Textiles, with a focus on apparel, is a priority product group in the first ESPR Working Plan, so Indian exporters should start collecting supply-tier data now: material composition, recycled content, substances of concern, durability, repair and end-of-life. A machine readable data carrier such as a QR code follows, tracked against the indicative textile delegated act.
Why textiles sit near the front of the queue
Textiles, with a focus on apparel, is named a priority product group in the first ESPR and Energy Labelling Working Plan, Communication COM(2025) 187 final, adopted 16 April 2025 and covering 2025 to 2030, alongside furniture, tyres, mattresses, iron and steel and aluminium. Under the Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, a covered product may be placed on the EU market only once a Digital Product Passport is available (Article 9). Apparel is a leading India to EU trade flow, which places textile and apparel exporters among the groups most likely to face an early delegated act. India has no domestic DPP law; the obligation is the European Union’s and reaches goods placed on the EU market regardless of where they are manufactured.
Start supply-tier data collection now
The passport requirement flows upstream to suppliers, so early data collection is the decisive move. A DPP record holds the following, kept accurate, complete and up to date across the value chain:
| Data field | What apparel exporters assemble |
|---|---|
| Material composition | Fibre make-up of each product |
| Recycled content | Share of recycled input |
| Substances of concern | Restricted chemicals present |
| Durability | Expected product life |
| Repair | Repairability information |
| End of life | Recyclability and disposal route |
This data sits across multiple Indian supply tiers, from spinning and weaving to finishing, so tracing it takes the longest lead time. The same product level data also underpins a life cycle assessment and the carbon footprint of a product, so the effort compounds across export requirements. A structured DPP readiness guide sets out the full field list.
Ready a carrier and track the delegated act
Alongside the data, exporters secure unique product, operator and facility identifiers and prepare a machine readable data carrier such as a QR code, reached by scanning to reveal the record. The exact carrier type and standard are fixed by the delegated act for each product group, not by the framework, so a vendor-neutral approach avoids locking to one product early. The textile Working Plan year, around 2027, is indicative planning, not a legal deadline; the binding obligation starts only once the textile delegated act is adopted and applies, and as of June 2026 no product-specific ESPR delegated act had been adopted. Separately, the Commission must set up the central EU DPP registry by 19 July 2026. A DPP discovery brief and Digital Product Passport readiness sequence this data and carrier work against those dates.
Sources: Regulation (EU) 2024/1781 (ESPR) · COM(2025) 187 final ESPR Working Plan