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Free Tool — DPP & ESPR Reference

DPP & ESPR Glossaryfor fashion brands

Every term, acronym, regulation, and deadline that fashion brands need to navigate the EU Digital Product Passport and Ecodesign for Sustainable Products Regulation — from supply chain tiers to chemical compliance, all in one place.

75+ terms defined12 categoriesMar 2026 last updated

75 terms

A
Annual Public Disclosure
RegulationEPR

Required under ESPR Art. 24. Affected businesses must publish annually on their website: the number and weight of unsold products discarded, reasons for discarding, the proportion sent to re-use vs. recycling vs. disposal, and measures taken and planned to prevent future destruction.

Disclosure is publicly enforceable and carries significant reputational risk — NGOs, journalists, and competitors can reference published figures.

Azo Dyes
Chemical

The largest class of synthetic dyes, accounting for 70%+ of all textile colourants. Most azo dyes are safe — but a specific subset can release carcinogenic aromatic amines through reductive cleavage on the skin. These restricted amines are listed in REACH Annex XVII Entry 43.

Limit: 30 mg/kg of restricted aromatic amines. OEKO-TEX Standard 100 and bluesign certification both cover azo dye compliance. Laboratory testing of dyed fabrics from new suppliers is standard practice.

B
Bluesign
CertificationChemical

Chemical management certification for fabric and finishing mills. Covers restricted substances, dye house wastewater and emissions, and chemical input safety. Provides process-based chemical assurance at Tier 2 of the supply chain (fabric mills, dye houses, finishers).

Recognised for chemical safety DPP data, particularly for ZDHC MRSL conformance and restricted substances compliance.

C
C0 DWRFluorine-free Durable Water Repellent
ChemicalEcodesign

PFAS-free alternatives to traditional DWR coatings, using wax-based, dendrimer, or silicone chemistries. Provides good water repellency for most fashion outerwear applications but with reduced wash durability compared to C8/C6 PFAS finishes.

The preferred route to PFAS elimination in finished garments. Brands transitioning to C0 DWR improve their ESPR recyclability scores, reduce EPR fees, and position ahead of the incoming REACH restriction on PFAS.

Carbon Footprint
MetricDPP

Measured in kg CO₂ equivalent across the product lifecycle using PEFCR methodology. Includes Scope 1 (direct), Scope 2 (energy), and Scope 3 (supply chain) emissions. A mandatory DPP data field for environmental footprint.

Fibre type is the dominant driver: wool and conventional cotton have significantly higher carbon footprints than recycled polyester or lyocell. PEFCR methodology ensures these figures are comparable across brands.

Care Label
Labelling

The physical label sewn into a garment currently showing fibre composition (under Regulation (EU) No 1007/2011), care symbols (EN ISO 3758), country of origin, and manufacturer identification.

From approximately 2028, care labels are expected to add a machine-readable QR code or NFC tag linking to the DPP. The exact specifications — including minimum QR code size, label durability requirements, and information hierarchy — will be confirmed in the textiles delegated act.

CN CodeCombined Nomenclature Code
LabellingRegulation

EU customs classification code used to determine which products fall within ESPR and EPR scope. In-scope textile categories include: Chapters 61–62 (apparel), 6301–6304 and 6309 (home textiles, second-hand), 6401–6405 (footwear), 4203 (leather apparel), 6504–6505 (headgear).

Required in DPP records for product identification. Brands should confirm CN code classification for all product types to understand their precise scope of obligation.

CEN/CLC/JTC 24
StandardDPP

The EU harmonised standards working group formalising technical specifications for Digital Product Passports — including JSON-LD data formats, data carrier specifications, and interoperability requirements. Standards developed by this body will be referenced in the textiles delegated act and will define the technical implementation of DPP systems.

D
Delegated Act
Regulation

Secondary legislation adopted by the European Commission under ESPR to set product-specific requirements. The textiles delegated act — expected in 2027 — will confirm exact DPP data fields, ecodesign threshold values, and care label specifications for fashion and apparel.

