The first ESPR obligation lands before the passport.
The ESPR is a framework. It builds the machinery and leaves the rules for each product group to later acts. For apparel, though, one obligation already binds: large companies may no longer destroy unsold goods. The ecodesign requirements and the passport arrive later, with the textile act.
A framework, not a product rule
The ESPR does not say how long a jacket must last. It does not say how much recycled fibre a t-shirt must contain. What it does is list the kinds of requirement the Commission may impose, and set out the procedure for imposing them.
The list is broad: durability, repairability, recycled content, environmental footprint, substances of concern. The numbers, however, arrive one product group at a time, through delegated acts. If you look in the ESPR for the threshold that applies to your garment you will not find it, because it has not been written yet.
The obligation that already binds: unsold goods
From 19 July 2026 large companies may no longer destroy the unsold consumer products listed in Annex VII. Apparel, clothing accessories and footwear are on that list. Medium-sized companies come under the same ban from July 2030. Micro and small companies are exempt, and the exemption is permanent.
The ban is not absolute. A delegated regulation adopted on 9 February 2026 sets a closed list of exceptions. On the same day an implementing act standardised how destroyed quantities have to be disclosed.
For most companies the practical work is smaller than it sounds. The disclosure asks for a quantity per product category. A quantity requires knowing what was produced, what was sold and what was left over. That is inventory data rather than environmental data, and it usually exists already, somewhere between the ERP and the warehouse.
The scale of the problem is worth stating. According to the European Environment Agency, between 4 and 9% of the textile products placed on the European market are destroyed before anyone has used them.
What the textile act is expected to carry
The Commission's preparatory work is carried out by the Joint Research Centre. For apparel it has put four families of requirements on the table: how well a garment survives washing, how recyclable it is given its composition, how much recycled fibre it contains, and what footprint its manufacture leaves.
These are proposals inside a preparatory study. They are not adopted requirements, and they will change before they become law. No figure circulating today should be treated as a threshold you have to meet.
The scope of the study is also narrower than many summaries suggest. It covers apparel made of at least 80% textile fibres, workwear and sportswear included. Footwear is excluded and will follow a separate path, with a study expected at the end of 2027. A brand that makes both shoes and garments is therefore working to two calendars rather than one.
The European registry already exists
The Commission's DPP Registry has been operational since 20 July 2026. It is an index: it holds identifiers and metadata, not the passports themselves.
The first product groups are registering, and textiles are not among them. Two things are missing: the delegated act, and the semantic catalogue that describes textile data. For a fashion brand today the registry is not a filing obligation. It is the sign that the infrastructure has stopped being a plan.
What is worth putting in order while the delegated act is being written.
Know what goes unsold, by category
This is the figure the disclosure asks for, and in most companies it already exists, scattered between the ERP and the warehouse. Putting it into a stable form costs little now and a great deal later.
Composition fibre by fibre
Every requirement under discussion is computed from the real composition of the garment and its components, not from what the care label says. It is the field to make solid first, whatever threshold arrives.
Suppliers beyond the first tier
None of the expected requirements stop at the manufacturer. A brand that already has an open channel to tier two and tier three will, when the act arrives, be adding fields to a chain it knows, instead of setting out to find one.