COMPLIANCE DEEP DIVE

DPP for Footwear Brands: What's the Same, What's Different

Published 28.09.2026 · Reading time ~13 min · by Lior Gabriel Graetz · LG Fashion Labs

Every apparel-focused DPP guide on this site is useful background for footwear too — ESPR's own priority list names footwear right alongside textiles, and it will very likely carry the same kind of passport eventually. But footwear does not ride the same delegated-act timeline as apparel: the Commission's own ESPR Working Plan pulls it back out as "a separate product category from textiles," with only a feasibility study commissioned so far. And a footwear brand's actual compliance map has real, footwear-specific terrain that no apparel guide covers: a decades-old EU labelling directive that applies to shoes and nothing else, a REACH restriction that targets leather footwear specifically, a customs chapter that has never had anything to do with clothing, and — in France — a producer-responsibility scheme that has treated footwear as its own category since 2009, sixteen years before the rest of the EU caught up.

This guide works through exactly what's shared with apparel and exactly what isn't, sourced directly from EU and French primary law — EUR-Lex, the Joint Research Centre's own project pages, and the French government's own environmental-agency and Official Bulletin publications. Nothing here is estimated or inferred from apparel rules by analogy.

1. Does the Digital Product Passport even apply to footwear yet?

Start with what's genuinely still open, because it's easy to get wrong in both directions. ESPR's own Article 4(5)(c) names footwear alongside textiles in the legal priority list for the first working plan — "textiles, in particular garments and footwear." But the Commission's detailed ESPR Working Plan document pulls footwear back out: it states footwear "is in a separate product category from textiles due to the distinct use of materials, product functionality and supply chains," and rather than giving it a delegated-act timeline, only commissions a feasibility study on footwear, due by the end of 2027. Textiles/apparel, by contrast, already has its own indicative 2027 adoption timeline in that same Working Plan. On this level, footwear and apparel are not treated as one bucket.

But look at the actual technical groundwork feeding that eventual delegated act, and footwear's position gets noticeably less certain than apparel's. The JRC's preparatory study — the one that will set the candidate data requirements the Commission actually works from — is formally titled the "Preparatory Study on Textile Products," and its own May 2026 output document mentions footwear exactly once: as a citation of the "Product Environmental Footprint Category Rules (PEFCR): apparel and footwear," a shared methodology used for footprint calculations, not as a product footwear brands should expect their own data fields to come from. Footwear is not itself in that study's scope.

What this means, concretely

No ESPR delegated act exists for footwear, or for textiles, yet — nothing is mandatory today
Footwear has no delegated-act timeline of its own — only a feasibility study on footwear, due by the end of 2027; apparel's own indicative adoption timeline is 2027, feeding a 2029-at-the-earliest application date under ESPR's 18-month rule
Footwear's own product-specific data content has not been separately determined by any JRC study
There is no dedicated ESPR/JRC preparatory-study product group for footwear at all, as of publication

A genuine research trap to avoid

The JRC's Product Bureau does list a project called "Footwear" — but it's a revision of the EU Ecolabel criteria for "Footwear and leather products," carried out 2013–2015
That project runs under EU Ecolabel Regulation (EC) No 66/2010 — a voluntary certification scheme, entirely unrelated to ESPR or the DPP
Searching "JRC footwear study" can easily surface this unrelated, decade-old Ecolabel page instead of the actual textile-apparel preparatory study
The two must not be confused when researching footwear's DPP timeline

See our scope guide for the general test, and our DPP Master Timeline for how this fits the wider Commission schedule.

2. The footwear-specific EU law apparel brands never had to think about

While the DPP's footwear-specific content is still undetermined, one EU law has already required footwear-specific labelling for thirty years, completely independently of ESPR: Directive 94/11/EC. It has no equivalent in apparel — clothing's own fibre-composition labelling runs under a different regulation entirely (Regulation (EU) No 1007/2011).

Directive 94/11/EC, Article 1(1)

"This Directive shall apply to the labelling of the materials used in the main components of footwear for sale to the consumer. For the purposes of this Directive, 'footwear' shall mean all articles with applied soles designed to protect or cover the foot... The following shall be excluded from the Directive: — second-hand, worn footwear, — protective footwear covered by Directive 89/686/EEC, — footwear covered by Directive 76/769/EEC, — toy footwear."

