Digital Product Passport Compliance: Why Non-EU Fashion Brands Need an EU-Based Representative
Selling Clothes in the EU? The EU’s Digital Product Passport is coming, and if you manufacture garments outside the European Union, you will need an EU-based entity to manage your compliance. Here’s what that means and what you should be doing about it now.
Why the DPP requires an EU presence
The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, came into effect on 18 July 2024. It requires a Digital Product Passport (DPP) for textiles, with the textiles delegated act expected late 2026 / early 2027 and compliance applying from approximately mid-2028.
In simple terms, the DPP means that every garment sold in the EU must be connected through a QR code, NFC tag, or RFID chip to a digital record. This record will include information about the product’s materials, supply chain, sustainability features, and how it should be handled at the end of its life.
Here is an important point many non-EU brands overlook. The ESPR puts the responsibility for compliance on a company based in the EU. If you manufacture in Asia, the US, or outside the EU, you may not automatically have a company that can take on this role.
What the regulation says:
Under ESPR Article 8, where a product is manufactured outside the Union and placed on the EU market, the importer assumes the obligations of the manufacturer with regard to compliance with ESPR requirements, including those related to the DPP. Where an authorised representative has been designated, that representative may perform specific tasks on behalf of the manufacturer within the limits of the mandate conferred.
In other words, you need to have a presence in the EU. This can be handled either by your importer taking on the responsibility, or by appointing an Authorised Representative (AR) to act for you.
What does an Authorised Representative do under the DPP?
Under the ESPR, an Authorised Representative performs specific, mandated tasks on behalf of the manufacturer. For DPP compliance, this is much more than just a name on a form. It is an active, ongoing data management role.
This is not a one-time filing. The DPP is a living record that must be maintained, updated, and accessible at all times. Market surveillance authorities have full access and can order product withdrawal for non-compliance.
Why this is especially urgent for non-EU manufacturers
If you sell garments into the EU through distributors or retailers, you might assume the compliance burden falls on them. It does not, at least not in full.
Distributors and retailers are only required to check that a DPP is in place before putting a product on the shelf. They are not responsible for creating it, maintaining it, or ensuring its accuracy. That responsibility goes back to the manufacturer, or if there is no EU-based manufacturer, to the designated Authorised Representative.
What happens if you don’t comply with the DPP?
The ESPR requires each EU country to set penalties that are effective, fair, and strong enough to discourage violations. Authorities can remove products from the EU market if they do not comply.
A study by the European Parliamentary Research Service (EPRS) suggests that penalties could include fines between €10,000 and €100,000 per violation, and up to 5% of annual turnover for repeated or widespread non-compliance. Higher penalties may also apply if data is falsified, although each country will define its own exact rules.
For brands outside the EU, the risk is straightforward. If you do not appoint an Authorised Representative, there is no one in the EU responsible for your Digital Product Passport. As a result, your products could be removed from the market.
How the Authorised Representative role under the DPP connects to what Euverify already does
If you are already working with Euverify for GPSR compliance, you may already be close to meeting DPP requirements. The Authorised Representative role under the DPP is set up in much the same way as the role Euverify already provides under the General Product Safety Regulation.
This means the same compliance setup can be used:
- GPSR product safety data management → DPP product data management
- GDPR data protection frameworks → DPP data security and privacy (DPP systems must comply with GDPR for any personal data they contain)
- Cosmetics compliance documentation → Chemical compliance and substances of concern tracking (REACH/SVHC)
- EU AR network → DPP responsible actor role
Euverify supports you through the entire DPP compliance process. This includes identifying compliance gaps, coordinating data collection across your supply chain, managing and organising DPP data, and acting as your EU Authorised Representative throughout the product lifecycle.
What should non-EU brands be doing right now?
The textiles delegated act is expected late 2026 / early 2027, with compliance applying from approximately mid-2028, meaning brands that begin preparing now have a realistic window to get ahead of the requirement without the scramble of a last-minute rush.
Step 1 — Map your current data availability
Industry protocols developed for textile DPP pilots suggest up to 125 data points may be relevant. This includes details such as where raw materials come from, fibre composition, where the product is made, any chemicals used, carbon footprint, durability, and how the product should be handled at the end of its life.
Most brands do not have all this information yet. The sooner you identify what is missing, the more time you have to work with your supply chain partners to gather it.
Step 2 — Designate your Authorised Representative
Do not assume your importer will take on this role. If they do, they may be treated like the manufacturer and take on significant legal responsibility for your product’s compliance. This may not be what you or your importer expect.
Appointing a dedicated Authorised Representative gives you more control, clear responsibility, and a partner focused on your compliance needs.
Step 3 — Build your compliance stack
DPP compliance does not stand on its own. It connects with other rules such as GPSR, REACH, the Green Claims Directive, CSDDD, and EPR requirements.
Brands that treat it as part of a wider compliance effort, rather than a separate project, will be in a much stronger position.
Key takeaway
The Digital Product Passport is a major change in how textile brands share product information. For manufacturers outside the EU, it brings a clear requirement. You must have a qualified Authorised Representative based in the EU to manage your DPP compliance.
Brands that see this as a chance to improve supply chain transparency, strengthen access to the EU market, and stand out with verified sustainability claims will be better prepared than those who leave it until the last minute.
Euverify can support you through this process. It combines existing EU compliance systems with DPP expertise to help make compliance easier for brands of all sizes.Ready to get your DPP compliance in order? Get in touch with Euverify today.
Frequently Asked Questions
It applies to all non-EU brands selling textiles in the EU, regardless of size. That said, smaller brands may benefit from simplified requirements, such as covering fewer data categories and lighter audit cycles. The exact thresholds will be confirmed in the textiles delegated act, but no brand should assume they are exempt based on size alone.
Yes. One AR can manage DPP compliance across all your product lines under a single written mandate. This makes it far more practical than relying on separate importers in different markets to handle it product by product.
Not automatically. A GPSR AR handles product safety documentation. An AR whose mandate includes DPP obligations takes on a broader, ongoing role: compiling passport data, registering it with the EU registry, and keeping it accurate throughout the product’s life. If you have an existing AR relationship, check explicitly whether your mandate covers DPP obligations.
The passport must always reflect the actual product on the market. If your manufacturer, materials or production location changes, the DPP needs to be updated. This is why the AR role is ongoing. Someone needs to manage those changes as they happen, not just at the point of setup.
Only products placed on the market from the compliance deadline onwards, currently expected around mid-2028, need a DPP. Existing stock already in market is not affected retroactively. However, if you are still actively selling and distributing a product line after that date, it will need to comply regardless of when it was originally launched.
