Horizontal DPP Q2 2026: five hypotheses on the shift of the Digital Product Passport from a sectoral ESPR mechanism to a cross-cutting NLF framework

COM(2025) 500 projects the DPP as a horizontal requirement of the NLF (Q2 2026). Five hypotheses 2026-2030 on the transition from a sectoral ESPR mechanism to a cross-cutting internal-market framework.

• COM(2025) 500 declares that "the upcoming reform of the new legislative framework will fully introduce the digital product passport to demonstrate compliance with EU product legislation" (p. 60) and schedules the proposal for Q2 2026 (p. 31).
• The DPP transitions from a sectoral ESPR mechanism (Article 4 delegated acts by product group) to a horizontal, prior and unavoidable requirement for the marketing of any product covered by internal-market harmonisation legislation.
• The JRC 145830 methodology (March 2026) anticipates this duality: a common horizontal NLF vocabulary + product-group-specific ontologies nested as additional fields.
• Five prospective hypotheses 2026-2030: (1) the 2027 textile delegated act as a horizontal NLF pilot, (2) absorption of the EU Declaration of Conformity, (3) accountability of non-EU marketplaces, (4) interoperability of Safety Gate + ICSMS + Customs Data Hub, (5) convergence of sectoral delegated acts towards a common architecture.
• EP Resolution 52025IP0242 (OJEU C/2026/2096 29.4.2026) ratifies the political consensus: the passport "should replace the existing declarations of conformity" (p. 233) and requires interoperability with "Safety Gate, ICSMS, Certex and the future EU Customs Data Hub" (p. 235).

What COM(2025) 500 says about a horizontal DPP

Update (June 2026): since the publication of COM(2025) 500, the review of the New Legislative Framework has been regrouped into the European Product Act, with the legislative proposal foreseen for the second half of 2026 (the public consultation closed on 4 February 2026). The following analysis retains the original reference of the Communication —"second quarter of 2026" (p. 31)— as a literal citation of the source.

Communication COM(2025) 500 final redefines the architecture of regulatory compliance in the European internal market. The text certifies the Commission's will to transition from a regulatory model based on physical documents towards an ecosystem structured around data. This move requires the review of the New Legislative Framework (NLF). The Commission's mandate is explicit. The document states that "the upcoming reform of the new legislative framework will fully introduce the digital product passport to demonstrate compliance with EU product legislation" (CELEX 52025DC0500, p. 60). The publication of this legislative proposal is scheduled for the "second quarter of 2026" (CELEX 52025DC0500, p. 31).

The text does not limit the passport's function to mere environmental traceability. It assigns the instrument a broad digital-container role. The Strategy establishes that the passport "will serve as a digital repository for digital labels, conformity documentation, instructions and manuals" (CELEX 52025DC0500, p. 59). This formulation broadens the technical scope of the mechanism. The container design forces brands' systems to integrate disparate data flows. They must unify life-cycle impact metrics with safety certificates.

The impact on the fashion industry is articulated through the absorption of adjacent regulations. The text anticipates the review of labelling rules. The Commission explicitly stipulates the integration of those requirements. "The Commission will review the Regulation on the labelling of textile products with a view to clarifying the applicable rules... Digital labels will form part of the digital product passport" (CELEX 52025DC0500, p. 25). The assimilation of textile labelling into the passport eliminates the possibility of maintaining parallel infrastructures. It forces the consolidation of fibre-composition information with circularity data.

The Strategy requires the deployment of the "once only" principle. Economic operators should not supply the same information repeatedly to different authorities. This mandate requires absolute interoperability between the passport repository and customs databases. The administrative-simplification effort relies on the Omnibus package accompanying the Strategy. The Commission stresses the intention to "move from a document-based single market to a data-based single market" (CELEX 52025DC0500, p. 9). The fulfilment of this objective depends critically on the redesign of the NLF. The passport ceases to be an ecological requirement to become the digital access key to the market.

Sectoral vs horizontal — current ESPR DPP vs post-NLF horizontal DPP

The architecture in force under the ESPR Regulation operates through a purely sectoral approach. Article 4 of Regulation (EU) 2024/1781 empowers the Commission to establish requirements by means of product-group-specific delegated acts. The ESPR Working Plan 2025-2030 (COM(2025) 187 final) delimits the initial application to a restricted spectrum. It prioritises the textile sector for 2027. Also tyres on the same date. It includes furniture for 2028 and mattresses for 2029. Intermediate products such as iron and steel appear for 2026. To these is added aluminium in 2027. The sectoral model designs the passport as an annex to the particular ecodesign requirements of each vertical.

