🇮🇹🇩🇪🇫🇷🇪🇸🇵🇹🇳🇱🇵🇱🇸🇪🇩🇰🇫🇮🇨🇿🇷🇴🇭🇺🇬🇷🇧🇬🇭🇷🇸🇰🇸🇮🇪🇪🇱🇹🇱🇻🇮🇪🇲🇹🇸🇦🇨🇳🇯🇵🇰🇷🇮🇳🇹🇷🇻🇳🇮🇩
A falsifiable thesis to open with. Ask any vendor declaring “ESPR readiness” to list — with regulation numbers, study identifiers, mandate codes, committee references and delegated act drafts — every regulatory, scientific, technical and infrastructural stream their system must integrate to issue a single legally defensible Digital Product Passport. Demand at least twenty references. Most will give you three. Some will give you a brochure. A handful will give you a QR code.
That is the problem. And once you see the actual list, the size of the underlying market starts to make sense.
The textile DPP is not a feature. It is the convergence point of at least five EU regulations.
EU Regulation 2024/1781 — the Ecodesign for Sustainable Products Regulation (ESPR) — is the frame. Article 9 mandates the Digital Product Passport. Article 14 delegates product-specific requirements to secondary acts. Textiles sit in the first wave of expected delegated acts; the EU’s 2025–2030 Working Plan confirms textiles as a priority, with the delegated act expected in late 2026 / early 2027 and mandatory compliance no earlier than 2028.
But ESPR does not live alone. A DPP that withstands a real market surveillance inspection, the customs officer somewhere is Europe, the regional textile authority somewhere else in Europe, the national consumer protection agency in another European country again, requires at least five regulatory bodies to operate jointly, in convergence:
— ESPR itself, treated not as a document format but as an enforcement framework;
— ECGT — Directive (EU) 2024/825 on Empowering Consumers for the Green Transition — prohibiting unsubstantiated environmental claims and making durability disclosures legally consequential;
— PPWR — Regulation (EU) 2025/40 on Packaging and Packaging Waste, in force since February 2025, generally applicable from 12 August 2026 — because the product DPP must coordinate with the packaging DPP;
— EPR national schemes for textiles, where they exist, with France leading by almost two decades (more on this in the dedicated section below);
— eIDAS 2.0, as the legal basis for qualified credentials, qualified signatures and the European Business Wallet.
Five regulatory bodies, all live, none optional. A DPP that satisfies ESPR but violates ECGT is non-compliant. A DPP that satisfies ECGT but ignores PPWR for its packaging is non-compliant. A DPP that satisfies both but is hosted on infrastructure incompatible with eIDAS qualified credentials cannot be legally signed. Compliance is joint, not additive.
The science is not “documentation”. It is three published JRC milestone studies, a fourth one coming, and a parallel JRC cross-cutting DPP study.
The Commission does not legislate on the DPP from a blank page. The JRC Preparatory Study on Textiles is the evidence base on which the textile delegated act will be drafted.
The 1st Milestone was published in February 2024, defining scope, use cases and the consumer behaviour analysis. The 2nd Milestone followed at the end of 2024, addressing technological feasibility and DPP system architecture. The 3rd Milestone Technical Report on Textiles was presented by JRC on 14–15 January 2026 at workshops in Seville, and serves as the technical foundation for mandatory DPP requirements. The public stakeholder feedback period on the 3rd Milestone closed at the end of March 2026. The 4th and final milestone is forthcoming and will be the document the Commission will cite when it drafts the impact assessment and the delegated act.
Parallel to the textile-specific preparatory study, a cross-cutting JRC study on the DPP system itself defines the architectural options on which the standardisation work is built.
A vendor who cannot name which milestone covers their product category, and which milestone defines the DPP technical architecture they claim to comply with, is not selling a DPP. They are selling a slide deck.
I transmitted to the JRC Seville responsible for the textile preparatory study the Durability Index V2.0 dataset (DOI 10.5281/zenodo.20034567): 120 lab reports calibrated on 9 fabric tests plus ISO 6330 and ISO 15487 garment-level testing. The dataset is in the calibration base for the very parameter under discussion in the delegated act. That is the difference between reading a milestone and contributing to one.
The standards are not voluntary. They are the eight harmonised modules of Commission Implementing Decision C(2024)5423.
