PRODUCT SAFETY GUIDE
GPSR for Fashion and Footwear Brands: The Product-Safety Data Already Required Under Regulation (EU) 2023/988, and Where It Meets the DPP
The GPSR (Regulation (EU) 2023/988) has applied since 13 December 2024, including to clothing and footwear sold to consumers: only safe products may be placed on the market. Several of its rules already ask for data ESPR lists as possible passport content. One point is open: whether the operator duties in Articles 9 to 18 apply to garments and shoes.
Same data: GPSR, then ESPR
- Manufacturer contactArt. 19(a)Art. 36(1)(a)
- Product identificationArt. 19(c)Art. 36(1)(c)
- Batch/serial numberArt. 9(5)*Art. 27(5)
- Safety informationArt. 19(d)*Art. 27(7)
- Marketplace contactArt. 22(1)Art. 35(3)
* depends on the open question (Art. 2(1))
What you need to know
- 1
Your brand is the manufacturer.
Whoever has products made and markets them under its own name or trademark is the “manufacturer” (Art. 3(8)). The DPP waits for an ESPR delegated act; a search on 20 October 2026 found none for textiles or footwear. §1
- 2
The open question.
Articles 9 to 18 do not apply to products subject to specific requirements of EU “harmonisation legislation”, which includes the textile and footwear labelling acts and REACH. One reading puts garments and shoes under that carve-out; another says composition-labelling rules do not trigger it. We found no guidance or ruling settling it. §2
- 3
Online offers apply either way.
Each offer must show the manufacturer’s name and postal and electronic address, product identification including a picture, and required warnings (Art. 19). The EU responsible person and some warnings depend on the open question. §3
- 4
Accidents must be reported.
The manufacturer ensures that an accident causing death or serious adverse effects on health and safety is notified without undue delay through the Safety Business Gateway (Art. 20). Online marketplaces must act on authority orders within two working days (Art. 22(4)). §3
- 5
Kids’ drawstrings: a presumption, not a pass.
Conformity with EN 14682:2014 gives a presumption of conformity only for the risks the standard covers (Art. 7). Other risks are assessed under Article 6, and authorities can still act on evidence that a product is dangerous. §4
- 6
Where the GPSR meets the DPP.
Once a clothing or footwear delegated act applies, the type, batch or serial number, manufacturer and importer contacts and safety information become ESPR duties (Art. 27(5)–(7), 29(3)), whatever the GPSR answer. §5
What to do now
Keep one record per style.
Type, variants, batch or lot, GTIN where used, main picture. §7
Keep one master contact record.
Manufacturer, importer and EU operator, so a change reaches labels, listings and passport together. §7
Decide how to treat Articles 9 to 18.
Applying them while the question is open is a cautious business choice, not a legal conclusion. §7
Status of the guide: 23 October 2026. Based on the GPSR (Regulation (EU) 2023/988), Articles 2, 3, 7, 9 to 22, ESPR (Regulation (EU) 2024/1781), Articles 27, 29, 35 and 36, and Implementing Decision (EU) 2026/901. A simplified summary: the full guide below and the EU texts are authoritative. Not legal advice.
Everything below is the complete, sourced guide. ↑ Back to the short version
The Digital Product Passport for clothing and footwear still depends on an ESPR delegated act that had not been adopted by 20 October 2026. Product-safety law already applies: the General Product Safety Regulation, Regulation (EU) 2023/988 (GPSR), has applied since 13 December 2024 (Article 52) to products placed or made available on the market "whether new, used, repaired or reconditioned" (Article 2(3)), and clothing and footwear sold to consumers are such products. Several of its rules already ask for data that ESPR lists as possible passport content, for a delegated act to select: who made the product, how it is identified, which warnings go with it and, depending on the open question below, who answers for it in the EU.
One point is genuinely open. The GPSR switches off its section on manufacturers, importers, distributors and the EU responsible person (Articles 9 to 18) for products "subject to specific requirements imposed by Union harmonisation legislation", and the list that defines that legislation includes the Textile Labelling Regulation, the footwear labelling Directive and REACH, which restricts certain substances in clothing and footwear. Whether that carve-out reaches garments and shoes has not been settled by the Commission's guidelines or, as far as we found, by any court. This guide sets out both readings, the duties that apply either way, the children's-clothing standard EN 14682:2014, and what the GPSR requires now compared with what ESPR adds once a delegated act applies.
13 Dec 2024
Date from which the GPSR applies (Article 52). It covers consumer products, including clothing and footwear; no DPP duty applies to them yet.