A minimum 18-month transition period must follow a delegated act's entry into force before compliance becomes mandatory. Brands selling into the EU should monitor the stakeholder consultation period in 2026–2027 to anticipate specific requirements.

Digital Product PassportDPP
DPP

A standardised, machine-readable digital record permanently linked to a physical textile product. Contains verified data on materials, manufacturing, environmental impact, certifications, and end-of-life options. Accessed via a QR code or NFC tag on the care label.

Under ESPR Art. 9(2)(i), the DPP must be maintained for at least the expected lifetime of the product. All textile products entering the EU market will require a compliant DPP from approximately mid-2028 (18 months after the textiles delegated act).

The DPP is both a compliance obligation and a commercial opportunity — enabling brands to surface verified sustainability credentials to consumers.

Data Carrier
DPPLabelling

A machine-readable medium — QR code, NFC tag, or similar — that links a physical product to its DPP record. Must be durable enough to remain scannable through the product's full lifecycle.

Technology-neutral under ESPR Art. 3(29): brands may choose QR code, NFC, or other approved formats. GS1 Digital Link URL structure is the expected implementation standard for QR-based carriers. Minimum recommended size is 15mm × 15mm (20mm+ preferred).

Data Escrow
DPP

ESPR Art. 11 requires that the DPP "shall remain available for the period specified in delegated acts adopted pursuant to Article 4, including after an insolvency, a liquidation or a cessation of activity in the Union of the economic operator responsible for its creation." This reflects the long lifecycle of textile products and the regulatory obligation that persists long after a garment is sold.

The specific technical mechanism — such as third-party hosting contracts or escrow arrangements — will be defined in the textiles delegated act. Brands building DPP infrastructure should plan for continuity provisions in their technology contracts.

Destruction Ban
RegulationDeadline

Under ESPR Art. 25, brands are prohibited from destroying unsold consumer products listed in Annex VII — which for textiles covers apparel (CN chapters 61, 62), leather clothing accessories (4203), headgear (6504–6505), and footwear (6401–6405). Home textiles (bed linen, towels) are not in Annex VII.

ESPR Art. 2 defines "destruction" as the intentional damaging or discarding of a product as waste, with the exception of discarding for the sole purpose of delivering the discarded product for preparing for reuse, including refurbishment or remanufacturing operations.

Timelines:

  • 19 Jul 2026 Large enterprises (250+ employees) — prohibition applies
  • 19 Jul 2030 Medium enterprises (50–249 employees) — prohibition applies
  • Micro and small enterprises (<50 employees) — currently exempt from Art. 25(1)

Routes that avoid "destruction": markdown and clearance sales, donation for re-use, sale to liquidators and resellers, refurbishment, delivery for preparing for reuse or remanufacturing.

Durability
Ecodesign

One of six ESPR ecodesign parameters. How long a garment maintains its performance under normal conditions of use — measured across pilling resistance, abrasion resistance, colour fastness, dimensional stability (shrinkage), and seam strength.

Key test standards: ISO 12947 (abrasion resistance, Martindale method), ISO 12945-2 (pilling resistance), ISO 5077 (dimensional stability / shrinkage), ISO 105 series (colour fastness). Higher durability scores reduce EPR fees and signal product quality to consumers.

Destruction Ban — Large Enterprises (19 Jul 2026)
DeadlineRegulation

The destruction ban under ESPR Art. 25 enters force for large enterprises (250+ employees). From this date, large fashion brands may not intentionally destroy or discard as waste unsold consumer textile products — including via incineration (even with energy recovery) or landfilling.

Annual public disclosure of any destruction also becomes mandatory from this date.

DPP Mandatory (expected mid-2028)
DeadlineDPP

DPP expected to become mandatory for all textile products entering the EU market, approximately 18 months after the textiles delegated act enters into force (assuming a 2027 adoption). Ecodesign compliance will also become mandatory at this point.

