EU Digital Product Passport Is Coming: 5 Preparations for Workwear Exporters
If CBAM (the Carbon Border Adjustment Mechanism) governs "price," then the Digital Product Passport (DPP) that the EU is rolling out governs "eligibility"—without a passport, a product does not even get onto the field of the EU market. According to a September 2026 article in Tianjin Customs' "Guomen Times" and related public materials from China's Ministry of Commerce, the DPP, as the core tool of the Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781), is landing faster than many companies expect—and textiles are on the first priority list.
Companies exporting workwear and industrial uniforms should start preparing now. Based on public sources, this article summarizes the latest DPP progress and five things exporters can put in place ahead of time.
What the DPP Is: A "Digital ID Card" for Every Product
The DPP uses a data carrier (typically a one-item-one-code QR code) to record lifecycle information for each product: material composition, carbon footprint, recycled content, repairability, durability, and supply chain traceability. Consumers, regulators, and recyclers can scan the code and read data according to their access level.
Key milestones (cross-verified from multiple sources):
- July 18, 2024: ESPR entered into force; product-specific requirements are set by later delegated acts.
- July 20, 2026: The DPP central registry, together with its test environment, officially went live; the registration implementing act was published, and six of the eight harmonized standards—covering unique identifiers, interoperability, data carriers, APIs, and data exchange and storage—have been released.
- February 18, 2027: The battery passport becomes mandatory first.
- 2027: Delegated acts for textiles, aluminum, and tires are expected to follow (per Shandong Provincial Department of Commerce, the textile delegated act is expected in the second half of 2027, with mandatory application likely between 2028 and 2029).
- Note in particular: the unique registry identifier of imported products will be verified at EU customs—if the code fails, the goods do not clear.
What the Textile DPP Will Disclose
Combining MOFCOM's "DPP Technology Development Report" with analysis from industry consultancies (CIRS), the textile DPP will follow a three-phase, easy-to-hard rollout. The first, simplified phase is expected to cover:
- Basic description: brand, SKU, size, color, country of origin;
- Fiber composition: precise fiber ratios (e.g., 80% cotton, 20% polyester) including recycled content, aligned with Regulation (EU) No 1007/2011;
- Chemical management: disclosure of REACH substances of very high concern (SVHC) and PFAS.
Later phases will add carbon footprint, durability, and repairability data. One point with major implications for data management: the registry stores only identifiers and indexes, while business data is held and managed by the company itself—"data need not leave the factory," but full-chain data governance capability must keep up.
Five Things Exporters Can Do Now
- Build fiber composition and BOM data archives. Starting from fabric procurement, retain composition test reports and recycled-content certificates for every fabric batch. For EU-bound orders, composition data must be granular enough for item-level disclosure.
- Plan a one-item-one-code system. The DPP requires item-level identification and data carriers. Pilot hangtag QR codes on high-value product lines and link "code—SKU—batch—supply chain data," so the system can migrate once technical rules are finalized.
- Complete chemical compliance files. The REACH SVHC list updates dynamically and PFAS restrictions keep tightening. Agree on SVHC/PFAS declaration obligations with fabric suppliers, and use existing certifications such as OEKO-TEX as part of the compliance evidence chain (see our earlier analysis of the 2026 OEKO-TEX updates).
- Build a digital foundation for self-held data. Since DPP data is held by the company itself, businesses need the ability to store supply chain data long-term and share it by permission level. Even well-structured spreadsheets and cloud storage are a start—treat "data assets" seriously rather than hunting for records from zero later.
- Watch the 2027 textile delegated act. The act will define the specific disclosure fields and mandatory dates for textiles, likely with a transition period. List it as a compliance milestone and complete data integration for pilot categories one year ahead.
What It Means for Chinese Workwear Manufacturers
For workwear producers like Hengtong, the DPP, ESG audits, and the OEKO-TEX updates are three facets of the same transparency wave: European buyers are writing environmental and traceability requirements into procurement contracts, clause by clause. Early movers can convert compliance investment into brand credibility—when "proof by data" becomes the norm, a supplier that can produce a complete evidence chain is a differentiated one.
Hengtong holds ISO three-system certifications, OEKO-TEX Standard 100 certification, and an in-house testing laboratory, and completed its export qualification layout in 2026. We will keep tracking the textile DPP delegated act and provide compliance-ready workwear and suits for export clients. Real delivery records are in our case library, company introduction on the About page. Contact us to learn more.