Arts 9–18
Chapter III, Section 1: the manufacturer, importer, distributor and responsible-person duties that Article 2(1), third subparagraph, point (b), disapplies for products subject to specific requirements imposed by Union harmonisation legislation. Whether that covers garments and footwear is open.
Item 37
EN 14682:2014 on cords and drawstrings on children's clothing, in Annex I to Implementing Decision (EU) 2026/901, in force since 27 April 2026.
2 working days
Time limit for an online marketplace to act on a market surveillance authority's order about an offer of a dangerous product (Article 22(4)).
1. The GPSR applies today; the DPP waits for a delegated act
Article 5, Regulation (EU) 2023/988 (GPSR)
"Economic operators shall place or make available on the market only safe products."
The GPSR repealed the General Product Safety Directive 2001/95/EC with effect from 13 December 2024 (Article 50(1)); Member States may not impede the making available of products that conform to that Directive and were placed on the market before that date (Article 51). It covers any item which "is intended for consumers or is likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them" (Article 3(1)). The "manufacturer" is whoever manufactures a product or has it designed or manufactured, "and markets that product under that person’s name or trademark" (Article 3(8)). A brand that has garments or shoes made by a supplier and sells them under its own trademark is therefore the manufacturer for GPSR purposes.
On 21 November 2025 the Commission published guidelines for businesses (C/2025/6233, corrected on 4 March 2026 in four language versions, not the English one) and guidelines on the Safety Business Gateway (C/2025/6238). Both state that "only the text of the EU legislation itself has legal force".
The DPP works differently. Under ESPR, Regulation (EU) 2024/1781, a passport becomes a condition for placing a product on the market only through the information requirements of a delegated act (Article 9(1)), and a delegated act's date of application "shall not be earlier than 18 months from its entry into force", except in duly justified cases or in cases of partial repeal or amendment of delegated acts (Article 4(4)). A search of the EU Publications Office records on 20 October 2026 found no ESPR delegated act for textiles or footwear. The expected dates are in our DPP master timeline; where footwear stands is explained in our footwear guide. Until then, several of the data points that ESPR Annex III lists as possible passport elements are already required, for product-safety purposes, by the GPSR (section 5).
2. The open question: do Articles 9 to 18 apply to garments and footwear?
Article 2(1), third subparagraph, GPSR, as amended by Regulation (EU) 2024/2748
"With regard to products subject to specific requirements imposed by Union harmonisation legislation as defined in Article 3, point (27): (a) Chapter II does not apply insofar as the risks or categories of risks covered by Union harmonisation legislation are concerned; (b) Chapter IIa, Chapter III, Section 1, Chapters V and VII and Chapters IX to XI do not apply."
Article 3, point (27), defines Union harmonisation legislation as the legislation listed in Annex I to Regulation (EU) 2019/1020 "and any other Union legislation harmonising the conditions for the marketing of products to which that Regulation applies". That Annex lists Directive 94/11/EC on the labelling of the materials used in the main components of footwear (item 8) and Regulation (EU) No 1007/2011, the Textile Labelling Regulation (item 40), covered in our Textile Labelling Regulation guide. It also lists REACH, Regulation (EC) No 1907/2006 (item 22). Chapter III, Section 1, is the core of the GPSR's operator duties: the manufacturer's internal risk analysis and technical documentation, kept for 10 years (Article 9(2) and (3)); a "type, batch or serial number or other element enabling the identification of the product" (Article 9(5)); the manufacturer's name and postal and electronic address on the product (Article 9(6)); instructions and safety information (Article 9(7)); corrective action, complaint channels and a complaints register (Article 9(8) to (13)); the checks of importers and distributors (Articles 11 and 12); and the EU responsible person (Article 16).
Reading 1: the carve-out applies. Point (b) is not limited to safety rules. It applies to products "subject to specific requirements imposed by Union harmonisation legislation", and a garment that must carry a fibre-composition label, or a shoe that must carry a materials label, is subject to such requirements. Recital 8 says that "most of the obligations of economic operators, should not apply to products covered by Union harmonisation legislation", and the Commission's business guidelines state, in general terms, that Chapter III, Section 1 "does not apply with respect to products subject to specific requirements imposed by Union harmonisation legislation" (footnote 17). On this reading, Articles 9 to 18 do not apply to clothing and footwear, and nor do the GPSR chapters on market surveillance (Chapter V), on the Commission's role and enforcement coordination (Chapter VII), or on international cooperation, financing and final provisions such as penalties (Chapters IX to XI). Market surveillance of such products then runs under Regulation 2019/1020 (Article 2(1) of that Regulation); how market surveillance and penalties work is covered in our penalties guide.