Destruction Ban — Medium Enterprises (19 Jul 2030)
DeadlineRegulationCompany Size

The destruction ban extends to medium enterprises (50–249 employees). Four years after the large enterprise deadline, the ban on destroying unsold textile products covers all businesses above the small enterprise threshold.

E
ESPREcodesign for Sustainable Products Regulation
RegulationDPPEcodesign

EU Regulation 2024/1781, entered into force July 2024. The framework law establishing mandatory ecodesign requirements and Digital Product Passports across product categories — including textiles.

ESPR creates six mandatory ecodesign parameters for products: durability, repairability, recyclability, recycled content, hazardous substance absence, and microplastic release. Product-specific requirements are set via delegated acts, with the textiles delegated act expected in 2027.

Regulation (EU) 2024/1781 of the European Parliament and of the Council

Empowering Consumers for the Green Transition Directive
RegulationLabellingDeadline

Directive (EU) 2024/825, applying from 27 Sep 2026. Prohibits vague environmental claims such as "eco-friendly," "sustainable," or "green" without specific, verified data backing them up. Bans offset-based carbon neutrality claims unless supported by actual emission reductions.

Introduces a harmonised durability label for commercial guarantees. Directly affects all marketing copy, product pages, and care labels carrying sustainability claims.

Directive (EU) 2024/825

EU Textile Labelling Regulation
RegulationLabelling

Regulation (EU) No 1007/2011. Mandates fibre composition labelling for all textile products sold in the EU, using harmonised fibre names from Annex I. Does not mandate care instructions or country of origin (governed by separate legislation).

DPP will expand these obligations significantly — adding machine-readable format requirements and verification standards for composition data.

Regulation (EU) No 1007/2011

EU DPP Registry
DPPDeadline

A central EU registry for unique product identifiers and DPP records, mandated by ESPR Article 13(1) to be established by 19 Jul 2026. All DPP systems must connect to this registry. It will serve as the authoritative index of compliant passports, accessible to market surveillance authorities and customs.

EPRExtended Producer Responsibility
EPR

A policy framework making brands financially responsible for the end-of-life management of the products they place on the market. Covers collection, sorting, re-use, and recycling infrastructure. Established for EU textiles by Directive 2025/1892 (WFD Amendment), with national EPR schemes operational by 17 Apr 2028.

Applies to all brands selling textiles in the EU — including non-EU brands selling via e-commerce. Microenterprises (fewer than 10 employees) are exempt until 17 April 2029.

EPR Fees
EPR

Financial contributions paid by brands to PROs, calculated based on the weight of products placed on each national market. Eco-modulated: products designed with greater durability, recyclability, recycled content, and absence of hazardous substances pay lower per-kilogram contributions.

Specific rates are set by national PROs and vary by Member State. The fee modulation mechanism creates a direct financial incentive for sustainable product design — brands that invest in compliance reduce ongoing EPR costs.

Environmental Footprint
MetricDPP

The overall environmental impact metric combining carbon, water, and other indicators calculated via PEFCR methodology. Required in DPP for all textile products. Enables consumer-facing comparison and informs EPR fee modulation decisions.

Standardised PEFCR calculation makes footprint data comparable across competing brands for the first time — a significant shift from the current landscape of inconsistent voluntary disclosures.

EPR Schemes Operational (17 Apr 2028)
DeadlineEPR

All EU Member States must have operational EPR schemes for textiles. Brands must be registered with a PRO in each Member State where they sell and begin paying EPR fees based on product weight placed on market. Microenterprises are exempt until 17 April 2029.

F
Fee Modulation
EPREcodesign

The mechanism by which EPR fees are adjusted based on a product's environmental performance, established in Directive 2025/1892 Art. 22c(5)(a). Higher sustainability scores on durability, recyclability, recycled content, and hazardous substance absence directly reduce per-kilogram EPR contributions.