The review of the New Legislative Framework projected for the second quarter of 2026 alters the very basis of the mechanism. The NLF constitutes the legal matrix that governs CE marking. It affects all Union harmonisation legislation. The integration of the passport into the NLF transforms the instrument into a horizontal requirement. It becomes a prior and unavoidable condition for the marketing of any product covered by harmonisation legislation. The distinction is profound. The post-NLF horizontal passport does not depend on the activation of an ESPR delegated act to require the unique identification of the product. It imposes a mandatory base data layer for the entire internal market.

The JRC 145830 methodology (March 2026) anticipates this structural duality. The Joint Research Centre report defines a "common vocabulary" of cross-sectoral application. This base vocabulary governs the unique identifiers. Also the manufacturer's information (JRC 145830, p. 28). It acts as a horizontal semantic anchor. On top of this base sit the "product-group-specific ontologies". These ontologies translate performance concepts into sectoral metrics. An illustrative example lies in ageing resistance. The textile ontology requires abrasion-resistance data. The steel ontology demands fatigue-limit metrics (JRC 145830, p. 30).

The shift to the NLF consolidates the JRC's common vocabulary as a binding cross-cutting standard. Manufacturers' infrastructure must support the common vocabulary to obtain CE marking. The ESPR's sectoral requirements will operate as additional data fields nested in the NLF parent structure. This change demands agnostic IT infrastructures. Brands' corporate systems cannot be coded exclusively under textile logic. They must adopt data architectures based on the foundational NLF model.

Five prospective hypotheses 2026-2030

The convergence of regulatory frameworks demands projecting medium-term vectors of evolution. Analysis of the current legislative corpus supports the following structural hypotheses.

Hypothesis 1: the 2027 textile delegated act will act as the first complete implementation of the horizontal NLF (high probability, time frame Q2 2026-Q4 2027). The JRC 145830 methodology establishes the publication of the textile rules for 2027. This deadline coincides with the processing of the NLF reform. The intrinsic complexity of the textile supply chain makes this sector the ideal pilot for validating the horizontal model. Brands will have to trace from raw-material production (Tier 4) to final assembly (Tier 1). The textile data architecture will set the de facto standard for the NLF's horizontal taxonomy.

Hypothesis 2: the Digital Product Passport will fully absorb the EU Declaration of Conformity (medium-high probability, time frame 2027-2029). The Single Market Strategy already mentions the objective of advancing "by digitalising the declarations of conformity" (CELEX 52025DC0500, p. 59). EP Resolution 52025IP0242 explicitly demands this substitution, arguing the need to streamline requirements. The passport will cease to be a consultable document to become a cryptographic artefact that certifies the legal conformity of the product in real time.

Hypothesis 3: the chain of responsibility of non-EU e-commerce will become subject to the horizontal scope of the passport (medium-high probability, time frame 2026-2028). The projected review of the Market Surveillance Regulation aligns with the customs offensive. The Commission seeks to neutralise non-compliant imports of low-value consignments. Online platforms will have to verify the existence of the passport before listing the product. The operational cost of maintaining traceability systems at this level is high. The infrastructures of non-EU brands will face severe financial pressures to comply with the horizontal standard.

Hypothesis 4: mandatory interoperability with Safety Gate and ICSMS will be established as a framework requirement (medium probability, time frame 2027-2030). Added to this is the EU Customs Data Hub. The passport will not operate in a silo. The data-exchange protocols will have to interact directly with the Union's early-warning nodes. An alert in Safety Gate will deactivate the passport's unique identifier at the Union's borders. The customs system will automatically block the release for free circulation of the affected batches.

Hypothesis 5: sectoral delegated acts will converge towards a common NLF architecture (high probability, time frame Q2 2026-2030). The divergences in data models between sectors will disappear. The initial implementations will undergo technical adjustments to fit into the common vocabulary dictated by the NLF review. Companies' corporate systems will have to support dynamic schema updates to absorb the Commission's semantic redefinitions.

EP Resolution 52025IP0242 as parallel evidence

The European Parliament's stance ratifies the trajectory of horizontality. Resolution 52025IP0242 on a new legislative framework adapted to the digital and sustainable transitions was adopted on 21 October 2025. Its official publication (OJEU C/2026/2096 29.4.2026) confirms the political consensus on the redesign of the NLF. The parliamentary text acts as documentary evidence parallel to the Commission's strategy.