Reading 2: rules that only govern composition labelling do not trigger it. Article 2(1) opens by applying the GPSR "insofar as there are no specific provisions with the same objective under Union law which regulate the safety of the products concerned"; recital 7 explains that the scope rules are there "to avoid overlapping provisions", and recital 6 gives the GPSR the role to "fill gaps". The subject matter of the Textile Labelling Regulation and of Directive 94/11/EC is the labelling of fibre and material composition (Article 1 of each act), not product safety. Reading 1 also leaves a gap: Regulation 2019/1020 requires an EU-established economic operator only for products subject to the acts listed in its Article 4(5), and neither labelling act is listed there. A garment or shoe whose manufacturer is not established in the EU, sold directly to EU consumers, would then need no EU-established responsible operator under either Regulation, unless it falls under another act listed in Article 4(5). Recital 39 explains that the requirement was extended to products outside Union harmonisation legislation "to ensure that there is a responsible economic operator established in the Union". Reading 2 also has to deal with REACH, item 22 of the same Annex I: clothing and footwear are themselves subject to REACH restrictions (for example Annex XVII, entries 43 and 72), so on this reading Articles 9 to 18 apply only if such substance restrictions do not make a garment or shoe "subject to specific requirements imposed by Union harmonisation legislation" either. The guidelines' childcare-article example, discussed below, bears on that point.
What the Commission has said. Section 2.2 of the business guidelines lists, for products subject to specific requirements imposed by Union harmonisation legislation, the chapters that apply and those that do not, without discussing what makes a product subject to such requirements. The two notices do not mention clothing, footwear, textiles or the two labelling acts. In an example on scope, the guidelines say the GPSR "applies fully" to childcare articles, gymnastic equipment and furniture, "since these categories of products are not subject to specific requirements imposed by other EU legislation". If every requirement in a listed act triggered point (b), that example would be hard to square with REACH, which restricts certain phthalates in childcare articles that can be placed in the mouth by children (Annex XVII, entry 52). The guidelines do not explain the point.
What changed from the old Directive. Under Directive 2001/95/EC, where products were subject to specific safety requirements imposed by Community legislation, Articles 5 to 18, which included the obligations of producers and distributors, applied except where specific provisions with the same objective governed the aspects concerned (Article 1(2)(b)). The GPSR keeps an aspect-based test in the first two subparagraphs of Article 2(1), the second of which refers to "specific safety requirements imposed by Union law". For products subject to specific requirements imposed by Union harmonisation legislation, the third subparagraph replaced the aspect-by-aspect test with the chapter-level wording quoted above.
Our assessment. Both readings can be argued from the texts. We found no Commission guidance and no judgment of the EU courts that decides the point for clothing or footwear; a search of the Publications Office records on 20 October 2026 found two EU court cases linked to the GPSR, and neither concerns Article 2(1). The rest of this guide therefore marks the provisions concerned as depending on the open question. This is an analysis of the legal texts, not a statement of how any authority applies them.
3. What applies to clothing and footwear either way
Point (b) leaves several parts of the GPSR in place. For products subject to specific requirements imposed by Union harmonisation legislation, the Commission's guidelines list as applicable Chapter I, Chapter II for the risks not covered by that legislation, Chapter III, Section 2 (distance sales, accidents, information in electronic format), Chapter IV (online marketplaces), Chapter VI (Safety Gate and Safety Business Gateway) and Chapter VIII (right to information and to a remedy, including recalls). Recital 8 explains why: the rules on marketplaces, accidents, consumer information and recalls "should apply to products covered by Union harmonisation legislation to the extent that there are no specific provisions with the same objective in such Union harmonisation legislation".
