Digital Product Passport: Merchandise Starts With Apparel
A digital product passport is an EU record of a product's materials, origin, repair and recycling data, reached through a data carrier such as a QR code. The Ecodesign for Sustainable Products Regulation introduces it one product group at a time.
This guide explains when the digital product passport is planned to reach a club, event or brand merchandise range, which items come first, which data to collect now, and how the EU ban on destroying unsold apparel already changes what happens to surplus stock. It draws on the regulation and the European Commission’s own pages and is an explainer, not legal advice.
Key Takeaways
- The passport rests on the Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781. The EU registry for passports has been live since 20 July 2026.
- No merchandise item needs a passport yet. Each product group gets its own delegated act, followed by at least 18 months to comply.
- Apparel comes first for most ranges: the textiles act is planned for the fourth quarter of 2027, so a passport for shirts or jackets would not be mandatory before 2029.
- Pins, keyrings, medals and trophy replicas are not in the Commission’s first working plan as finished products. Toys need passports under their own law from 1 August 2030.
- Since 19 July 2026, large companies may not destroy unsold apparel, clothing accessories, hats and footwear; medium-sized ones follow on 19 July 2030, and micro and small enterprises are exempt.
- Two steps pay off now: collect fibre, origin and test data per style, and agree a second life for surplus before you order.
In This Article
- Key Takeaways
- What Is a Digital Product Passport?
- When Will the Digital Product Passport Reach Merchandise?
- Which Items in a Merchandise Range Come First?
- What Data Should You Ask the Factory For Now?
- How Does the Ban on Destroying Unsold Apparel Work?
- What Must Companies Disclose About Discarded Stock?
- What Should You Do With Unsold Club and Event Stock?
What Is a Digital Product Passport?
A digital product passport is a product’s data record, opened by scanning a data carrier such as a QR code on the product, its packaging or its documents. It can hold material, origin, repair and recycling information, and its legal basis is the ESPR.
The Commission calls it a digital container for products, components and materials; depending on the product group, it may cover safety, origin, materials, repairability, environmental performance, reuse and recycling. Article 10 of the ESPR requires a persistent unique product identifier and a data carrier physically present on the product, its packaging or its accompanying documents.
The detailed data stays with the company that places the product on the market or with a service provider it hires. Only identifiers and registration data go into the central registry, which the Commission launched on 20 July 2026. The Commission’s DPP FAQ expects customs to check imports against the registry from around 2029.
There is no general passport duty. According to the FAQ, a passport becomes mandatory only through product-specific rules, and a place on the working plan does not by itself make it mandatory.
When Will the Digital Product Passport Reach Merchandise?
On the Commission’s indicative timeline, the first ESPR passports that touch merchandise come with the textiles act, planned for the fourth quarter of 2027, plus a transition of at least 18 months. Toys follow a separate law from 1 August 2030.
The ESPR and energy labelling working plan for 2025 to 2030 sets the order: four final products (textiles with a focus on apparel, furniture, tyres and mattresses), two intermediate products (iron and steel, and aluminium) and two horizontal measures. Other laws set passports of their own, and the Commission’s DPP page names the Batteries Regulation, the PPWR and the Toy Safety Regulation among them.
The battery, steel and aluminium dates come from the Commission’s DPP timeline, the footwear study from the working plan. The ESPR dates are indicative, and none of these delegated acts has been adopted. The Commission’s page on textile apparel adds that timelines may evolve. Toys have a fixed date in law, so a delayed textiles act, or a transition longer than the minimum, would put toys first.
Which Items in a Merchandise Range Come First?
Apparel is the first merchandise line on the passport’s path. Metal goods such as pins, keyrings, medals and trophy replicas have no passport planned as finished products, and their fit with the passport is weak.
Shirts, jackets and other apparel
The Commission’s textile apparel page says the passport rules for the sector will come in the same delegated act as the ecodesign requirements. The passport is to be accessible at online points of sale and through a data carrier on the product itself, such as a QR code.
In a club or event range, that means replica and training shirts, T-shirts, hoodies, jackets and other garments. Whether scarves and caps are included depends on the act’s final scope, which is not settled. On new designs, keep room on the woven or printed label for a data carrier.
Pins, keyrings, medals and trophy replicas
These items are not textiles, and the working plan treats iron and steel and aluminium as intermediate products. The Commission’s iron and steel page describes steel as an input for other goods, in sectors such as automotive, construction and industrial equipment.