That second exclusion is worth pausing on: Directive 89/686/EEC was the EU's old personal protective equipment (PPE) law. It was repealed and replaced by Regulation (EU) 2016/425 on 21 April 2018, so the exclusion is now properly read as covering protective and safety footwear regulated under that PPE Regulation instead — steel-toe boots and other certified safety footwear sit outside this labelling directive's scope, and outside the general fashion-DPP conversation, because they're regulated as protective equipment, not as consumer footwear.

For everything else, the Directive requires information on three separate parts of every shoe, and sets a hard numerical threshold for when a material has to be named at all:

Directive 94/11/EC, Article 4(1)

"The labelling shall provide information on the material, determined in accordance with Annex I, which constitutes at least 80% of the surface area of the upper, and the lining and sock, of the footwear, and at least 80% of the volume of the outersole. If no one material accounts for at least 80%, information should be given on the two main materials used in the composition of the footwear."

The three parts — upper, lining and sock, and outersole — are each labelled separately, using either pictograms or written indications, drawn from four material categories set out in Annex I: Leather, Coated Leather (a surface coating over 0.15mm but no more than one-third of total thickness — beyond that ratio it's no longer "Leather" at all), Textile, and All other materials. Labelling only has to be affixed to one shoe of each pair, and can be printed, stuck, embossed, or an attached tag — but it must be visible, securely attached, and not misleading.

Who is on the hook for getting it right runs on a familiar logic, if you've read our retailers and wholesalers guide:

Directive 94/11/EC, Article 4(5)

"The manufacturer or his authorized agent established in the Community shall be responsible for supplying the label and for the accuracy of the information contained therein. If neither the manufacturer nor his authorized agent is established in the Community, this obligation shall fall on the person responsible for first placing the footwear on the Community market. The retailer shall remain responsible for ensuring that the footwear sold by him bears the appropriate labelling prescribed by this Directive."

That's the same shape as ESPR's own manufacturer/distributor/dealer split, three decades before ESPR existed: the party that makes or first imports the footwear supplies the label and answers for its accuracy; the retailer carries an independent duty to check the label is actually there before selling. Annex II — the Directive's own non-exhaustive product list — closes with a direct link worth knowing for the customs section below: "products covered by Chapter 64 of the combined nomenclature ('CN') may, as a general rule, be regarded as falling within the scope of this Directive."

3. Producer responsibility: footwear is already in scope EU-wide — and France got there first

Unlike the DPP itself, extended producer responsibility (EPR) for footwear is not a future question. Our Textile EPR guide already covers the EU-wide mechanics in full; footwear's position within it is unambiguous:

Directive (EU) 2025/1892, Annex IVc, Part II

Footwear gets its own dedicated part of the Directive's product-scope annex, separate from apparel's: "Footwear, and articles of apparel and clothing accessories for household use or other uses, where such products are similar in nature and composition to those for household use, whose main composition is not textile, that fall within the scope of Article 22a" — listing CN codes 6401 to 6405 by name. The Directive entered into force 16 October 2025; Member States must transpose it into national law by 17 June 2027 at the latest.

Footwear was never an afterthought bolted onto a textiles rule — it's named explicitly, alongside apparel, in the EU-wide instrument itself. What's genuinely footwear-specific is how much longer this has already been true in one particular Member State.

France: sixteen years of history apparel brands don't have to think about

France's national EPR scheme for this sector isn't called a "textile" scheme at all in its own founding documents — it's called "TLC," and the "C" stands for footwear:

Refashion (formerly Eco-TLC) — French Code de l'environnement, Art. L. 541-10-3

"TLC" stands for Textiles d'habillement, Linge de maison et Chaussures — clothing textiles, household linen, and footwear. Refashion's predecessor, Eco-TLC, received its first ministerial accreditation on 17 March 2009 (Arrêté du 17 mars 2009), following an application dated 13 January 2009 — under Articles L. 541-10-3 and D. 543-214 of the French Code de l'environnement. Refashion has been re-accredited three times since (2014, 2019, 2022).