| GPSR provision | What it requires | Garments and footwear |
|---|---|---|
| Article 5, with Articles 6 to 8 | Only safe products may be placed or made available. Safety is assessed against, among other things, the product's design and composition, its labelling and warnings, and the risk for vulnerable consumers such as children (Article 6(1), points (a), (d) and (e)). | Applies to the risks that a harmonisation act does not cover (Article 2(1), third subparagraph, point (a)). |
| Article 7 | Conformity with a European standard whose reference is published in the Official Journal gives a presumption of conformity with the general safety requirement for the risks the standard covers (section 4). | Applies (Chapter II). |
| Article 19 | Online and other distance-sales offers "shall clearly and visibly indicate at least": the manufacturer's name, registered trade name or registered trade mark and postal and electronic address; where the manufacturer is not established in the EU, the responsible person; information identifying the product, "including a picture of it, its type and any other product identifier"; and any warning or safety information that the GPSR or the applicable Union harmonisation legislation requires to be affixed to the product or packaging or included in an accompanying document, in a language consumers can easily understand as determined by the Member State. | Applies (Chapter III, Section 2). Point (b) refers to the responsible person "within the meaning of Article 16(1) of this Regulation or Article 4(1) of Regulation (EU) 2019/1020", so what it requires where the manufacturer is not established in the EU depends on the open question. Point (d) covers the warnings required by the GPSR, such as those under Article 9(7), or by harmonisation legislation, so its GPSR part also depends on the open question. |
| Article 20 | The manufacturer must ensure that an accident caused by its product is notified through the Safety Business Gateway, without undue delay, to the authorities of the Member State where it occurred, with the type and identification number of the product. Accidents are occurrences that resulted in death or serious adverse effects on a person's health and safety (Article 20(2)). Importers and distributors inform the manufacturer (Article 20(3)); where the manufacturer is not established in the EU, the responsible person who knows of the accident ensures it is notified (Article 20(4)). | Applies. The Commission's Safety Business Gateway guidelines state that reporting accidents through the Gateway "is an obligation for all products, including those which are also subject to Union harmonisation legislation". Paragraph 4 refers to the responsible person "within the meaning of Article 16(1) of this Regulation or Article 4(1) of Regulation (EU) 2019/1020", so, as with Article 19(b), who must ensure notification where the manufacturer is not established in the EU depends on the open question. |
| Article 21 | For the information required by Article 9(5), (6) and (7), Article 11(3), Article 16(3) and the relevant provisions of Union harmonisation legislation, operators "may additionally make the information referred to in those provisions available in a digital format" by means of electronic technical solutions clearly visible on the product or, where that is not possible, on its packaging or in an accompanying document. | Applies; it adds a digital channel and does not replace the information on the product, packaging or accompanying document. The GPSR provisions it refers to are in Chapter III, Section 1, so for garments and footwear its GPSR part depends on the open question. |
| Article 22 | Online marketplaces need a single point of contact for authorities, registered on the Safety Gate Portal, and one for consumers; they must act on authority orders without undue delay and within two working days at the latest, and process product-safety notices within three working days at the latest; their interfaces must let traders show the Article 19 information on each listing (Article 22(1), (2), (4), (8) and (9)). | Applies (Chapter IV). |
| Articles 35 to 37 | Recalls: affected consumers who can be identified are notified directly; a written recall notice is headed "Product safety recall" and shows, among other things, a picture, name and brand of the product, product identification numbers such as batch or serial number, the hazard, the action to take and the remedies (Article 36(2)). The template is set by Implementing Regulation (EU) 2024/1435. | Chapter VIII applies. Article 35(1) ties the operators' role to "their respective obligations as provided for in Articles 9, 10, 11 and 12", so for operators its reach also turns on the open question; the marketplaces' role under Article 22(12) does not. |
Depends on the open question: Article 9 (risk analysis and technical documentation, identification number, contact details on the product, instructions and safety information, corrective action, complaint channels and register), Article 10 (authorised representatives), Article 11 (importers), Article 12 (distributors), Article 13 (when another person takes on the manufacturer's obligations), Articles 14 and 15 (internal processes, cooperation with authorities), Article 16 (responsible person), Article 17 (information to economic operators) and Article 18 (traceability requirements for certain products).
Accessories. Leather bags and belts, metal jewellery and other accessories that are neither textile products nor footwear fall outside both labelling acts. That does not settle their position. REACH, item 22 of the same Annex I, restricts for example nickel in jewellery and other articles in direct and prolonged contact with the skin (Annex XVII, entry 27) and chromium VI in leather articles that come into contact with the skin (entry 47), so their position turns on whether such substance restrictions on their own trigger point (b), the same REACH question that arises for clothing and footwear (see Reading 2 above and, for entry 72, our REACH Entry 72 guide).
4. Children's clothing: EN 14682:2014 and the Article 7 presumption
Article 7(1), point (a), GPSR
A product shall be "presumed to be in conformity with the general safety requirement laid down in Article 5" where "it conforms to relevant European standards or parts thereof as far as the risks and risk categories covered by those standards are concerned, the references of which have been published in the Official Journal of the European Union in accordance with Article 10(7) of Regulation (EU) No 1025/2012".
Commission Implementing Decision (EU) 2026/901 of 17 April 2026 publishes those references for the GPSR. Its Annex I, item 37, is "EN 14682:2014 Safety of children’s clothing — Cords and drawstrings on children’s clothing — Specifications". The Decision entered into force on the day of its publication, 27 April 2026 (Article 3), and repealed Implementing Decision (EU) 2019/1698, the list made under the old Directive, in which the same standard was item 48 of Annex I. The date of 27 October 2027 in Article 2 of the new Decision concerns only the four superseded standards in its Annex II, none of them a clothing standard; EN 14682:2014 has no withdrawal date.