The working plan notes that rules on intermediates could affect all final products made from them, and lists two ways to limit that: information requirements only, or including selected final products that contain high quantities of the intermediate. Our reading: pins and keyrings contain little metal, and zinc alloy, used for die-cast pins and medals, is not on the plan at all. Finished metal merchandise and trophy replicas are therefore a weak fit, possible later through the steel or aluminium acts, but not planned.
Toys and packaging
Under the new Toy Safety Regulation, all toys placed on the EU market will need a digital product passport with safety and compliance information from 1 August 2030. That matters if your range includes plush mascots or other toys.
The PPWR creates no passport for packaging itself. Recital 70 of the PPWR says that where the packaged product needs a passport, that passport should also carry the packaging information, so one data carrier serves both. Today’s packaging duties are in our guide to who the packaging manufacturer is under the PPWR.
What Data Should You Ask the Factory For Now?
Ask, style by style, for the data a textiles act is likely to draw on: fibre composition by component, where each production step happens, care and repair information, test reports and chemical compliance. At order stage this costs little; chasing old orders later costs more.
The textile apparel page lists what a passport may contain: product identification, fibre composition, use, repair and maintenance, reuse and recycling information, origin and the economic operators involved. Annex III of the ESPR adds the GTIN, the commodity code, identifiers for operators and production facilities, and compliance documents, and the working plan says passports will include material composition and any substances of concern.
Settle your own role, too. The ESPR defines the manufacturer as anyone who has a product designed or manufactured and markets it under their own name or trademark, so a club or brand selling crested goods under its own marks is the manufacturer even when a partner factory makes them. For licensed merchandise, the licence or supply contract should say who creates and maintains the passport.
Am Ball has its high-end apparel made mostly at partner factories in Portugal, while most of its metal goods come from partner factories in Asia, so origin data for one mixed range comes from several sources. A sheet per style keeps it together; fill it at the sample stage and match each composition and test report to the approved sample before series production.
Passport data can back a specific green claim, but it does not replace the claim rules, as our guide to which green claims merchandise can carry explains. Material choices themselves, such as recycled polyester, are covered in our buyer guide to eco-friendly merchandising.
How Does the Ban on Destroying Unsold Apparel Work?
Since 19 July 2026, large companies may no longer destroy unsold apparel, clothing accessories, hats and footwear, except under derogations they can document. Medium-sized companies follow on 19 July 2030, and micro and small enterprises are exempt.
The ban sits in Article 25 of the ESPR. Unsold products include surplus stock, excess inventory, deadstock and consumer returns, and destruction means intentionally damaging or discarding a product as waste. Handing goods over for preparing for reuse or remanufacturing is not destruction, and a company outside the ban must not destroy stock passed to it to get around it.
The Commission estimates that 4 to 9 percent of unsold textiles in Europe are destroyed before they are ever worn.
Which merchandise items are on the list
Annex VII of the ESPR lists the goods by customs code: apparel and clothing accessories of leather (4203), knitted (chapter 61) or not knitted (chapter 62), hats and other headgear (6504 and 6505), and footwear (6401 to 6405). In a club or event range, that covers replica shirts, T-shirts, hoodies, jackets, caps and beanies. Scarves count too: the customs headings for textiles place shawls and scarves under 6214 and knitted clothing accessories under 6117.
Pins, keyrings, medals and trophy replicas are not on the list, and neither are towels and blankets, which sit in chapter 63. The working plan says the Commission does not intend to extend the ban during the first plan, because data from the disclosure duty are not yet available.
When destruction is still allowed
The Commission adopted the delegated act on derogations on 9 February 2026; it applies from 19 July 2026 and allows documented destruction in ten cases, including:
- dangerous products, or products that breach other law where destruction is required or is the proportionate corrective action;
- products found to infringe intellectual property rights, such as counterfeits;
- products under a valid licence that forbids sale after a set date, once that date has passed and destruction is proportionate;
- products whose protected labels, logos or recognisable design cannot technically be removed for reuse;
- damaged products that cannot be repaired technically or cost-effectively, and defective products that cannot technically be repaired;
- products offered for donation to at least three suitable social economy entities in the EU, or on your website for at least eight weeks, and not accepted.
The licence and logo cases matter for licensed merchandise, but they are no blanket exemption. You need the licence clause that restricts sale after a date, or an inspection report showing the logos cannot be removed, plus a justification. Companies keep this documentation for five years, produce it within 30 days of an authority’s request and tell the waste treatment operator which derogation applies.