On 31 July 2024 the European Commission adopted Implementing Decision C(2024)5423 — a formal standardisation request to CEN, CENELEC and ETSI for the development of eight harmonised European standards in support of the Digital Product Passport. The request covers, by module:
Unique identifiers (product, operator, facility);
Data carriers and the link between the physical product and its digital representation;
Access rights management, information system security and business confidentiality;
Interoperability — technical, semantic and organisational;
Data processing, data exchange protocols and data formats;
Data storage, archiving and data persistence;
Data authentication, reliability and integrity;
Application Programming Interfaces (APIs) for product passport lifecycle management and searchability.
These are not eight nice-to-have specifications. They are the eight modules that, taken together, define what a “DPP system” technically is in EU law.
The work is allocated to CEN-CENELEC Joint Technical Committee 24, CEN-CLC/JTC 24 “Digital Product Passport Framework and System”, with multiple Working Groups responsible for the individual modules. The actual publication of the eight standards have a mandatory application phased from 2027 onwards.
Above this European layer, a new global layer has just appeared. ISO/IEC JTC 5 — the new Joint Technical Committee on Digital Product Passports — was announced on 20 April 2026 by DIN/DKE. It is positioned as the global standards venue underpinning ESPR and the Battery Regulation, with substantive deliverables expected from 2028.
European harmonised standards plus global ISO/IEC standards plus a Commission standardisation request: three concentric layers, all moving in parallel, all on different clocks. A vendor that cannot tell you which module of C(2024)5423 their product addresses, which CEN-CLC/JTC 24 Working Group they participate in, and how they intend to track ISO/IEC JTC 5 deliverables, is asking you to fund a research project, not buy a compliance system.
Semantics is not metadata. It is legal determinism — and it requires a common upstream standard at consortium level.
A DPP is read by a machine, by a market surveillance authority, and by a consumer. Three readers, three compatible semantics. Without a shared vocabulary, “100% recycled” means one thing for the brand, another for the GRS auditor, and a third for the customs officer who has thirty seconds to decide whether to clear the consignment.
The operational reference is UN/CEFACT UNTP, the UN Transparency Protocol. UNTP 0.7.0 is the version Reeco implements, defining the structures for Digital Product Passport, Digital Conformity Credential and Digital Identity Anchor. My contribute on the UN/CEFACT repository was merged in April 2026: 6/6 DPP tests and 16/16 DCC structural tests passing.
But UNTP alone is not enough. Cross-vendor semantic interoperability requires a common upstream standard at consortium level. This is the role played in the global supply-chain space by GS1 and, increasingly, by the Global Textile Standard (GTS) consortium, of which I am a partner. The reason a common consortium-level standard matters is not philosophical. Without it, every brand’s “recycled polyester” becomes a private dialect, and the customs API ends up trying to translate sixty thousand variants at runtime. It will not.
CIRPASS-2 contributes the complementary piece. The EU DPP Core Ontology requirements published by CIRPASS-2 in March 2025 are the de-facto interoperability reference for sector pilots in textiles, electronics, tyres and construction. The consortium itself is a Coordination and Support Action (not a certification body, not a standardisation body) and its outputs feed the recommendations process around the delegated acts.
A DPP without UNTP, without a consortium-level upstream standard, and without alignment to the CIRPASS-2 Core Ontology, is a PDF with a QR code on it.
Identity is not a login. It is LEI, qSign, DID with a resolver, EUBW, EU DPP Registry, and JTC governance — six dependencies, all distinct.
A DPP signed without a trust chain is not a DPP. It is a file with a signature image, which is not the same thing.
The minimum technical components for a legally binding emission:
LEI (Legal Entity Identifier, ISO 17442) for the issuing brand. Without an LEI, the brand has no globally resolvable legal identity to which the signature can be anchored. C(2024)5423 explicitly lists ISO 17442 among the standards CEN-CLC/JTC 24 must consider for Module 1 (unique identifiers);
eIDAS 2.0 as the legal framework for qualified electronic signatures and credentials, including the European Business Wallet (EUBW) as the enterprise custodian for trust services;
qSign — Qualified Electronic Signature — applied by the legal representative of the brand through an eIDAS-conformant Qualified Trust Service Provider. Not a digital signature image. Not an OAuth token. A qSign;
DID — Decentralized Identifiers (W3C recommendation) — for persistent identifiers of product, brand and verifier. Crucially, resolvable through an authoritative resolver, not through a single private vendor’s database. A DID that only your DPP provider can resolve is not a DID. It is vendor lock-in disguised as interoperability;
EU DPP Registry adherence: the central index where the unique identifier of each issued DPP must be registered for market surveillance authorities to locate it. The EU Central DPP Registry is scheduled to go live alongside ESPR full application on 19 July 2026;
Cryptographic suite at parity: Ed25519 for performance, ES256 for eIDAS compatibility, both Verification Methods exposed in the public DID document.