This creates the most direct financial link between product design decisions and compliance costs — brands designing for end-of-life from the outset will consistently pay less than competitors using conventional materials and constructions.

Formaldehyde
Chemical

Used in wrinkle-resistant, easy-care, and anti-shrink finishes on cotton fabrics (particularly shirting). Restricted under REACH Annex XVII Entry 72: limit of 75 mg/kg for garments in direct skin contact, 300 mg/kg for non-skin-contact items.

Test results are required from finishing mills when sourcing easy-care or permanent press fabrics. Formaldehyde-free alternatives exist but may have reduced performance characteristics.

G
GOTSGlobal Organic Textile Standard
Certification

Provides physical chain-of-custody certification for organic fibres (cotton, wool, linen) from field through final manufacturing. Requires independent audits and covers both environmental and social criteria. Accepted for organic content DPP claims.

Note: BCI's (Better Cotton Initiative) mass-balance model does not meet DPP-grade origin verification — only GOTS and OCS provide the physical chain-of-custody required.

GRSGlobal Recycled Standard
Certification

Chain-of-custody certification for recycled content claims. Requires transaction certificates per production lot, distinguishing post-consumer (PCR) from post-industrial (PIR) recycled content. Required for any recycled content claims carried in a DPP.

GRS certification must be verified at Tier 3 (spinner/yarn) and sometimes Tier 2 (fabric mill) of the supply chain. Transaction certificates confirm each specific lot, not just facility eligibility.

Green Claims
LabellingRegulationDeadline

Environmental claims made about a product. From 27 Sep 2026, under the Empowering Consumers Directive (EU 2024/825), vague claims such as "eco-friendly," "sustainable," "green," "conscious," or "responsible" are prohibited without specific, verified data.

Offset-based carbon neutrality claims are banned unless supported by actual emission reductions (not purchases). Brands must audit all marketing copy, product pages, care labels, and social content to remove non-compliant claims before the September 2026 deadline.

GTINGlobal Trade Item Number
LabellingDPP

A globally unique product identifier — the number encoded in a barcode (EAN or UPC). The primary product identifier used in DPP records and GS1 Digital Link QR codes. Assigned at SKU level (each distinct product variant has its own GTIN).

Green Claims Law (27 Sep 2026)
DeadlineLabelling

Empowering Consumers Directive (EU 2024/825) applies. Vague environmental claims ("sustainable," "eco-friendly," "green," "conscious") become prohibited without specific, verified data. Offset-based neutrality claims are banned. Harmonised durability label required for commercial guarantees over 2 years.

H
Hazardous Substances
EcodesignChemical

One of six ESPR ecodesign parameters. The absence of substances that pose risks to human health, environmental health, or the recyclability of the product at end of life. ESPR works alongside REACH to create a layered chemical safety framework.

Key substances of concern: PFAS (impair recyclability), restricted azo dyes (human health), heavy metals, formaldehyde, antimicrobial finishes. Products with clean chemical profiles score higher on this parameter, reducing EPR fees and enabling stronger DPP credentials.

Heavy Metals
Chemical

Including chromium (chrome tanning in leather), lead (pigment dyes, certain hardware coatings), and cadmium (pigment dyes, hardware). Chrome VI (hexavalent chromium) is carcinogenic and must be present at under 3 mg/kg in tanned leather.

LWG-certified leather tanneries test for Chrome VI as standard. Metal hardware (zippers, buttons, rivets) requires heavy metal compliance declarations — particularly for products in direct, long-term skin contact.

Harmonised Durability Label
LabellingRegulationDeadline

A standardised visual label format for commercial guarantees of product durability. Required from 27 Sep 2026 under the Empowering Consumers Directive (EU 2024/825) when a brand offers a commercial guarantee of more than 2 years — at no additional cost — covering the entire product.

The European Commission was required to specify its exact design and content via implementing act by 27 September 2025. The label must also remind consumers of their legal guarantee of conformity (minimum 2 years under Directive 2019/771).

