For brand directors, sustainability leaders and operations managers. The apparent 2026–2027 ‘cliff’ is not one deadline. It combines an ESPR rule on destroying certain unsold consumer products, an indicative 2027 target for adopting textile ecodesign measures, and a mandatory battery-passport date of 18 February 2027.
Regulatory status and timeline
The ESPR creates the framework for product-specific ecodesign and DPP requirements. Its restrictions and disclosure rules for unsold consumer products are a separate workstream from the future textile delegated act. In the 2025–2030 Working Plan, 2027 is an indicative adoption target for textiles/apparel—not an automatically enforceable textile-passport date. By contrast, Article 77 of the Battery Regulation states that each LMT battery, industrial battery above 2 kWh and EV battery must have an electronic battery passport from 18 February 2027.
Products and operators affected
Fashion brands, manufacturers, importers and retailers should map unsold-goods and future textile-data responsibilities separately. Battery manufacturers and economic operators placing covered LMT, industrial and EV batteries on the EU market need a 2027 implementation programme now.
Required data and preparation data
Required or anchored in adopted legislation: For covered batteries, Annex XIII and Article 77 anchor model- and item-specific passport information, identifiers, performance, durability, composition and lifecycle data. Textile DPP fields remain subject to the future delegated act; do not label a preparatory data list as final legal content.
Recommended preparation while detailed rules develop: For apparel, structure fibre composition, material origin, chemicals, manufacturing sites, durability, care, repair and end-of-life information. For batteries, close gaps in unique identification, chemistry, carbon-footprint evidence, responsible sourcing, state of health and event history.
A four-step readiness checklist
- Audit product families, operator roles and the source systems that hold evidence.
- Structure material and supplier data with owners, units, provenance and update rules.
- Select an interoperable platform that can separate public, partner and authority access.
- Pilot one product line and test identifier, carrier, update and retention workflows.
Where DigiPP fits
DigiPP can help organise source data into governed product records, connect identifiers to digital views and publish different information for different audiences. The legal decision about which fields apply remains with the responsible economic operator and its advisers.
Official sources
Regulatory disclaimer. This article is general information, not legal advice. Requirements, guidance and implementation measures may change. Confirm the current legal text, product scope, operator role and transition rules for your products.