Above all of this sits the JTC governance layer: CEN-CLC/JTC 24 for the European harmonised standards under mandate M/595, and the new ISO/IEC JTC 5 for the global standards from 2028 onward. A harmonised standard generates presumption of conformity — meaning that brands which follow it are presumed to comply with ESPR. No harmonised standard, and every brand must individually prove its conformity in court if challenged. Much higher cost, much longer timelines, much larger legal exposure.
The vendor who cannot answer “which LEI, which resolver, which qSign provider, which EU DPP Registry endpoint, which JTC working group” is not selling a DPP system. They are selling a frontend.
Storage is not hosting. It is institutionally underwritten lifecycle persistence — and the only honest architecture involves third-party custodians.
Article 9.7 ESPR: the DPP must remain available for the lifetime of the product. A garment can live five to ten years; technical textiles longer. If the DPP vendor goes bankrupt in 2029, where does the passport of the garment sold in 2026 go?
Concrete question for the vendor: show me your retention architecture for the event of the bankruptcy of your own company. Not from the end of the contract. From the end of the legal entity.
The answer cannot be a clause in a B2B contract. A B2B contract is not a public enforcement mechanism.
The defensible answer requires retention finalised with institutional partners — eIDAS-qualified Trust Service Providers, accredited archival entities, or national legal deposit infrastructures — guaranteeing a minimum of ten years of retention, independent of the commercial life of the DPP vendor. Plus a guaranteed accessibility interface for European customs authorities. Plus a metadata copy endpoint for the central authorities — national competent authorities, the European Commission, statistical and surveillance bodies — that will, by law, request it. Plus formal adherence to the EU DPP Registry.
Four external dependencies for storage alone, none renegotiable: “Data storage, archiving and data persistence” : the persistence must hold even when the original economic operator is no longer active. The vendor that cannot show contracts, SLAs and legal arrangements with institutional retention partners is not solving the problem. They are postponing it onto someone else’s balance sheet.
GS1 is not a barcode. It is the physical-to-digital anchor, and it is now explicitly recognised under ESPR.
GS1 Digital Link is the relevant technical specification — combined with EPCIS for the traceability of supply chain events. GS1 Digital Link, with GTIN as the unique identifier and a QR code resolving via the GS1 resolver to the DPP record, is now explicitly recognised as a valid identifier pattern under ESPR — with serialized GTIN extending this to item-level identity for batteries and high-value goods. SGTIN, CPV and the broader GS1 identifier family are the bridge between the physical unit and its digital twin. Without a GS1-compliant, resolvable encoding, the DPP is not interoperable with retail and not interoperable with the modern distribution network.
The French dossier is two regimes, not one — and the convergence problem includes both.
A specific note on France, because it is the most instructive example of the convergence problem visible right now.
France has two distinct textile regimes, both legally active, both relevant to the DPP, and they are routinely conflated in industry discussion:
The EPR scheme for textiles, clothing, household linen and footwear, in place since 1 January 2007 under Article L541-10-3 of the French Environmental Code, modernised by the 2020 AGEC law and a new 2023–2028 cahier des charges. The scheme is operated by Refashion (formerly Eco-TLC), accredited by the French authorities.
The Coût Environnemental (formerly Eco-score), part of France’s affichage environnemental programme. Introduced under the AGEC law and formalised by the 2021 Climate and Resilience Law, with the calculation methodology established by Decree No. 2025-957 of 6 September 2025. Voluntary display from 1 October 2025; from October 2026, third parties may publish the Environmental Cost on behalf of brands that have not done so themselves. Calculation tool: Ecobalyse, the official French government calculator, with 16 environmental impact indicators.
Two regimes, two legal bases, two enforcement mechanisms. The EPR scheme is a producer responsibility framework with eco-modulated fees; the Coût Environnemental is a consumer-facing environmental display scheme. A DPP issued for the French market must coexist with both. A vendor that only references “the French Eco-score” has read half the file. A vendor that only references “French EPR” has read the other half. The convergence problem is exactly this: both must close.
Mass balance is not lot certification. It is per-unit reconciliation, and the math either closes or it is disclosed as not closing.