I
ISO Test Standards for Textiles
StandardEcodesign

Key ISO standards referenced in ESPR ecodesign parameters:

  • ISO 12947 — Abrasion resistance (Martindale method)
  • ISO 12945-2 — Pilling resistance
  • ISO 5077 — Dimensional stability / shrinkage
  • ISO 105 series — Colour fastness (to washing, rubbing, light)
  • ISO 4484 series — Microplastic release (Parts 1, 2, 3)
  • ISO 3758 — Care labelling symbols
  • ISO/IEC 15459 — Data carrier standards for product identification
J
JSON-LD
DPPStandard

A structured data format for machine-readable DPP records. Being formalised through the EU harmonised standards process (CEN/CLC/JTC 24). Enables DPP data to be processed by automated systems including market surveillance tools, customs, and third-party platforms.

L
LWGLeather Working Group
CertificationSupply ChainChemical

Certification for leather tannery environmental performance, covering chemical management, wastewater treatment, energy use, and emissions. Provides Gold, Silver, and Bronze levels. Required for DPP Tier 4 data for products containing leather.

Chrome VI (a carcinogenic compound) must be present at under 3 mg/kg in tanned leather; LWG certification covers this testing requirement.

LCALife Cycle Assessment
Metric

A methodology for quantifying environmental impacts across a product's full lifecycle — raw material extraction through manufacturing, use phase, and end-of-life. Under ESPR, LCA methodology is standardised via PEFCR for textiles, replacing the voluntary, non-comparable approaches brands have historically used.

Large Enterprise
Company SizeDeadline

250+ employees OR €50M+ annual turnover OR €43M+ balance sheet total. Destruction ban applies from 19 Jul 2026. All EPR obligations apply from 17 April 2028. Annual public disclosure of destroyed unsold goods applies immediately on the destruction ban date.

M
Market Surveillance
RegulationDPP

EU authorities responsible for verifying compliance with DPP, ecodesign, and labelling requirements. Market surveillance authorities will have access to full DPP data including dedicated customs/regulatory views. Non-compliant products can be blocked at customs entry or removed from the market post-sale.

Microplastic Release
EcodesignChemical

One of six ESPR ecodesign parameters. The rate at which synthetic textiles shed microplastic fibres during washing, wearing, and end-of-life processing. Measured using the ISO 4484 series (2023): Part 1 (material loss), Part 2 (qualitative and quantitative analysis), Part 3 (domestic washing measurement).

Design factors that reduce shedding: longer staple or continuous filament fibres, tighter yarn twist, woven constructions (vs. knit), heat-setting, calendering and enzyme washing finishes, laser cutting (seals fibre ends vs. mechanical cutting).

Mono-Material Construction
Ecodesign

A product construction using a single fibre type throughout — facing, lining, interlining, and trims all from the same fibre family. Significantly improves recyclability scores under ESPR because the product can enter a single fibre recycling stream without contamination from other materials.

Blended fibre constructions (e.g., 50% cotton / 50% polyester) are difficult to recycle via current fibre-to-fibre technology and receive lower recyclability assessments.

Medium Enterprise
Company SizeDeadline

50–249 employees. Destruction ban applies from 19 Jul 2030 — four years after the obligation begins for large enterprises. All other ESPR and EPR obligations apply on the standard timeline.

Microenterprise
Company Size

Defined as fewer than 10 employees AND annual turnover and balance sheet total at or below €2 million (EU SME Recommendation 2003/361/EC).

EPR: fully exempt from all obligations including registration until 17 Apr 2029. ESPR: no DPP exemption. Destruction ban: currently exempt (subject to review).

Size assessment is at group level — all linked enterprises combined. A 5-person brand that is part of a larger corporate group may not qualify as a microenterprise.

Microenterprise EPR Exemption End (17 Apr 2029)
DeadlineEPRCompany Size

The EPR exemption for microenterprises (fewer than 10 employees) expires. From this date, all brands — regardless of size — must register with a PRO and comply with full EPR obligations.