Do the arithmetic: France required EPR compliance for footwear specifically from March 2009 — roughly sixteen years before Directive (EU) 2025/1892 made this mandatory across the whole EU bloc. A footwear brand selling into France before the EU-wide directive's own 17 June 2027 transposition deadline has already been operating under a separate national registration, fee and reporting regime, with its own French eco-organism, for over a decade and a half. Other Member States, by contrast, generally did not run footwear-inclusive EPR schemes before the EU-wide directive arrived — France is the outlier, not the template. See our Textile EPR guide's own Member State research for which other countries already had schemes running, and for which ones are building theirs from scratch under the new EU-wide deadline.

4. Chromium VI: the REACH restriction that targets leather footwear specifically

Our PFAS & REACH guide already covers the PFHxA restriction that explicitly names footwear (in force from 10 October 2026). Leather footwear carries a second, older, footwear-relevant REACH restriction that has nothing to do with PFAS at all, and that apparel brands working mainly in textile fabrics rarely need to think about:

REACH Annex XVII, Entry 47(5)–(7) — introduced by Commission Regulation (EU) No 301/2014

"5. Leather articles coming into contact with the skin shall not be placed on the market where they contain chromium VI in concentrations equal to or greater than 3 mg/kg (0,0003 % by weight) of the total dry weight of the leather. 6. Articles containing leather parts coming into contact with the skin shall not be placed on the market where any of those leather parts contains chromium VI in concentrations equal to or greater than 3 mg/kg (0,0003 % by weight) of the total dry weight of that leather part. 7. Paragraphs 5 and 6 shall not apply to the placing on the market of second-hand articles which were in end-use in the Union before 1 May 2015."

Paragraph 6 is the one that matters most for footwear specifically: it doesn't just cover standalone leather goods, it covers any article — a shoe, in practice — that contains leather parts in skin contact, even if the rest of the shoe is a different material entirely. A leather-lined sneaker with a synthetic upper is squarely inside this restriction's scope for its lining alone. This restriction has applied since 1 May 2015 — over a decade of established testing and compliance practice, unlike several of the newer ESPR-track obligations still being finalised.

5. Leather sourcing: what already doesn't apply, and why

Our EUDR & Leather guide already covers this in depth for the site generally; footwear brands specifically get a double reassurance rather than a single one. Finished footwear — like finished bags and leather apparel — never had its own entry in the EU Deforestation Regulation's Annex I list of regulated commodities and products in the first place, so the due-diligence duty never reached finished goods like shoes even before anything changed recently. And as of 18 September 2026, Delegated Regulation (EU) 2026/2102 removed the upstream leather HS codes (raw hides, tanned hides, finished leather material) from Annex I entirely. A footwear brand buying already-finished leather — soles, uppers, trim — was essentially never inside EUDR's scope for that leather, on either count. The only theoretical exposure ever existed for a company directly importing raw or semi-tanned hides itself — typically a tannery or leather-material trader, not a footwear brand buying finished material — and even that narrow case is now closed.

6. A different customs chapter entirely

Our DPP & Customs guide covers the general mechanics of how the EU DPP Registry ties into commodity codes at the border. Footwear's own position in that system starts from a structurally different place than apparel's: footwear is classified under EU Combined Nomenclature (CN) Chapter 64 — "Footwear, gaiters and the like; parts of such articles" — headings 6401 to 6405 for footwear itself, and heading 6406 specifically for footwear parts. Apparel sits in entirely separate chapters (61 and 62). Footwear was never nomenclature-adjacent to clothing to begin with.

This is exactly why Directive (EU) 2025/1892's Annex IVc has to separately, explicitly list footwear's own CN codes rather than footwear being automatically swept in under a generic "textiles" heading — and it's the same reason the EU DPP Registry (ESPR Art. 13), which stores commodity codes for products entering free circulation, will key footwear's customs treatment off Chapter 64 codes specifically once a delegated act ever applies to it, not off apparel's own codes.

