten categories, plan as if DPP obligations will apply once the textile delegated act applies. If not, note that the Working Plan is regularly updated (Article 18(3) ESPR). §5

What to do now

Status of the guide: 20 October 2026. Based on an external study prepared for the JRC (watermarked draft, listed 13 May 2026), ESPR (Regulation (EU) 2024/1781) Article 18, the Commission’s ESPR Working Plan (COM(2025) 187) and Regulation (EU) No 1007/2011. A simplified summary: the full guide below and the EU texts are authoritative. General information only, not legal advice. Read the full notice.

Full guide · in full detail · ~4 min

Everything below is the complete, sourced guide. ↑ Back to the short version

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, and isn't on a short list of explicit exclusions. That's the proposed working scope for the first textile delegated act, drawn directly from an external study prepared for the Joint Research Centre (JRC), listed by the JRC with the date 13 May 2026 and watermarked as a draft — non-binding and 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 listed as in scope in the external study prepared for the JRC.

13 May 2026

Date the JRC lists for the external draft study this working scope is drawn from — not yet law.

Finished garment
At least 80% textile fibres by weight?yes ↓
IF NO

Not textile-covered — outside the proposed scope of the first textile delegated act

One of the 10 apparel categories in the study?yes ↓
IF NO

Different product group — its own scope test

Not on the 5-item exclusion list?yes ↓
IF NO

PPE, medical device, toy, smart or e-textile — excluded from this scope

IN SCOPE

First textile delegated act

Not covered by this test — a separate, undecided category:

GREY ZONE

Footwear (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 the proposed scope, both taken from the study, which notes that its 80% threshold is also in line with the existing EU Textile Labelling Regulation (EU) No 1007/2011:

Everything below assumes both conditions are already met.

2. The 10 in-scope categories

The study proposes 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:

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

This isn't pure silence, though: a 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); the JRC project plan lists a fourth milestone explicitly covering "elements to be included in the Digital Product Passport", with the date "To be communicated".

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).

DPP AUDIT

How ready is your collection for the DPP?

Benchmark one complete collection against the LGFL DPP Data Framework. 10 domains, four ESPR categories. Under NDA.

Start Your DPP Audit

Frequently asked questions

What's the exact threshold for a "textile product" under this scope? +
At least 80% textile fibres by weight — the threshold proposed in the external study prepared for the JRC, which describes it as also in line with the existing EU Textile Labelling Regulation (EU) No 1007/2011.
Does the EU Digital Product Passport apply to footwear? +
Not yet, and not by this specific study. The Commission's ESPR Working Plan explicitly places footwear in a separate product category from textiles — not under the "Textiles/Apparel" entry of its priority list — and it isn't covered by the external study on textile apparel prepared for the JRC (listed by the JRC with the date 13 May 2026 and watermarked as a draft) either; only a study on footwear, due by the end of 2027, is planned.
Does a fabric or yarn supplier need to create a Digital Product Passport? +
No. The external study prepared for the JRC explicitly limits the proposed DPP obligation to finished textile apparel products. Intermediate products like fabrics, yarns and fibres are excluded, even though their data still needs to feed into the finished garment's DPP.
Does adding an RFID or NFC chip make a garment an excluded "e-textile"? +
No. The external study prepared for the JRC explicitly states that using UHF, RFID or NFC as the product's own DPP data carrier does not count as making it an e-textile. The exclusion is about the garment's function, not its data carrier.

Sources

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 external study prepared for the JRC and watermarked as a draft, not a delegated act — the eventual legal scope may differ. This is general information, not legal, financial or investment advice.

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