O
OCSOrganic Content Standard
Certification

Chain-of-custody certification for organic fibre content claims. Provides physical traceability but fewer social criteria than GOTS. Accepted for organic content DPP claims when physical chain-of-custody is maintained throughout supply chain.

OEKO-TEX Standard 100
CertificationChemical

Chemical compliance certification testing finished textile products for restricted substances: heavy metals, azo dyes releasing carcinogenic amines, formaldehyde, pesticides, and pH levels. Widely recognised for hazardous substance absence claims in DPP data.

Certification levels: Class I (products for babies under 36 months), Class II (skin contact), Class III (no direct skin contact), Class IV (decoration/furnishing). Class I represents the most stringent requirements.

P
Producer
EPR

Under EPR law, a "producer" is defined broadly. It includes:

  • Any brand that manufactures and sells textile products under its own brand name
  • Any brand that supplies products for the first time from another Member State or a third country
  • Any brand that resells textile products under its own label (even if another brand originally made the product)
  • Non-EU brands selling to EU consumers via distance/online sales

Critically: putting your own label on a product makes you the producer, regardless of who manufactured it.

PROProducer Responsibility Organisation
EPR

A collective compliance body that manages EPR obligations on behalf of member brands. PROs handle the physical and financial infrastructure: collection infrastructure, transport, sorting, re-use, and recycling operations. They manage reporting to national authorities and calculate per-brand contributions based on weight placed on market.

Brands typically join one PRO per Member State where they sell. PRO membership is the standard route to EPR compliance for all but the very largest brands.

Post-Consumer RecycledPCR
EcodesignSupply Chain

Recycled material derived from products that have been used by consumers and collected at end of life — e.g., recycled PET from used plastic bottles, or recycled polyester from collected garments. Valued more highly than post-industrial recycled content under ESPR and EPR fee modulation.

Textile-to-textile PCR (from collected garments) is the highest-value pathway. Bottle-to-textile PCR (rPET) counts but scores lower. Must be verified via GRS or RCS transaction certificates.

Post-Industrial RecycledPIR
EcodesignSupply Chain

Recycled material derived from manufacturing waste before it reaches a consumer — e.g., cutting floor offcuts, yarn waste, or defect fabric reprocessed into new fibre. Counts toward recycled content claims but is valued less than post-consumer recycled content under ESPR.

Must be certified via GRS or RCS. DPP requirements will make the PCR/PIR distinction transparent to consumers and regulators.

PFASPer- and Polyfluoroalkyl Substances
ChemicalEcodesign

A family of 10,000+ synthetic chemicals that do not break down in the environment ("forever chemicals"). In textiles, used as durable water repellent (DWR) coatings and soil-release finishes.

PFAS are problematic under ESPR for two reasons: (1) they impair fibre-to-fibre recyclability, reducing recyclability scores and increasing EPR fees, and (2) they are subject to a broad EU restriction currently progressing through REACH.

The C0 DWR (fluorine-free) alternatives provide adequate water repellency for most fashion applications, though with lower wash durability than traditional PFAS finishes. Transitioning to C0 DWR before the REACH restriction takes effect is advisable.

PEFCRProduct Environmental Footprint Category Rules
Metric

Standardised EU methodology for life cycle assessment of textile products. Specifically: Product Environmental Footprint Category Rules for Apparel and Footwear. Ensures comparability of environmental footprint data across brands — a single, mandatory calculation methodology replaces voluntary LCA practices.

PEFCR-compliant environmental footprint data covers carbon footprint (kg CO₂ equivalent), water consumption (litres), and other impact categories. Required in DPP for all in-scope textile products.

R
REACHRegistration, Evaluation, Authorisation and Restriction of Chemicals
RegulationChemical

Regulation (EC) No 1907/2006. Regulates the presence of hazardous chemicals in products placed on the EU market. Requires disclosure of Substances of Very High Concern (SVHCs) present above 0.1% by weight in articles.