7. What this means in practice

A footwear brand's compliance map has more independently-moving parts than an apparel-only brand's, but most of them are already fixed law, not future uncertainty: the labelling directive, the chromium VI restriction, and EU-wide (plus French) EPR obligations are all already binding today, regardless of where the DPP itself ends up. Only the DPP's own footwear-specific data content remains genuinely open. A practical starting point: audit your current footwear labels against the 80% Annex I threshold and the three-part pictogram system now, since Directive 94/11/EC isn't waiting for anything; confirm your French sales are actually registered with Refashion under the TLC filière if you sell there; and if leather is anywhere in your uppers or linings, get a chromium VI test result on file rather than assuming a supplier's tannery already handles it.

With that many SKU-level variables — material category per part, per style, per season, on top of the same DPP data fields every fashion brand eventually needs — footwear brands tend to reach the point where spreadsheet-based tracking breaks down faster than a smaller apparel-only range would.

BUILD & HOST

More styles, more parts, more materials per SKU — footwear multiplies the data problem.

Build & Host structures footwear's own compliance layers — labelling data, chromium test results, EPR registration status, and eventual DPP fields — into one production-ready system per style, scoped after a Full Collection Audit and maintained on a monthly retainer for the 10-year horizon the regulation requires.

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Frequently asked questions

Does the Digital Product Passport already apply to footwear? +

Not yet, and its exact scope is genuinely less settled than apparel's. Footwear is named alongside textiles in ESPR's own priority list (Article 4(5)(c)), but the Commission's detailed ESPR Working Plan explicitly separates it out as "a separate product category from textiles," with no delegated-act timeline of its own — only a feasibility study, due by the end of 2027. The JRC's own textile-apparel preparatory study — the one setting candidate data requirements for the eventual delegated act — mentions footwear only once, as a citation of a shared environmental-footprint methodology, not as an included product in its own data-point list. There is no dedicated ESPR preparatory-study product group for footwear at all as of publication. Footwear brands should not assume they're on the same delegated-act timeline as apparel; footwear's own scope, data content and timing all remain genuinely undetermined.

Is there a separate JRC study specifically for footwear? +

There is a JRC "Footwear" project, but it is easy to confuse with the DPP work and it is not the same thing. That project is a revision of the EU Ecolabel criteria for "Footwear and leather products," carried out under the separate, voluntary EU Ecolabel Regulation (EC) No 66/2010 — the study itself dates from 2013–2015 and has nothing to do with the Digital Product Passport or ESPR. Searching for "JRC footwear" can easily land on this unrelated page instead of the actual ESPR-relevant textile study (product group 467), which does not have footwear in its own scope.

Does the existing EU footwear labelling law still apply once the DPP arrives? +

Yes — Directive 94/11/EC on footwear labelling is a separate, already-decades-old law that ESPR does not repeal or replace. It requires every pair of footwear sold in the EU to carry pictogram or written labelling for three parts — the upper, the lining and sock, and the outsole — identifying whichever material makes up at least 80% of each part's surface area or volume. This obligation exists independently of the Digital Product Passport and will keep applying alongside it once footwear is covered by a delegated act.

Is chromium VI in leather footwear actually restricted under EU law? +

Yes, and it has been since 2015 — well before any DPP-related discussion began. REACH Annex XVII, entry 47, introduced by Commission Regulation (EU) No 301/2014, prohibits placing leather articles, or articles containing leather parts, on the market where the leather contains chromium VI at 3 mg/kg or more of the total dry weight, wherever that leather comes into contact with skin. For footwear, this covers leather uppers and linings directly, and has applied since 1 May 2015.

Why does France treat footwear differently from other EU countries on producer responsibility? +

Because France built footwear into its national textile EPR scheme from the very start, long before the EU harmonised this rule bloc-wide. Refashion (formerly Eco-TLC) — "TLC" standing for Textiles d'habillement, Linge de maison et Chaussures, i.e. clothing textiles, household linen and footwear — received its first ministerial accreditation on 17 March 2009, under Article L. 541-10-3 of the French Code de l'environnement. That is roughly 16 years before Directive (EU) 2025/1892 made textile-and-footwear EPR mandatory across the whole EU. A footwear brand selling into France has had a separate national compliance duty, with its own registration and fee mechanics, since 2009.

