What Products Are in Scope?

The study focuses on textile apparel products placed on the EU market. It aligns with the preparatory study definition of a textile product as a product containing at least 80% textile fibres by weight.

Product groups discussed include:

The study also notes that intermediate products such as fibres, yarns, and fabrics are excluded from the formal DPP obligation under the textile apparel scope. However, data from these upstream stages will still be essential because final-product DPP information often depends on supply chain data.

The Core DPP Data Areas for Textile Apparel

For textile and apparel companies, preparing for the Digital Product Passport (DPP) is not only about creating a digital label. It is about building a structured, reliable, and traceable product information system that can support compliance, market access, sustainability communication, and circularity.

The current preparatory work on textile apparel under the Ecodesign for Sustainable Products Regulation (ESPR) groups the proposed DPP content into four main areas: product identification and classification, producer identification, product information, and compliance documentation. These areas give companies a practical starting point for assessing what data they already collect, where that data is stored, which suppliers are involved, and which gaps must be closed before DPP obligations become product-specific legal requirements.

1. Product identification and classification

Source: Table 5.

2. Producer identification

Source: Table 6.

3. Product information

3.1 Material information

Source: Table 7.

3.2 Mechanical properties

Source: Table 7.

3.3 Chemical properties / substances of concern

Source: Table 7.

3.4 Recyclability

Source: Table 7.

3.5 Recycled content

Source: Table 7.

3.6 Other environmental law / organic / ecolabel

Source: Table 7.

3.7 Product footprint

Source: Table 7.

3.8 Manuals and instructions

Source: Table 7.

4. Compliance documentation and verification attributes

4.1 Mechanical properties verification

Source: Table 8.

4.2 Recyclability verification

Source: Table 8.

4.3 Recycled content verification

Source: Table 8.

4.4 Organic content verification

Source: Table 8.

4.5 Product footprint verification

Source: Table 8 and its note.

5. Implementation metadata also proposed in the report

The report also provides a proposed granularity level for each data point in Table 13 and a proposed access-rights level in Table 14. These are not extra product-content attributes, but they are important DPP implementation metadata. Table 13 includes model/batch/item granularity, and Table 14 distinguishes public, authority-only and legitimate-interest access.

Key Readiness Challenges for the Textile Sector

The study identifies several practical challenges that companies should not underestimate.

Fragmented Supply Chain Data

The apparel supply chain is long, global, and often opaque. Final-product DPP data may depend on information from fibre producers, yarn suppliers, fabric mills, dye houses, manufacturers, brands, importers, and retailers.

Even where the legal DPP obligation applies to the final product, the quality of the passport depends on upstream data accuracy and continuity.

Lack of Standardised Digital Formats

Many companies still manage sustainability and compliance information through manual and document-based processes. Data may exist, but not in a structured, machine-readable, interoperable format.

This creates a major challenge for DPP implementation because the DPP depends on reliable digital data, not only static documents.

Granularity Decisions

The study highlights the importance of choosing the right level of granularity. DPP data may be organised at model, batch, or item level.

A balanced approach is needed. Item-level data may support repair, resale, and recycling use cases, but it can also increase costs and complexity. Model-level data is more aligned with current industry practice, while batch-level data may be important where product characteristics vary by production run.

Confidential Business Information

Some textile data can be commercially sensitive. Detailed supplier information, chemical details, or fibre-blend data may reveal business relationships or cost structures.

This is why role-based access rights are essential. Not every DPP data field should necessarily be visible to every user. Public authorities, consumers, recyclers, and business partners may need different levels of access.

What Textile Companies Should Do Now

Textile and apparel companies do not need to wait for every final technical detail before preparing. The first step is to understand current data maturity.

A practical readiness approach should include:

The companies that prepare early will be better positioned to respond to future delegated acts, customer requests, marketplace requirements, and market surveillance expectations.

Textile DPP Is a Data Governance Project

A successful textile DPP will require more than collecting information once. It will require an ongoing governance model that keeps data accurate, complete, and up to date.

Businesses should define:

• Who owns each data field
• Which supplier evidence is required
• How data is checked and approved
• When information must be updated
• How certificates and test reports are linked to products
• Which data is public, restricted, or authority-facing
• How product changes trigger reassessment

This is especially important for companies placing products on the EU market, because they may need to rely on upstream suppliers while still carrying responsibility for the final product information.

How ComplyMarket Can Support Textile DPP Readiness

ComplyMarket supports companies in managing product, material, supplier, ESG, and Digital Product Passport compliance requirements in a structured and scalable way.

For textile DPP preparation, ComplyMarket can help companies:

• Map product and supplier data against expected DPP information areas
• Centralise supplier declarations, certificates, and compliance documentation
• Manage substances and material compliance evidence
• Build audit-ready documentation workflows
• Connect product data with regulatory and sustainability requirements
• Identify data gaps before DPP obligations become operational
• Support supplier engagement and evidence collection
• Prepare for machine-readable, structured product compliance data

As textile DPP requirements develop, companies that already have clean data, clear responsibilities, and reliable supplier evidence will be in a stronger position. ComplyMarket helps turn scattered compliance information into a controlled, business-ready process for future DPP implementation.