Works alongside ESPR to create a layered chemical safety framework. A broad EU restriction on PFAS is progressing through REACH — ESPR will additionally penalise PFAS-containing products via lower recyclability scores.

Regulation (EC) No 1907/2006

Repairability
Ecodesign

One of six ESPR ecodesign parameters. How easily a product can be repaired to extend its useful life. Factors include spare parts availability, modular construction, seam accessibility (lockstitch is easier to repair than chainstitch), replaceable hardware, and availability of repair documentation or guides.

DPP will carry repairability indicators and spare parts information. Brands that provide digital repair guides, sell spare buttons/zippers, and design for seam accessibility will score higher.

Recyclability
Ecodesign

One of six ESPR ecodesign parameters. How effectively a product can be returned to useful materials at end of life — specifically fibre-to-fibre recyclability, which is the priority pathway under ESPR.

Key design factors improving recyclability: mono-material construction (single fibre type), detachable trims and hardware, absence of PFAS coatings, avoidance of blended fibre constructions that contaminate recycling streams. DPP must carry recyclability classification and disassembly instructions for recyclers.

Recycled Content
EcodesignCertification

One of six ESPR ecodesign parameters. The percentage of certified recycled fibres in a product by weight. Post-consumer recycled (PCR) content is valued more highly than post-industrial (PIR) content. Textile-to-textile recycling is prioritised over bottle-to-textile (rPET from plastic bottles).

Must be verified via GRS (Global Recycled Standard) or RCS (Recycled Claim Standard) chain-of-custody certificates at transaction level. Higher recycled content reduces EPR fees and strengthens green marketing claims.

RCSRecycled Claim Standard
Certification

An alternative to GRS for recycled content verification. Provides chain-of-custody and transaction-level traceability but with fewer social criteria than GRS. Both GRS and RCS are accepted for recycled content DPP claims.

RDSResponsible Down Standard
CertificationSupply Chain

Certification for down and feather traceability and animal welfare. Covers supply chain integrity from farm through final product. Required for DPP Tier 4 data for down-filled products. Verifies no live-plucking or force-feeding of geese and ducks.

RWSResponsible Wool Standard
CertificationSupply Chain

Certification for wool sustainability and animal welfare, specifically covering non-mulesed status and land management. Required for DPP Tier 4 (raw material origin) data for wool-containing products. Provides the traceability chain needed for verified origin claims.

S
Stakeholder Consultation
Regulation

A public engagement process during 2026–2027 where the European Commission invites industry, brands, NGOs, and member states to provide feedback on proposed delegated act requirements — including proposed DPP data fields, ecodesign threshold values, and test methodologies.

Brands and industry associations that participate in stakeholder consultation can influence the final requirements and receive early insight into upcoming obligations.

SKUStock Keeping Unit
DPP

An individual product variant — typically each combination of style, colour, and size that carries a distinct GTIN. The DPP granularity level (per SKU, per batch, or per item) will be confirmed in the textiles delegated act.

General expectation: one DPP per unique product model where regulated data (composition, certifications, environmental footprint) differs. Different sizes of the same colourway may share a DPP; different colourways requiring different dye processes will typically need separate DPPs.

SVHCSubstances of Very High Concern
ChemicalDPP

Chemicals meeting criteria under REACH Article 57: carcinogenic, mutagenic, or reproductive toxic (CMR); persistent, bioaccumulative, and toxic (PBT); very persistent and very bioaccumulative (vPvB); or endocrine-disrupting substances.

Must be disclosed in the DPP if present above 0.1% by weight — mirroring the existing REACH SVHC disclosure obligation. Examples include certain azo dyes, hexavalent chromium, PFAS, phthalates, and formaldehyde precursors.