The presumption has limits. It covers only "the risks and risk categories covered by those standards", so other risks of the same garment are assessed under Article 6, which names the risk for vulnerable consumers such as children (Article 6(1)(e)). It "shall not prevent market surveillance authorities from taking all appropriate measures under this Regulation where there is evidence that, despite such presumption, the product is dangerous" (Article 7(3)). Only the reference of the standard is published in the Official Journal; this guide does not describe its technical content.
Where a manufacturer applies the standard, the technical documentation under Article 9(2) contains, where appropriate, "the list of any relevant European standards" applied, a duty that falls within the open question for clothing. Recital 92 shows that the legislator had this risk in view: among the remedies consumers can carry out themselves, it names "cutting excessively long drawstrings on a children’s garment when provided for in the recall notice".
5. Where the GPSR meets the DPP
The GPSR has no passport of its own, but ESPR builds on it in three places. Annex III, point (k), lists among the elements a delegated act may put in the passport "the name, contact details and unique operator identifier of the economic operator established in the Union responsible for carrying out the tasks set out in Article 4 of Regulation (EU) 2019/1020 or Article 15 of Regulation (EU) 2023/988, or similar tasks pursuant to other Union law applicable to the product". In the adopted GPSR, Article 15 deals with cooperation with market surveillance authorities; the responsible person is Article 16. Article 15 was the responsible-person article in the Commission's 2021 proposal (COM(2021) 346), and ESPR has not been amended or corrected on this point. Article 36(1) requires distance-sales offers of products covered by a delegated act to show data close to GPSR Article 19, and Article 35(3) allows a marketplace's ESPR contact point to be "the same contact point as that referred to in Article 22(1) of Regulation (EU) 2023/988". Articles 35 and 36 are explained in our online-selling guide.
| Data | Required now (GPSR) | Required once a delegated act applies (ESPR) |
|---|---|---|
| Manufacturer in the online offer | Name, registered trade name or registered trade mark, postal and electronic address (Article 19(a)). | The same (Article 36(1)(a)). |
| EU operator in the online offer, where the manufacturer is not established in the EU | Name, postal and electronic address of the responsible person under Article 16(1) GPSR or Article 4(1) of Regulation 2019/1020 (Article 19(b)); for garments and footwear see section 2. | Name, postal and electronic address and telephone number of the operator within the meaning of Article 4(2) of Regulation 2019/1020 (Article 36(1)(b)). |
| Product identification in the offer | Information identifying the product, including a picture, its type and any other product identifier (Article 19(c)). | The same wording (Article 36(1)(c)); the passport adds a unique product identifier at the level the delegated act sets (Annex III, point (b)). |
| Warnings and safety information | In the online offer (Article 19(d)); with the product under Article 9(7) (open question). | Article 27(7): digital instructions, which the manufacturer includes in the passport where there is one, and, on paper in a concise format, safety information and the instructions relevant for health and safety. Not in Article 36(1). Annex III, point (f), lists "user manuals, instructions, warnings or safety information, as required by other Union law applicable to the product" as an element a delegated act may select. |
| Type, batch or serial number on the product | Article 9(5) (open question). | Article 27(5). |
| Manufacturer's contact details on the product | Article 9(6) (open question). | Article 27(6): on the product and "on the public part of the digital product passport, where applicable". |
| Importer's contact details | Article 11(3) (open question). | Article 29(3), including the public part of the passport where applicable; the importer's information and EORI number are Annex III elements (point (j)). |
| EU-established responsible operator | Article 16: name and contact details on the product, its packaging, the parcel or an accompanying document (open question). | Annex III, point (k), if the delegated act selects it. |
| Marketplace contact point for authorities | Single point of contact, registered on the Safety Gate Portal (Article 22(1)). | Single contact point for ESPR, which may be the GPSR one (Article 35(3)). |
One consequence: for clothing or footwear covered by a future delegated act, the type, batch or serial number, the manufacturer's and importer's contact details and the instructions and safety information become ESPR duties (Articles 27(5) to (7) and 29(3)), whatever the answer to the GPSR question. The same may be true of the EU-established operator: Article 4(5) of Regulation 2019/1020 lists the Ecodesign Directive 2009/125/EC, and ESPR Article 79(3) provides that references to that Directive are to be construed as references to ESPR; our non-EU brands guide explains that reading. The customs data that names the responsible economic operator is covered in our customs-code guide, and identifiers in our product-identifiers guide.
