Do UK and US brands need a Digital Product Passport to sell in the EU?
By Cat Taylor and Leanne Elliott-Young · 20 October 2026 · 8 min read
Last updated:
Why EU rules apply to non-EU brands
The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) sets rules for products "placed on the market" in the EU, meaning the first time a product is made available there. It does not matter where the product was designed, made or sold from.
Under ESPR, a product covered by the rules can only be placed on the EU market if a Digital Product Passport is available for it (Article 9). So if your products reach EU customers, the rules reach you.
Who is legally responsible when you're outside the EU?
ESPR gives obligations to "economic operators". For a brand based outside the EU, that usually means:
- Importer: an EU-based business that brings your products into the EU market. This might be your distributor, a wholesale customer or your own EU company.
- Authorised representative: an EU-based business you appoint by written mandate to act on your behalf (ESPR Article 28).
- Manufacturer: you, as the brand, are still responsible for the product meeting the requirements and for the passport data.
EU product law generally requires an economic operator established in the EU for products sold there, including products sold online direct to consumers (Regulation (EU) 2019/1020, Article 4). Many UK and US brands already have one for product safety: since 13 December 2024, the General Product Safety Regulation (Regulation (EU) 2023/988) has required an EU-based responsible person for consumer products sold in the EU. Passports will add to that relationship.
What applies to you: common scenarios
| How you sell | Does the DPP apply? | Who handles EU responsibility |
|---|---|---|
| You sell direct to EU customers from your UK or US website | Yes | An EU authorised representative or EU-based fulfilment partner, plus you as manufacturer |
| You sell wholesale to EU retailers or distributors | Yes | Usually the EU importer (your retailer or distributor), using passport data you provide |
| You sell through online marketplaces | Yes | You and your EU representative. Marketplaces must also act on non-compliant listings (ESPR Article 35) |
| You have an EU company or warehouse | Yes | Your EU company can act as importer |
| You sell into Northern Ireland | Yes | EU product rules apply in Northern Ireland under the Windsor Framework |
| You sell only in Great Britain or the US | Not today | No passport requirement yet, but EU retail partners and future UK rules may ask for the same data |
The EU passport registry and customs checks
The EU has a central Digital Product Passport registry, which ESPR required the Commission to set up by 19 July 2026 (Article 13). The economic operator placing a product on the market uploads its identifiers to the registry. Customs authorities can then check a product's registration before releasing it into the EU (Article 15).
For UK and US brands this matters in practice. Once the textile rules apply, shipments without properly registered passports risk delays at the EU border.
Read our full guide to the EU DPP registry →
Key dates for UK and US fashion brands
| Date | What happens |
|---|---|
| 18 July 2024 | ESPR enters into force |
| 13 December 2024 | General Product Safety Regulation applies, requiring an EU-based responsible person |
| 16 October 2025 | Revised Waste Framework Directive (Directive (EU) 2025/1892) enters into force, bringing extended producer responsibility (EPR) for textiles |
| 19 July 2026 | EU passport registry set up. Ban on large companies destroying unsold clothing and footwear begins |
| July–September 2026 | UK government runs a call for evidence on "digital product records" |
| 2027 (expected) | Textile delegated act adopted, setting what textile passports must contain |
| By around April 2028 | EU countries must have textile EPR schemes in place |
| Around 18 months after the delegated act (expected 2029) | Digital Product Passports required for textiles |
| 19 July 2030 | Destruction ban extends to medium-sized companies |
Textile dates after 2026 are expected timings and may change.
Two more EU rules that affect non-EU fashion brands
Extended producer responsibility (EPR) for textiles
The revised Waste Framework Directive requires every EU country to set up EPR schemes for clothing, footwear, accessories and home textiles within 30 months of it entering into force. Brands that place these products on the EU market, including non-EU brands selling online to EU consumers, will pay fees towards collection, sorting and recycling. Fees will be lower for more durable, repairable and recyclable products. Non-EU sellers may need to appoint an authorised representative for EPR in each country where they sell.
The ban on destroying unsold clothing and footwear
Since 19 July 2026, large companies can't destroy unsold clothing and footwear in the EU, except in specific cases such as safety risks or damage (ESPR Article 25). The ban extends to medium-sized companies from 19 July 2030. Micro and small companies are exempt. If you hold stock or handle returns in the EU, plan for unsold items to be resold, repaired, donated or recycled.
What about rules in the UK and US?
UK: There is no UK Digital Product Passport requirement today. Between July and September 2026, the UK government ran a call for evidence on "digital product records" to explore whether a UK policy is needed, including its impact on businesses selling into the EU and Northern Ireland. Brands that build EU-ready passports now will be well placed if the UK follows.
US: As of October 2026, there is no federal US Digital Product Passport requirement. US brands selling into the EU must follow the EU rules for those products.
The practical answer for most UK and US brands is to build one passport system that meets EU requirements and use it across every market.
What UK and US brands should do now
- Map where your products go. List every route into the EU: direct online sales, wholesale, marketplaces and Northern Ireland.
- Confirm your EU representative. Check whether your existing product safety responsible person or importer will also handle passports, registry uploads and EPR.
- Collect your product data. Materials, origin, care, repair and recycling information sits with your suppliers. Start gathering it now.
- Choose passport levels and data carriers. Decide which products need model, batch or item-level passports, and whether to use QR codes, NFC chips or RFID.
- Use GS1 Digital Link. One standard identity per product works across EU retail, logistics and the registry.
- Plan for EPR and the destruction ban. Budget for EPR fees and set up resale, repair and recycling routes for unsold stock and returns.
- Use the passport for more than compliance. The same passport can power authentication, resale, repair and customer engagement in every market, not just the EU.
How PATINA helps UK and US brands sell into the EU
PATINA is the post-purchase operating system for fashion and luxury brands, built on Digital Product Passports. It:
- Creates passports at model, batch or item level that meet EU requirements, for every market you sell in.
- Supports QR codes, NFC chips and RFID.
- Uses GS1 Digital Link, so each product has one standard web identity.
- Prepares passport data for the EU registry and your EU representative.
- Turns the passport into a direct customer relationship through authentication, repair, resale, take-back and rewards.
Quick answers
Do UK brands need a Digital Product Passport?
Only for products sold in the EU or Northern Ireland. There is no passport requirement for products sold only in Great Britain today, though the UK government is exploring "digital product records".
Do US brands need a Digital Product Passport to sell in Europe?
Yes. The EU rules apply to products placed on the EU market, wherever the brand is based. Textile passports are expected to be required around 2029.
Who is responsible for the Digital Product Passport if my brand is outside the EU?
An EU-based economic operator, usually your importer or an authorised representative you appoint. You, as the brand, are still responsible for the product data.
Does the Digital Product Passport apply to products sold online to EU customers?
Yes. Direct online sales to EU customers count as placing products on the EU market, and online marketplaces must act on non-compliant products.
When do Digital Product Passports become mandatory for clothing?
The textile delegated act is expected in 2027, followed by around 18 months for brands to comply, so passports are expected to be required around 2029.
Does the Digital Product Passport apply in Northern Ireland?
Yes. EU product rules, including the Digital Product Passport, apply in Northern Ireland under the Windsor Framework.
Sources
- Regulation (EU) 2024/1781 (ESPR)
- Regulation (EU) 2019/1020 on market surveillance
- Regulation (EU) 2023/988 (General Product Safety Regulation)
- Directive (EU) 2025/1892 (revised Waste Framework Directive)
- European Commission, New EU rules to stop the destruction of unsold clothes and shoes (February 2026)
- UK Government, Call for evidence: digital product records policy (July 2026)
