Textiles Digital Product Passport: what the JRC study proposes for apparel data, granularity and access

Fashion brands waiting for the ESPR textiles rules now have the most detailed official signal so far of what a garment's Digital Product Passport will contain. On 13 May 2026 the Joint Research Centre's Product Bureau published the Study on DPP content for textile apparel products under ESPR, a JRC Science for Policy Report authored by M. González-Torres and A. Arcipowska. It is an external study prepared for the JRC, and it states that its contents do not necessarily reflect the position or opinion of the Commission.

It is not the delegated act. The Working Plan gives 2027 as the indicative adoption year for textiles. The study feeds the fourth and final milestone of the JRC preparatory study on textile products, covering policy scenarios and DPP elements, whose date has not yet been announced. The third milestone consultation closed on 30 March 2026.

Scope and structure

The study covers textile apparel. Its proposed content falls into four categories: product identification and classification, producer identification, product information (material, mechanical and chemical properties, environmental footprint, recycled and organic content, manuals and instructions) and compliance documentation. Voluntary entries would be allowed only if they do not duplicate regulated fields, and the study says they should be unrelated to sustainability unless defined in the preparatory study and incorporated into the delegated act, to prevent greenwashing.

For identification it leans on existing GS1 practice, all compliant with prEN 18219:

• Unique product identifier at item level, a serialised GTIN or equivalent. Readiness is rated very low because item-level identifiers are not common practice.
• Batch ID, a GTIN plus lot number. Readiness medium.
• Model ID, a GTIN-13. Readiness high.
• An ESPR product category (knitted, woven, denim) and a PEFCR category based on the Product Environmental Footprint Category Rules for apparel and footwear, plus the six-digit HS commodity code.

Granularity: item-level IDs, model-level disclosure

The study adopts working definitions. A model is a version of a product whose units share the same technical characteristics, pattern and construction, not necessarily distinguishing colour and size. A batch is a subset of a model produced in a specific plant at a specific time under the same conditions. An item is a single unit.

Its recommendation follows the approach set out by CIRPASS-2: assign item-level identifiers so every unit can be scanned, but populate the passport with batch- or model-level data at first and append item-specific data only when needed. Fibre composition, component specification and recyclability score are proposed at model level. Producer identification is proposed at batch level, because the manufacturing facility and the importer can differ within a model. Chemical properties are proposed at batch level as a minimum, covering a worst case across the colours in the batch. Mechanical test data could be requested at batch level under self-declaration, with model level considered if third-party certification is required.

Access rights: three tiers

The study proposes public access, authority-only access (notified bodies, market surveillance authorities, customs and the Commission) and legitimate-interest access, for example for recyclers. Identifiers, product categories, commodity code, operator name and address, facility identifier, fibre composition, component specification and the robustness score are proposed as public. Operator contact details are proposed as authority-only. Stakeholders told the JRC that fibre-property and chemical-usage data are treated as confidential business information because they reveal cost structures. The study's rule of thumb: what consumers see at the point of sale should be at model level, except for substances of concern.

What to do now

• Audit whether your model-level GTINs, lot numbering and facility identifiers can support the proposed identifier stack without a new coding scheme.
• Start mapping chemical and test data to batches, since that is where the study puts the minimum granularity.
• Treat the data list as directional. The delegated act sets the law, and the ESPR gives at least 18 months after adoption before requirements apply.

Primary sources: Study on DPP content for textile apparel products under ESPR; JRC Product Bureau, textile products project plan.