6. What is still pending
| Item | Status on 20 October 2026 |
|---|---|
| Revision of Regulation (EU) 2019/1020 (Have your say, initiative 14807) | A call for evidence and a public consultation ran from 12 November 2025 to 4 February 2026. A Commission proposal was planned for the third quarter of 2026, which ended on 30 September 2026 without one; the record, last modified on 26 June 2026, still lists it as upcoming, and a search of the Publications Office records found no 2026 Commission proposal amending that Regulation. The European Parliament's Legislative Train (information as of 20 September 2026) now gives the fourth quarter of 2026 as the updated indicative date and reports that the Commission has merged this revision with the review of the New Legislative Framework into a single proposal; the Commission planning date of 6 October 2026 that it cites has passed. The Commission's evaluation of the Regulation, a staff working document dated 9 October 2026 (SWD(2026) 309), does not address GPSR Article 2(1) for clothing or footwear. Because GPSR Article 3(27) refers to its Annex I, and its Article 4 sets the EU-operator rule, a revision could affect the question in section 2; the initiative's summary does not mention the GPSR. |
| Proposal COM(2025) 504 on digitalisation and common specifications | Commission proposal of 21 May 2025 amending seven regulations, including ESPR but not the GPSR; for ESPR it would among other things define a 'digital contact' and require information requested by authorities to be provided in electronic form. Procedure 2025/0134(COD): according to the European Parliament's Legislative Observatory (OEIL), the committee responsible approved the text agreed in interinstitutional negotiations on 14 July 2026, and the indicative date of the first-reading plenary sitting is 23 November 2026, but no adopted act had been published in the Official Journal. |
| Proposal COM(2026) 780 on European standardisation | Commission proposal of 6 October 2026 (procedure 2026/0307(COD)) to repeal and replace Regulation (EU) No 1025/2012, under whose Article 10(7) the references of European standards drafted in support of the GPSR, such as EN 14682:2014, are published (GPSR Article 7(1)(a)). It would also repeal GPSR Article 48, which inserted that provision, and references to Regulation 1025/2012 would be construed as references to the new Regulation. It does not touch GPSR Article 2(1). No adopted act. |
| ESPR delegated act for textiles | Not adopted; see our DPP master timeline. |
| Rulings on GPSR Article 2(1) | None found. The two EU court cases linked to the GPSR in the Publications Office records concern patent jurisdiction and injunctions (C-196/26) and Delegated Regulation (EU) 2024/3173 on the Safety Gate (T-154/25). |
7. One product-data set for both regimes
The following are practical suggestions, not legal duties. They aim to collect each data point once and reuse it for labels, online offers, marketplace listings, accident reports and, later, the passport.
| Data block | Used today (GPSR) | Used later (ESPR, once a delegated act applies) | Practical suggestion |
|---|---|---|---|
| Identifiers | Online offers (Article 19(c)); recall notices (Article 36(2)); on the product under Article 9(5) (open question). | Article 27(5); Annex III, point (b) (unique product identifier) and, if selected, points (c) and (d). | One record per style: type, variants, batch or lot, GTIN where used, main picture. |
| Operator contacts | Article 19(a) and (b) (for point (b), see section 2); Articles 9(6), 11(3) and 16(3) (open question). | Article 36(1)(a) and (b), which adds a telephone number; Articles 27(6) and 29(3); Annex III, points (g), (j) and (k), if selected. | One master record for manufacturer, importer and EU operator, with postal address, electronic address and telephone number, so a change reaches labels, listings and passport together. |
| Warnings and safety information | Article 19(d); Article 9(7) (open question). | Article 27(7) (digital instructions in the passport; safety information also on paper); Annex III, point (f), if selected. | Store warnings per product and per language, with the Member States in which each language version is used. |
| Safety evidence | Technical documentation under Article 9(2), including, where appropriate, the outcome of test reports and the standards applied, such as EN 14682:2014 (open question). | Annex III, point (e), if selected. | Keep the risk analysis, test reports and list of standards applied per style, including where you treat Article 9 as not applicable. |
| Accidents, complaints and recalls | Article 20 through the Safety Business Gateway, which requires an EU Login account; Article 9(11) and (12) (open question); Articles 35 to 37. | No corresponding ESPR passport element. | Decide who notifies and how importers, distributors and marketplaces pass accident reports to you; keep recall-notice data (picture, identifiers, where and when sold) ready. |
| Marketplace data | Article 22(9) and (10): fields for the Article 19 data and the EU operator. | Article 36(1); Article 35(3). | Feed every marketplace from the same record. |
Many of the data points in Articles 9 to 18 are the same ones that Article 19, the marketplaces and, later, ESPR ask for. Treating them as required for garments and footwear while the question is open is a cautious business choice, not a conclusion about the law.
