- within Antitrust/Competition Law, Technology and Insurance topic(s)
February 2026 – Fashion and luxury brands selling into the EU should prepare for a regulatory shift that will directly affect how products are documented, traced and placed on the market.
Regulatory work is now intensifying on implementing measures, including the rollout of Digital Product Passports (DPPs). DPPs are becoming a central instrument in the EU's strategy to advance circularity, transparency and sustainability.
For the fashion industry, DPPs represent not only a compliance obligation, but a shift in how product data and supply chains are managed.
DPPs as a new regulatory standard
A Digital Product Passport will function as a product's digital identity, containing information on origin, material composition, environmental impact, repairability and certifications.
Unlike traditional ESG reporting obligations, DPPs are directly linked to market-access requirements. In practical terms: a product without a compliant DPP may not be legally sold in the EU.
This shifts DPPs from the realm of soft ESG commitments into hard market-access regulation.
Timeline: Uncertainty in details, not in direction
Textiles and apparel are among the priority product groups under the ESPR Working Plan for 2025–2030.
Current regulatory indications suggest:
- the delegated act for textiles is expected by late 2027,
- an approximately 18-month compliance period is anticipated,
- draft rules are likely to be published in advance through consultation processes,
- a central EU registry of product identifiers is planned for June 2026.
Importantly, 2027 does not automatically mark the start of enforcement. Enforcement timelines will be determined closer to adoption.
Regulatory uncertainty therefore concerns timing and technical standards — not the existence of the obligation itself.
Political context and the question of delays
Recent adjustments and delays affecting certain ESG regulations (such as CSRD and CSDDD) have led some market participants to speculate whether DPP requirements might also be softened.
At present, however, there is no indication of a material rollback. DPPs remain a key pillar of the EU's circular economy policy.
Relying on regulatory retreat would therefore be a high-risk strategy.
Implementation as a transformation project
Early implementation experience shows that DPPs are primarily a data governance and supply chain transformation project with a technological component — rather than a purely IT exercise.
Key challenges include:
- data availability and reliability,
- standardisation across systems,
- supplier engagement,
- cross-functional internal coordination.
For brands operating complex outsourcing models, this may represent a multi-year transformation.
In the near term, brands should prioritise strengthening their product data governance, engaging supply chain partners and assessing technological solutions that can support future DPP requirements. Early preparation will be important, as implementation will require cross-functional coordination and reliable product-level data. While compliance is the immediate driver, companies that integrate DPPs into broader commercial and lifecycle strategies may also unlock longer-term business value.
Key legal takeaway
Unlike ESG reporting, DPP compliance is directly tied to market access.
Non-compliance may ultimately mean exclusion from the EU market.
This places DPPs firmly within core regulatory risk management.
Conclusion
Companies have time to act — but not time to delay.
While technical standards are still evolving, the regulatory direction is clear. Businesses that begin building data and process foundations now will be better positioned to adapt to final requirements.
Those waiting for absolute legal certainty may face significant time pressure and competitive disadvantage.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