This is the technical jump that separates documentary traceability from operational verification.
A GRS Transaction Certificate certifies that 5.000 kg of recycled polyester entered the supply chain. ESPR Annex III requires a declaration per garment: this specific garment, of 180 grams, with what actual recycled content percentage? ESPR’s question is per-unit. Between them sits a mathematical gap.
Reeco’s patented per-unit mass balance reconciliation methodology closes that gap. The internal logic is not disclosed publicly. What is disclosed publicly is the behaviour at the boundary.
When the certified balance does not cover all the brand’s declared garments, the system informs the brand before emission. Worked example: 500 garments declared as 100% recycled; the certified balance covers 490 units. Reeco notifies. The brand decides. 490 garments receive a DPP with the certified claim; 10 garments receive a DPP with declared, non-certified composition. Market surveillance sees the full audit trail, cryptographically timestamped, with the boundary clearly recorded.
Reeco verifies and informs then the decision remains with the brand, who is the economic operator responsible under ESPR.
The math closes, or it is disclosed as not closing. There is no third option.
Repairability, durability, robustness are not adjectives. They are calibrated indices under ESPR Annex III.
ESPR Annex III lists the parameters the DPP must carry. For textiles, the list includes recycled content, recyclability, presence of hazardous substances, durability and repairability.
These are not adjectives. They are measurable, calibrated, deposited indices.
The Durability Index V2.0 (DOI 10.5281/zenodo.20034567) : 9 fabric tests (180 points) + a binary bursting gate + ISO 6330 and 15487 garment tests (20 points) = 200 points total — is an example of a methodology that is third-party replicable on a calibration base of 120 lab reports, and that has been transmitted to the JRC Sevilla unit handling the textile preparatory study. The parallel Repairability Index follows the same logic: physical tests, quantitative thresholds, a numeric result that holds up under audit.
Without deposited and calibrated indices, any durability claim is an ECGT violation waiting to happen. With deposited and calibrated indices, the brand has a defensible position under ESPR, ECGT and any future market surveillance challenge.
The work is impressive. The market is more so.
Let me sum the convergence problem.
Five regulatory bodies: ESPR (EU 2024/1781), ECGT (EU 2024/825), PPWR (EU 2025/40), national EPR schemes, eIDAS 2.0. Three published JRC milestone studies on textiles plus a fourth forthcoming, plus the parallel JRC cross-cutting DPP study.
One Commission standardisation reques, C(2024)5423, defining eight harmonised standard modules-
Two standards committees — CEN-CLC/JTC 24 at European level, the newly launched ISO/IEC JTC 5 at global level.
One open protocol with merged contribution — UNTP 0.7.0.
One CIRPASS-2 EU DPP Core Ontology, with two formal contributions of mine on file.
One consortium-level upstream semantic standard GTS-class.
One identity chain, LEI + qSign + DID with authoritative resolver + EUBW + EU DPP Registry going live 19 July 2026.
One physical-to-digital specification, GS1 Digital Link + EPCIS 2.0. One per-unit mass balance reconciliation methodology, patent-anchored and SIAE-deposited.
Two Annex III technical indices (durability and repairability) DOI-deposited and JRC-acknowledged.
One institutional retention architecture, ten-year minimum, with customs accessibility and central-authority metadata interfaces.
And, for the French market alone, two parallel national regimes: EPR since 2007 and Coût Environnemental since October 2025 that must coexist with the EU DPP.
Roughly twenty distinct dependencies, depending on how granularly you count them.
ll must close on the same date.
All must produce the same DPP. All must withstand the same customs inspection.
The work required to build a system that actually closes not a QR code declaring closure, not a slide deck declaring readiness, is non-trivial. It is in fact, the largest unaddressed regulatory infrastructure project in the European textile sector in the last twenty years.
The EU textile market is roughly 29 billion garments per year, serving over 500 million consumers. The downstream DPP infrastructure market; issuance, verification, lifecycle persistence, identity layer, mass balance reconciliation, deposited technical indices, institutional retention, registry integration, is sized between €2 and €4 billion over the next five years.
Twenty streams converge into one signed file. That file is the access point to a €2–4 billion market.
Those who have read the regulations will remain in the market.
Those who sold QR codes will exit.
Stefano Cipriani is founder of Reeco®, Expert Member of CIRPASS-2 (EWG1, EWG3), and a JRC Registered Stakeholder.
ORCID: 0009-0001-3423-9402