DPP AUDIT
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We assess your product data, systems and supplier inputs against the GPSR information duties and the ESPR passport requirements, so you know where the gaps are before the textile delegated act is adopted. Under NDA.
Start Your DPP AuditFrequently asked questions
Does the GPSR apply to clothing and footwear?
Why is it unclear whether Articles 9 to 18 apply to garments and shoes?
What must an online offer for a garment show under the GPSR?
Do fashion brands have to report accidents?
Does conformity with EN 14682:2014 mean children's clothing meets the GPSR?
How does the GPSR relate to the Digital Product Passport?
Sources
- GPSRRegulation (EU) 2023/988 of the European Parliament and of the Council of 10 May 2023 on general product safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and Directive (EU) 2020/1828 of the European Parliament and the Council, and repealing Directive 2001/95/EC of the European Parliament and of the Council and Council Directive 87/357/EEC (OJ L 135, 23.5.2023, p. 1). Recitals 6, 7, 8, 39 and 92 (Official Journal text); Articles 2(1) and (3), 3(1), (8) and (27), 5 to 22, 35 to 37, 48, 50, 51 and 52 (consolidated version of 29 May 2026, which includes the amendment of Article 2(1) by Regulation (EU) 2024/2748). Corrigenda checked: 19.12.2023 (Croatian, Dutch, Estonian, Finnish, German, Romanian and Spanish), 21.1.2025 (Portuguese), 20.8.2025 and 18.3.2026 (Spanish); none concerns the English text. CELEX 32023R0988 ↗ · CELEX 02023R0988-20260529 (consolidated) ↗
- Regulation 2024/2748Regulation (EU) 2024/2748 of the European Parliament and of the Council of 9 October 2024 amending Regulations (EU) No 305/2011, (EU) 2016/424, (EU) 2016/425, (EU) 2016/426, (EU) 2023/988 and (EU) 2023/1230 as regards emergency procedures for the conformity assessment, presumption of conformity, adoption of common specifications and market surveillance due to an internal market emergency (OJ L, 2024/2748, 8.11.2024). Article 5, point (1) (new wording of Article 2(1), third subparagraph, point (b), GPSR); Article 7 (application from 29 May 2026). CELEX 32024R2748 ↗
- ESPRRegulation (EU) 2024/1781 of the European Parliament and of the Council of 13 June 2024 establishing a framework for the setting of ecodesign requirements for sustainable products, amending Directive (EU) 2020/1828 and Regulation (EU) 2023/1542 and repealing Directive 2009/125/EC (OJ L, 2024/1781, 28.6.2024). Articles 4(4), 9(1) and (2), 27(5) to (7), 29(3), 35(3), 36(1) and 79(3); Annex III, points (b) to (g), (j) and (k). Read in the Official Journal version; the Regulation has not been amended. Corrigenda checked: 7.8.2024 (Articles 77 and 78), 28.4.2025 (Articles 10(1)(d), 20, 41(4), 65(3) and 69(5)), 27.11.2025 (German only) and 4.2.2026 (Czech only); none changes the English text of the passages cited. CELEX 32024R1781 ↗
- Market Surveillance RegulationRegulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market surveillance and compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 765/2008 and (EU) No 305/2011, consolidated version of 12 August 2026. Articles 2(1) and 4(1), (2) and (5); Annex I, items 8, 22 and 40. CELEX 02019R1020-20260812 (consolidated) ↗
- Implementing Decision 2026/901Commission Implementing Decision (EU) 2026/901 of 17 April 2026 on European standards for products drafted in support of Regulation (EU) 2023/988 of the European Parliament and of the Council, and repealing Commission Implementing Decision (EU) 2019/1698 (OJ L, 2026/901, 27.4.2026). Articles 2 and 3; Annex I, item 37; Annex II. No corrigendum or amendment found. CELEX 32026D0901 ↗ · Commission Implementing Decision (EU) 2019/1698 of 9 October 2019 on European standards for products drafted in support of Directive 2001/95/EC of the European Parliament and of the Council on general product safety (OJ L 259, 10.10.2019, p. 65), Annex I, item 48. CELEX 32019D1698 ↗
- Commission guidelinesCommission Notice, Guidelines on the application of the EU general product safety legislative framework by businesses (C/2025/6233), OJ C, 21.11.2025: section 1 (status of the guidelines), section 2.2 and footnote 17. Corrigendum of 4.3.2026 (German, Estonian, Dutch and Spanish versions only). CELEX 52025XC06233 ↗ · Commission Notice, Guidelines for the practical implementation of the Safety Business Gateway under Article 27(2) of Regulation (EU) 2023/988 (C/2025/6238), OJ C, 21.11.2025: sections 1, 3 and 5.2. CELEX 52025XC06238 ↗