The document expresses without ambiguity its support for a non-fragmented model. It affirms that "a horizontal and cross-sectoral application of the digital product passport... would reduce fragmentation in sustainability information and ensure coherence across the internal market" (C/2026/2096, p. 219). The Parliament implicitly rejects the approach of isolated passports and defends a uniform data matrix. It further demands deep integration with the Union's executive infrastructure. It calls for an ambitious strategy to ensure interoperability with existing systems. It explicitly names "the Union's Safety Gate system, the information and communication system for market surveillance, Certex and the future EU Customs Data Hub" (C/2026/2096, p. 235).

The parliamentary stance directly addresses the current documentary friction. It considers that the passport "should replace the existing declarations of conformity in order to streamline conformity requirements" (C/2026/2096, p. 233). This affirmation underpins the hypothesis of absorption of the EU Declaration of Conformity. The passport assumes the evidentiary monopoly before market surveillance authorities.

The text also broadens the operational perimeter towards value retention. The Parliament stresses the weight of "reverse commerce". It values this segment at EUR 94 billion for the period 2022-2023 (C/2026/2096, p. 220). It warns about the legal gap affecting secondary operators. It requires establishing harmonised definitions of "remanufacturers" and "refurbishers" (C/2026/2096, p. 248). These definitions will have to be integrated into the passport's access-control model. The data architecture will have to grant write permissions to these operators to record repair operations. The passport requires an append-only ledger design throughout the product life cycle. The NLF will have to codify the circular economy's access rights.

Compliance roadmap 2026-2030 European textile brands

Adjustment to the NLF's horizontal matrix requires European textile companies to restructure their data flows. The roadmap towards 2030 depends directly on organisational size and the concurrent requirements of the CSRD directive. Compliance strategies vary according to the operational scenario.

The scenario for large corporations presents imminent and massive requirements. Companies exceeding 1,000 employees and EUR 450 million in net turnover (post-Omnibus CSRD thresholds, Recital 7 Dir 2026/470) operate under maximum time pressure. The ESPR Regulation entered into force on 18 July 2024. Its Article 25.1 imposes on this segment the ban on the destruction of unsold goods from 19 July 2026. This restriction requires a precise digital inventory. At the passport level, large firms must deploy complex enterprise architectures. They have to connect their ERP and PLM systems in real time with the European passport registry. They must ensure the automated generation of the product's unique identifier and its linkage with the data carriers. The management of access levels for customs audits requires advanced cryptographic capabilities.

The scenario for mid-sized entities requires a modular approach. The operational phases must prioritise the mapping of the supply chain. The textile architecture requires tracing from raw-material producers (Tier 4) to assembly facilities (Tier 1). The capture of material-composition data and substance-of-concern metrics must be systematised. The optimal strategy lies in assimilating the "common vocabulary" dictated by the JRC methodology. Aligning internal databases with this foundational NLF standard minimises refactoring costs when the textile delegated act is published in 2027.

The scenario for small business structures focuses the effort on functional certainty. Temporary exceptions are common in European regulation. The ESPR provides for a minimum grace period of 18 months between OJEU publication of the delegated act and its mandatory application (Article 4.4). However, value-chain pressure will force early adoption. Large distributors will require the passport from their suppliers regardless of their size. The roadmap must concentrate on acquiring capabilities to generate identifiers compatible with open standards and to host the required data in high-availability third-party repositories.

Analytical reflection

The 2025 Single Market Strategy triggers a profound reordering of the European economic space. The absorption of the Digital Product Passport by the New Legislative Framework eliminates its character as a sectoral experiment. The instrument abandons the exclusive sphere of sustainability to integrate into the Union's commercial law. Textile brands face the 2027 delegated act not as a simple ecological obligation, but as the first direct collision with the new horizontal standard of the internal market.

The displacement of the EU Declaration of Conformity towards a digital-native model forces corporations to audit their information repositories. The integration of customs nodes and surveillance systems signals zero tolerance towards data asymmetries. The textile industry assumes the role of testbed. The successful resolution of traceability from fibre cultivation to garment marketing will validate the NLF architecture. The success or failure of the textile deployment will define the technical jurisprudence for the rest of the European industrial sectors over the next decade.

To go deeper into the specific sectoral calendar, see the analysis of the ESPR Working Plan 2025-2030. On convergence between industrial verticals under the common model, review the piece on cross-sectoral DPP interoperability textiles-batteries-furniture. For the macro framework of the 2027 reordering, see the five hypotheses on the European textile sector post-1 January 2027.