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

The proposed DPP content is structured around four main categories. These categories can help companies start mapping what data they already have and what gaps they need to close.

1- Product Identification and Classification

A textile DPP must enable the product to be identified clearly and consistently. The study highlights data points such as:

• Unique product identifier
• Model ID
• Batch or lot ID
• Product category
• Commodity code, such as HS or TARIC where relevant

The study indicates that model-level identification is already common in industry, while item-level identification is less mature and may create additional operational complexity.

2- Producer and Operator Identification

The DPP is also expected to identify the economic operators responsible for the product. This may include:

• Manufacturer identity
• Manufacturer address and contact details
• Importer identity, where applicable
• Facility identifiers, where relevant
• Other responsible operator information, where required under EU law

This is important because the DPP must support accountability. Under ESPR, the main responsibility generally lies with the manufacturer or, where the manufacturer is not established in the EU, the importer.

3- Product Information

For textile apparel, product information may cover material, performance, chemical, care, and circularity-related information. The study discusses data points such as:

• Fibre composition
• Product mass
• Care instructions
• Robustness-related information
• Recycled content
• Organic content
• Recyclability-related information
• Environmental footprint information
• Substances of concern, where relevant and proportionate

This area is particularly important because much of the required data may come from upstream suppliers. Many companies already collect some of this information, but it is often stored in PDFs, spreadsheets, certificates, emails, or disconnected systems.

4- Compliance Documentation

The DPP may also act as a digital access point for compliance documentation. This can include:

• EU Declaration of Conformity
• Technical documentation
• Test reports
• Certificates
• Information required under other applicable EU legislation

For businesses, this means DPP preparation should be linked to documentation control, supplier evidence management, and audit-ready compliance workflows.

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.

Conclusion

The proposed textile DPP framework under ESPR shows where apparel compliance is heading: more transparency, more structured product data, stronger traceability, and clearer accountability.

For textile companies, the challenge is not only regulatory. It is operational. The businesses that can collect, verify, structure, and maintain reliable product data will be better prepared for the next phase of EU sustainability and product compliance.