- Labelling acts and REACHRegulation (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 and repealing Council Directive 73/44/EEC and Directives 96/73/EC and 2008/121/EC of the European Parliament and of the Council (Textile Labelling Regulation), Article 1 (consolidated version of 15 February 2018). CELEX 02011R1007-20180215 (consolidated) ↗ · Directive 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, Article 1(1) (consolidated version of 1 July 2013). CELEX 01994L0011-20130701 (consolidated) ↗ · Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), Annex XVII, entries 27, 43, 47 (paragraph 5), 52 and 72 (consolidated version of 22 June 2026). CELEX 02006R1907-20260622 (consolidated) ↗
- Other EU documentsDirective 2001/95/EC of the European Parliament and of the Council of 3 December 2001 on general product safety, Articles 1(2) and 5. CELEX 32001L0095 ↗ · Commission proposal for a Regulation on general product safety, COM(2021) 346 final, 30.6.2021, Article 15. CELEX 52021PC0346 ↗ · Commission Implementing Regulation (EU) 2024/1435 of 24 May 2024 laying down rules for the application of Regulation (EU) 2023/988 of the European Parliament and of the Council as regards establishing the template for a recall notice. Corrigendum of 24.7.2024 (OJ L, 2024/90426) to recital 6 and the Annex. CELEX 32024R1435 ↗ · Commission proposal amending Regulations (EU) No 765/2008, (EU) 2016/424, (EU) 2016/425, (EU) 2016/426, (EU) 2023/1230, (EU) 2023/1542 and (EU) 2024/1781 as regards digitalisation and common specifications, COM(2025) 504 final, 21.5.2025, Article 7; procedure 2025/0134(COD). CELEX 52025PC0504 ↗ · Commission proposal for a Regulation on European standardisation, repealing Regulation (EU) No 1025/2012, COM(2026) 780 final, 6.10.2026, Article 42; procedure 2026/0307(COD). CELEX 52026PC0780 ↗ · Commission Staff Working Document, Evaluation of Regulation (EU) 2019/1020 on market surveillance and compliance of products, SWD(2026) 309 final, 9.10.2026. CELEX 52026SC0309 ↗
- Have your sayEuropean Commission, Have your say, initiative 14807, Revision of Regulation (EU) 2019/1020 on market surveillance and compliance of products (call for evidence and public consultation 12.11.2025 to 4.2.2026; proposal planned for the third quarter of 2026, which ended on 30.9.2026 without a proposal; record last modified 26.6.2026; accessed 23.10.2026). Have your say ↗
- Legislative TrainEuropean Parliament, Legislative Train Schedule, Review of the market surveillance regulation (European Product Act package): Commission work programme indicative date Q3 2026, updated indicative date Q4 2026, Commission planning date 6.10.2026; information updated as of 20.9.2026 (accessed 23.10.2026). Legislative Train ↗
- Legislative ObservatoryEuropean Parliament, Legislative Observatory (OEIL), procedure 2025/0134(COD): key events and forecasts (accessed 23.10.2026). OEIL ↗
EU legal texts and Commission notices were read in the versions published by the EU Publications Office (EUR-Lex) on 20.10.2026, with corrigenda checked: for the GPSR, the Official Journal text for the recitals and the consolidated version of 29 May 2026 for the Articles. The Publications Office records were searched on 20.10.2026 for ESPR delegated acts, acts amending the GPSR and Regulation (EU) 2019/1020, 2026 Commission proposals on product safety, market surveillance or textile and footwear labelling, the procedure file of COM(2025) 504 and EU court cases linked to the GPSR; the Have your say record 14807 was read on 20.10.2026 and again on 23.10.2026, together with the European Parliament's Legislative Train. The proposal COM(2026) 780 and the staff working document SWD(2026) 309 were found and read on 21.10.2026. Article 2(1) of the GPSR is presented as an open question. Re-check this guide when Have your say initiative 14807 shows a published proposal, when COM(2025) 504 is published in the Official Journal, when COM(2026) 780 is adopted, or when the Commission or the EU courts address Article 2(1) for textile products or footwear. This is general information, not legal, financial or investment advice.