The Ecodesign for Sustainable Products Regulation — ESPR, formally Regulation (EU) 2024/1781 — is the EU's most ambitious product legislation since the CE marking framework. Article 7 specifically mandates Digital Product Passports for product categories including textiles and apparel, expected to be mandatory for fashion from 2027. This is the regulation your brand needs to understand, deeply, before it becomes urgent.
What is ESPR?
ESPR replaces and significantly expands the 2009 Ecodesign Directive, which previously only applied to energy-related products. The new regulation extends ecodesign requirements to almost all physical products sold in the EU — including textiles, furniture, electronics, and chemicals. Its core principle is that products should be designed for durability, repairability, and recyclability from the outset, and that this must be verifiable through standardised digital data.
ESPR operates through a system of delegated acts — the Commission publishes product-specific requirements category by category. The textile and apparel delegated act is expected in 2025-2026, which will define the exact DPP data schema, verification requirements, and mandatory date for fashion brands.
What Article 7 specifically requires
Article 7 mandates that every product within ESPR's scope carries a Digital Product Passport — a machine-readable digital record that must be accessible via a data carrier (QR code, RFID, NFC, or barcode) permanently affixed to the product. The DPP must contain all data specified in the product group delegated act, be accessible without discrimination to consumers, economic operators, and market surveillance authorities, and remain accessible for the expected useful life of the product.
Who is responsible?
The manufacturer or importer placing the product on the EU market is responsible for creating and maintaining the DPP. Responsibility cannot be delegated to suppliers. Retailers must ensure products they sell carry valid DPPs from the mandatory date.
The delegated act process
ESPR works through delegated acts — secondary legislation that defines product-specific requirements. The textile delegated act will specify exactly which data fields are mandatory for garments, what evidence standards apply, what the exact compliance date is, and what the enforcement mechanism looks like. Brands should monitor the Commission's working plan closely and engage with industry associations providing consultation feedback.
Penalties for non-compliance
Products without valid DPPs after the mandatory date cannot legally be placed on the EU market. Market surveillance authorities have the power to order product recalls, impose fines, and restrict market access. The penalties are set at national level but ESPR requires member states to ensure they are "effective, proportionate and dissuasive" — which in practice means significant financial exposure for brands caught without compliant passports.