Digital Product Passport for Textile Exporters to the EU

The ESPR obligation attaches to the product entering the EU market — not the seller's location. If you export textiles to Europe from Australia, the UK, the US, or anywhere else, this applies to you.

The obligation follows the product, not the seller

The EU Ecodesign for Sustainable Products Regulation (ESPR) requires that products placed on the EU market carry a Digital Product Passport. The obligation falls on the economic operator responsible for placing the product on the market.

For non-EU brands, this means:

  • If you sell directly to EU consumers (DTC, your own e-commerce store), you are the importer and must provide the DPP.
  • If you sell via an EU-based distributor or retailer, they may require you to provide DPP data as a condition of doing business.
  • If you use EU marketplaces, the marketplace may require DPP data for product listings.

In all cases, the practical requirement is the same: you need structured data about your products in a format that the EU system can consume.

What this means for your country

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Australian textile exporters

Australia has a significant textile export relationship with Europe. Australian fashion brands — particularly in sustainable and premium segments — sell to EU consumers via their own e-commerce stores, European stockists, and marketplaces.

Key considerations:

  • As a non-EU manufacturer, you'll need to appoint an EU authorised representative or work with an EU-based importer who takes on the compliance obligation.
  • GS1 Australia is the national GS1 member organisation. If you have GS1 barcodes, your GTINs are already GS1-compliant for Digital Link URIs.
  • Passportly lets you specify your EU authorised representative details in your organisation profile — these appear automatically on every DPP.
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UK brands post-Brexit

Since Brexit, UK brands are third-country exporters to the EU. The ESPR applies to you the same way it applies to any non-EU brand. If your products are sold on the EU market, they need DPPs.

Key considerations:

  • You need an EU authorised representative to place products on the EU market under ESPR. This is similar to the existing requirement for CE marking.
  • Many UK brands already have EU distribution through Ireland or the Netherlands. Your existing EU partner may take on the authorised representative role.
  • The UK may develop its own product passport requirements. Data entered on Passportly will be transferable if/when UK regulations emerge.
  • France is a major export market for UK fashion — the French Eco-Score deadline (October 2026) is your most immediate concern.
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US brands selling in Europe

American DTC brands with European customers face the same ESPR obligations as any non-EU seller. If you ship directly to EU consumers or sell through EU retailers, DPPs apply to your products.

Key considerations:

  • DTC brands shipping to Europe from US warehouses are acting as importers — you need either an EU authorised representative or an EU-based fulfilment partner who takes on the compliance role.
  • US brands selling through EU-based retailers may find their retail partners requiring DPP data as a B2B condition before the regulation technically mandates it.
  • The EU market is increasingly demanding supply chain transparency. Having DPP-ready data gives you a competitive advantage with EU buyers even before deadlines hit.
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Turkish manufacturers

Turkey is one of Europe's largest textile suppliers. Turkish manufacturers producing for EU brands and retailers will increasingly be asked to provide upstream DPP data.

Key considerations:

  • While the DPP obligation falls on the entity placing the product on the EU market (typically the EU brand or importer), EU brands will need your manufacturing data to complete their DPPs.
  • Proactive Turkish manufacturers who can provide structured DPP data will have a competitive advantage — your EU customers will prefer suppliers who make compliance easy.
  • Passportly's Connector API lets you share product data with your EU customers in the format their DPP systems expect.

About EU authorised representatives

Non-EU brands placing products directly on the EU market typically need an EU authorised representative — a person or entity established in the EU who acts on your behalf for regulatory compliance.

Passportly handles this in your organisation settings. When you set your EU market role to "manufacturer" (non-EU) and provide your authorised representative's details, that information appears automatically on every DPP you create. Your JSON-LD output includes the representative's data as required by ESPR Article 9(5).

If you sell through an EU-based importer or distributor, they may act as the responsible economic operator instead. Passportly supports all three ESPR roles: manufacturer, importer, and authorised representative.

Get your products EU-ready

Start free with 3 products. Enter your product data, set up your EU authorised representative, and generate compliant DPPs with QR codes.

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