Does the EU Deforestation Regulation (EUDR) apply to leather footwear? +

No, for two independent reasons. First, finished footwear, like finished bags and leather apparel, never had its own entry in EUDR's Annex I of regulated commodities and products — the due diligence duty never reached finished goods, only raw and semi-processed leather further up the chain. Second, as of 18 September 2026, even those upstream leather HS codes (raw hides, tanned hides, finished leather material) were removed from Annex I entirely by Delegated Regulation (EU) 2026/2102. A footwear brand buying already-finished leather, uppers or soles was essentially never in EUDR's scope, and the narrow theoretical exposure that existed for direct raw-material importers is now closed.

Sources

Footwear labellingDirective 94/11/EC of the European Parliament and of the Council of 23 March 1994 on the approximation of the laws, regulations and administrative provisions of the Member States relating to labelling of the materials used in the main components of footwear for sale to the consumer (consolidated text, 01.07.2013). Articles 1, 2, 4, 5; Annexes I and II. CELEX 01994L0011-20130701 ↗
PPE regulation superseding the labelling directive's protective-footwear exclusionRegulation (EU) 2016/425 of the European Parliament and of the Council of 9 March 2016 on personal protective equipment and repealing Council Directive 89/686/EEC, applicable from 21 April 2018. CELEX 32016R0425 ↗
Chromium VI in leatherRegulation (EC) No 1907/2006 (REACH), Annex XVII, entry 47, paragraphs 5–7, as introduced by Commission Regulation (EU) No 301/2014 of 25 March 2014. CELEX 02006R1907 (consolidated) ↗
ESPR scope — footwear named in the priority list, then split out from the delegated-act timelineRegulation (EU) 2024/1781 (ESPR), Article 4(5)(c) (first working plan priority list: "textiles, in particular garments and footwear"); European Commission, Communication COM(2025) 187 final, "Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025–2030" (Brussels, 16.4.2025), Section 2.2.3: footwear "is in a separate product category from textiles due to the distinct use of materials, product functionality and supply chains" and gets only a feasibility study, due by the end of 2027, not a delegated-act timeline. CELEX 32024R1781 ↗
JRC — textile-apparel study (footwear not in scope) and unrelated Ecolabel "Footwear" projectJoint Research Centre, Product Bureau: "Textile products" preparatory study, product group 467 (ESPR-relevant), and "Footwear" project, product group 434 (EU Ecolabel Regulation (EC) No 66/2010, unrelated, 2013–2015), accessed 28.09.2026. susproc.jrc.ec.europa.eu/467 ↗ · susproc.jrc.ec.europa.eu/434 ↗
Textile & footwear EPR — EU-wideDirective (EU) 2025/1892, Annex IVc. See our Textile EPR guide for the full citation already verified site-wide.
Refashion / Eco-TLC — France's footwear-inclusive EPR schemeADEME (French Agency for Ecological Transition), "Textiles d'habillement, linges de maison et chaussures (TLC)" filière page; French Ministry of Ecological Transition, Bulletin Officiel, Arrêté du 17 mars 2009 portant agrément d'un organisme ayant pour objet de percevoir les contributions au recyclage; French Code de l'environnement, Articles L. 541-10-3 and D. 543-214. Accessed 28.09.2026. filieres-rep.ademe.fr ↗
EUDR & leather footwearRegulation (EU) 2023/1115 (EUDR), Annex I; Commission Delegated Regulation (EU) 2026/2102 of 13 July 2026. See our EUDR & Leather guide for the full citation already verified site-wide.
Customs classificationEU Combined Nomenclature, Chapter 64 ("Footwear, gaiters and the like; parts of such articles"), headings 6401–6406; confirmed directly within Directive 94/11/EC, Annex II. European Commission, Access2Markets trade portal. trade.ec.europa.eu ↗

All sources were accessed and verified directly on EUR-Lex, the Joint Research Centre's Product Bureau, and official French government publications on 28.09.2026, and re-verified a second time before publication. Consolidated legal texts are unofficial documentation tools per EUR-Lex's own disclaimer, with the Official Journal as the authentic source.