What Must Companies Disclose About Discarded Stock?
Large companies that discard unsold consumer products must publish yearly, on their website, how many items they discarded, their weight, the reasons and where they went. This duty covers all consumer products, pins and keyrings included.
Article 24 of the ESPR also requires any derogation used, the shares sent to reuse, recycling, other recovery and disposal, and the measures taken and planned to prevent destruction. The first disclosure covers the first full financial year with the regulation in force, which is 2025 for a calendar-year company. Micro and small enterprises are exempt; medium-sized ones follow on 19 July 2030.
The Commission’s announcement of 9 February 2026 confirms that the disclosure rules already apply to large companies and that a standard format applies from February 2027.
Check your size first. Under the EU SME definition, a medium-sized company has fewer than 250 staff and either up to 50 million euros turnover or up to 43 million euros balance sheet total. A merchandising company inside a larger group may have to count the group’s figures too.
What Should You Do With Unsold Club and Event Stock?
Plan the second life of stock before you order: keep most of the volume undated, make dated pieces in small runs, and line up resale, partner packs and donation partners. Destruction then stays the documented last resort the law intends.
Article 23 of the ESPR asks every economic operator to take reasonable measures to prevent the need to destroy unsold products, and the Commission’s announcement points to stock management, returns handling, resale, remanufacturing, donation and reuse. For events, the surplus plan in our guide to planning sports event merchandise applies directly: undated core items, numbered limited pieces, pre-orders and an agreed destination for surplus.
Small runs help. Orders at Am Ball typically start around 300 units, so a shirt tied to a single final or anniversary match can be ordered close to the demand you can count, with a top-up date if it sells.
Worked example: the end-of-season count
Take a hypothetical club merchandising company inside a group above the medium-sized ceilings, so it counts as large. After the season it holds 1,500 knitted scarves with an undated crest design, 600 T-shirts printed for a cup final, 300 caps from a licensed collaboration whose licence banned sales after 30 June, and 2,000 enamel pins showing the season’s dates.
- Scarves: they go back on sale next season, in the webshop and at matches.
- Final T-shirts: sell them at a reduced price, put them in volunteer and partner packs, or offer them for donation for at least eight weeks. If nobody accepts them, the donation derogation allows destruction, with proof of the offer.
- Caps: the expired licence may justify destruction if the contract explicitly restricts sale after that date and destruction is proportionate. Check first whether the partner’s logo can be removed so the caps can still be sold or donated.
- Pins: the ban does not apply, but discarding them counts in the annual disclosure.
Whatever is discarded appears in the next disclosure. The cheaper fix sits upstream: next season, the final shirt becomes a pre-order and the pins carry no dates.
Frequently Asked Questions
Do T-shirts and scarves need a digital product passport today?
No. The textiles act is not adopted yet; the Commission plans it for the fourth quarter of 2027, followed by at least 18 months. The destruction ban is a separate rule and already covers scarves and caps at large companies.
Will pins, keyrings and medals need a digital product passport?
Not under the Commission’s first working plan. Steel and aluminium are on it as intermediate products, and the plan only mentions considering selected final products with high quantities of these materials.
Who creates the passport for licensed merchandise?
The economic operator that places the product on the EU market, usually the manufacturer or the importer, while distributors and dealers must make sure a passport is available. The ESPR manufacturer is whoever markets the product under its own name or trademark, so settle the role in the contract.
Can a club still destroy unsold shirts?
A large company only under one of the derogations, with documentation kept for five years. Medium-sized companies are covered from 19 July 2030 and micro and small enterprises are exempt, but none may destroy stock passed to them to get around the ban.
Does the destruction ban apply to event organisers?
It applies to economic operators, including manufacturers, importers, distributors and dealers, by company size. An organiser selling apparel under its own event marks is covered as a large company, and from 19 July 2030 as a medium-sized one.
Is a QR code on the label already a digital product passport?
No. A passport follows the delegated act for its product group, uses a persistent unique product identifier and must be registered in the EU registry before the product is placed on the market. Until the textiles act applies, a QR code linking to a product page is a voluntary extra.
Conclusion
The digital product passport reaches merchandise through apparel first, mandatory in 2029 at the earliest on the Commission’s timeline, while pins, keyrings and medals are a weak fit. The destruction ban already applies to large companies, so surplus planning matters now. Collect material and origin data per style today, and decide where leftover stock goes before you order.
If you are planning a range with that data built in from the first sample, talk to our team about your merchandising needs.
