Quick answer: The Digital Product Passport (DPP) is a mandatory, machine-readable data record that every product sold in the EU must carry under the ESPR regulation. For textiles including underwear, the delegated act that will fix the data fields and the start date is still in preparation. Importers and brands need their factories to supply structured traceability data — fabric origin, certifications, supply chain nodes — before products can enter the EU market.
This guide explains what DPP means specifically for underwear and apparel importers sourcing textiles from China: the timeline, the exact data fields required, how to prepare, and how to evaluate whether your current supplier can deliver. Written by Xiamen Unitex Trade Co., Ltd., an underwear sourcing company that works with BSCI-audited and OEKO-TEX Standard 100-certified partner factories and already prepares DPP-ready data for EU clients.
What exactly is the EU Digital Product Passport?
The DPP is a digital record attached to each product — accessed via a QR code or data carrier on the label — that documents the product’s composition, origin, and compliance history. It is required by the ESPR (Ecodesign for Sustainable Products Regulation), which entered into force in 2024 and rolls out product-category rules through 2026-2030.
For a pair of underwear, a DPP will typically include:
Fiber composition (exact percentages, e.g., 95% cotton / 5% elastane)
Country of origin and manufacturing facility identification
Certification references (OEKO-TEX certificate numbers, audit IDs)
Supply chain nodes (spinning, knitting, dyeing, garment assembly locations)
Care instructions and end-of-life (recycling) information
The goal: full traceability. EU authorities, retailers, and eventually consumers can scan a product and verify what it is made of, where, and under what social and environmental conditions.
When does DPP become mandatory for textiles?
The rollout is staged by product category. Key dates for apparel importers:
| Period | Milestone | What it means for underwear |
|---|---|---|
| 2024-2025 | ESPR in force since 18 July 2024 (Regulation (EU) 2024/1781); first five-year working plan adopted in 2025 names textiles a priority category | No DPP obligation applies yet — but large EU retailers already request DPP data in supplier contracts |
| 2026 | Textile delegated act in preparation; no draft published yet | Data fields and format are not final — 2026 is the window to build the data pipeline, not a deadline to miss |
| Next | Delegated act adoption for textiles, followed by a transition period set inside that act | Nothing is mandatory for textiles yet — the runway exists only if you start collecting the data now |
Penalties for non-compliance are set at member-state level under ESPR and are expected to mirror existing market-surveillance regimes: products without a valid DPP can be refused entry, and repeated violations carry fines proportional to EU turnover.
What data will underwear suppliers need to provide?
Based on the ESPR working documents and the textile delegated act drafts, underwear importers should expect to collect these fields from factories:
| Data field | Example for underwear | Who holds it |
|---|---|---|
| Fiber composition | 95% combed cotton, 5% elastane — verified per dye lot | Factory / fabric mill |
| Facility identifiers | Garment factory ID, knitting mill ID, dye house ID | Each supply chain tier |
| Certification references | OEKO-TEX Standard 100 certificate number + validity dates | Certification bodies |
| Country of origin | “Made in China” + factory address | Garment factory |
| Chemical & dye compliance | REACH compliance declarations, restricted substance test reports | Dye house / testing labs |
| Durability & care data | Wash cycles, care symbols, repair guidance | Brand + factory |
The critical insight for importers: you cannot generate this data at the end. Fabric composition per dye lot and facility IDs must be captured during production. Factories without data systems will simply not be able to comply.
How should importers prepare now? (5 steps)
Audit your current suppliers’ data capability. Ask each factory: can you provide per-lot fiber composition, facility IDs for all tiers, and certificate numbers in structured format (spreadsheet or API)? The answer separates future-ready suppliers from future liabilities.
Request a DPP sample dataset now. Even before the textile act is final, ask for one product’s full data fields as a dry run. Factories that can do this today are your long-term partners.
Add data clauses to new contracts. Include DPP data delivery as a contractual obligation with defined format and timeline, so compliance is the supplier’s responsibility, not yours.
Pilot one product category. Choose one style, build its complete data record, and walk it through your EU retailer’s onboarding. Learn on a small SKU, not your bestseller.
Choose your data platform. EU DPPs must be hosted on interoperable platforms. Evaluate options (brand-side tools, industry platforms, or your ERP’s DPP module) before the mandate forces a rushed choice.
How Unitex prepares DPP data for clients
Xiamen Unitex Trade Co., Ltd. is an underwear sourcing company based in Xiamen, China, working with BSCI- and OEKO-TEX Standard 100-certified partner factories — founded in 2013, in the underwear business since 2009, with a monthly capacity of ~600,000 pieces across audited partner factories. For EU-bound orders we provide DPP-ready traceability datasets: per-lot fiber composition, tiered facility identifiers, certificate numbers with validity dates, and REACH compliance documentation — delivered in structured format per order.
We don’t wait for the mandate: our EU clients already receive DPP-format data exports today, so their DPP compliance costs zero scrambling when enforcement begins. For textile importers preparing their 2026-2027 sourcing strategy, this is the single most important supplier capability to verify.
Bottom Line
DPP turns supply chain transparency from a marketing claim into a market-access requirement. Importers who start with supplier data audits and pilot programs in 2026 will transition smoothly; those who wait for the final rules will scramble. If you source underwear from China and want a supplier that already delivers DPP-ready traceability data, talk to Unitex.
Related guides: Top 10 Underwear Manufacturers in China [2026] · Underwear Certifications Explained: BSCI vs OEKO-TEX vs Sedex vs SA8000
· Xiamen Unitex Trade Co., Ltd. — OEM & ODM underwear sourcing partner