Small Enterprise
Company Size

10–49 employees. Per EU SME Recommendation 2003/361/EC. ESPR: exempt from the destruction ban (currently). DPP: no exemption applies. EPR: all obligations apply from 17 April 2028.

T
Tier 1: Assembly
Supply Chain

The facility where the finished product is assembled — cut, sewn, embroidered, washed, finished, and QC'd before shipping. May include subcontractors for specific operations.

Most fashion brands have their strongest relationships and best visibility at Tier 1. DPP data requirements at this level: facility name and location, social compliance certifications, environmental certifications, and any subcontractor disclosures.

Tier 2: Fabric Mills, Dye Houses & Finishers
Supply ChainChemical

The facilities performing weaving, knitting, dyeing, and finishing operations — which may be separate facilities or combined. This tier holds the most critical DPP data and typically represents the largest visibility gap for fashion brands.

Key data required: yarn specifications (fibre type, blend percentages, yarn count), dyestuff category (reactive, disperse, direct, vat, acid), finishing treatments (waterproofing type, softener, sanforizing), chemical management certifications (ZDHC MRSL conformance, bluesign, OEKO-TEX).

Tier 3: Yarn & Spinning
Supply ChainCertification

The spinner and yarn producer. Key data required: spinner identity and location, fibre origin country, and — critically for recycled or organic content claims — chain-of-custody certificates.

For recycled fibres: GRS or RCS chain-of-custody certificates and transaction certificates per production lot. For organic fibres: GOTS or OCS scope certificates. Tier 3 is where most recycled and organic content claims must be verified.

Tier 4: Raw Material Origin
Supply ChainCertification

The raw material source — cotton farm, wool farm, leather tannery, down supplier, or synthetic polymer producer. The most challenging tier to access and verify.

Certification requirements by fibre type:

  • Wool: RWS (Responsible Wool Standard), non-mulesed declaration
  • Down/feather: RDS (Responsible Down Standard)
  • Leather: LWG certification
  • Organic cotton: GOTS or OCS (BCI mass-balance does NOT qualify)
  • Recycled synthetics: GRS or RCS with transaction certificates
Transaction Certificate
Supply ChainCertification

A per-shipment certificate issued within a chain-of-custody framework (GRS, RCS, GOTS, OCS) confirming that a specific production lot contains the certified materials claimed. Distinct from the scope certificate (which confirms a facility is eligible to produce certified goods).

Transaction certificates are the highest-risk data point for recycled content claims. Brands must obtain and verify TCs for each production lot, not just rely on a supplier's scope certificate status.

Textiles Delegated Act (expected 2027)
DeadlineDPP

The textiles delegated act under ESPR is expected to be adopted in 2027, following stakeholder consultation in 2026–2027. This will confirm exact DPP data fields, ecodesign threshold values, and care label specifications. An 18-month transition period follows before compliance becomes mandatory.

W
WFD AmendmentWaste Framework Directive Amendment
RegulationEPR

Directive (EU) 2025/1892, amending Directive 2008/98/EC. Establishes Extended Producer Responsibility (EPR) for textiles across the EU with mandatory fee modulation based on product sustainability performance. Requires national EPR schemes to be operational by 17 Apr 2028.

Directive (EU) 2025/1892 amending Directive 2008/98/EC

Water Consumption
MetricDPP

Measured in litres per garment, calculated across the full product lifecycle using PEFCR methodology. Included as a mandatory DPP environmental footprint data field. Varies significantly by fibre type (conventional cotton is the highest consumer), production location, and finishing processes.

Z
ZDHC MRSLZero Discharge of Hazardous Chemicals Manufacturing Restricted Substances List
CertificationChemical

A shared industry chemical management standard listing prohibited and restricted chemicals for fabric and finishing mills. ZDHC Gateway reports provide verified conformance data from certified laboratories.

Key Tier 2 verification mechanism. Bluesign-certified mills are typically ZDHC MRSL conformant. ZDHC conformance is one of the strongest evidence bases for chemical safety DPP claims.

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