COM(2025) 504: the proposal that digitalises ESPR and harmonises seven product regulations

A proposal that affects seven sectors at once

The European Commission published in May 2025 the proposal COM(2025) 504 with a deliberately cross-cutting objective. The text seeks to simultaneously amend seven European regulations under the umbrella of the New Legislative Framework. This legislative decision projects an unequivocal strategic message. The digitalisation of conformity will not be executed through sectoral regulatory silos. The deployment will require a harmonised architecture. The Digital Product Passport ceases to be an isolated mechanism for circularity. It de facto assumes the burden of proof of technical conformity and the safety of products in the internal market.

The directive of the European Commission consolidates the principle of « digital by default ». The proposal eliminates the references to paper support for the EU declaration of conformity and the instructions for use. It obliges economic agents to transition towards structured data formats.

The proposal establishes a structural mandate. When the legislation requires a digital product passport, the technical compliance information will migrate to this support. The DPP becomes the canonical container of the product’s legality. It does not operate solely as a traceability repository. It functions as the active technical file that interacts with customs authorities and market surveillance agencies. This cross-cutting nature requires textile companies to observe the legal implications beyond their sector of activity.

The seven regulations affected and why together

The scope of the proposal intervenes surgically on the regulatory basis of the internal market. The texts amended jointly include Regulation (EU) 765/2008 on accreditation and market surveillance, Regulation (EU) 2016/424 on cableway installations, Regulation (EU) 2016/425 on personal protective equipment, Regulation (EU) 2016/426 on appliances burning gaseous fuels, Regulation (EU) 2023/1230 on machinery, Regulation (EU) 2023/1542 on batteries, and Regulation (EU) 2024/1781 on Ecodesign for Sustainable Products. In the fashion sector, attention is usually restricted to the sectoral texts, but the joint reading of these regulations is indispensable to understand the final technical architecture.

Grouping machinery, batteries, protective equipment and textiles in the same legislative package responds to the logic of the 2008 New Legislative Framework. This decision established reference provisions for the marketing of products in the Union. All these regulations share the structure of conformity assessment, the role of notified bodies and the requirement of CE marking.

One vector of this text is the introduction of « common specifications » as a legal safeguard. When the harmonised standards developed by bodies such as CEN or CENELEC do not exist, prove insufficient or are not published in the Official Journal of the European Union, the Commission may adopt implementing acts establishing these requirements. For the textile industry, this means that the technical deployment of the passport will not be blocked if standardisation suffers delays.

In the fashion context, a textile personal protective equipment item — such as high-visibility garments or flame-retardant equipment — will be subject simultaneously to Regulation 2016/425 and the ESPR 2024/1781. The obligation of both regulations will converge in a single digital passport, eliminating documentary duality.

The harmonisation of the Digital Product Passport format

The legal engineering of the proposal alters the documentary hierarchy of European articles. Article 4 of the proposed text, which amends the regulation on gas appliances, operates as a template for the equivalent amendments in the regulations on machinery, personal protective equipment and ecodesign. It consolidates a structural obligation: the information of the EU declaration of conformity and the instructions for use must be dumped natively into the product’s digital passport whenever the legislation requires its issuance. The DPP fully absorbs technical compliance.

This harmonisation impacts directly on data architecture. According to the CIRPASS D3.2 study and the D2.1 requirements mapping, the infrastructure will be based on decentralised identifiers or resolvers based on HTTP URIs. Requiring that the declaration of conformity reside in the DPP demands that the data schema support immutable legal semantics. The guidelines point to the strict use of the W3C Verifiable Credentials Data Model 2.0.

The underlying exchange format for these assertions will be JSON-LD. The architecture anticipates the need to map the legal requirements of different sectors with millimetric precision. The proposal requires building ontologies where the same graph node in RDF format expresses the material composition of the textile under ESPR and the applicable safety certification.

For textile operators, the impact is operational and profound. The passport will not consist solely of carbon footprint and recycled content data. It will contain a structured legal annex. The Commission stresses the figure of the « electronic contact » in the proposal. Manufacturers will have to include an online digital address to interact with customs authorities without requiring prior registration.

Friction points with the ESPR textile delegated act

The convergence imposed by the Commission’s document does not advance free of friction. The main tension falls on the legislative calendar and the specificity of fashion taxonomies. The ESPR Regulation establishes that the detailed requirements of the digital passport will be defined through delegated acts issued by product group. According to the methodological report JRC 145830, the textile delegated act will require precise traceability parameters. It will regulate the exact composition of fibres and the durability metrics. The critical point arises when synchronising this purely sectoral schema with the cross-cutting compliance architecture that the proposal imposes.

If the textile delegated act is consolidated with a data schema focused on environmental circularity before the industry assimilates the digitalisation requirements of the proposal COM(2025) 504, brands face a serious risk of double technical migration. First they would adapt their PLM systems to feed a sustainability DPP. Months later, they would have to refactor the data ontology to accommodate the EU declaration of conformity in JSON-LD format.

The Joint Research Centre study defines levels of granularity based on current data-collection practices. It distinguishes between model information, batch information and individual-item information. The proposal COM(2025) 504 raises the requirement by obliging the technical declaration of conformity to be linked to the passport. In conventional industrial sectors, conformity is linked to the batch.

The probable adoption calendar 2026-2027

The implementation timeline of the proposal defines the margin of manoeuvre of European manufacturing industry. Being a proposal that amends regulations in force, the text is subject to the ordinary legislative procedure. This requires a first reading in the European Parliament and in the Council of the European Union. This procedure consumes between six and twelve months in its initial phase, before advancing towards the institutional trilogues that will agree the final wording. Formal adoption is located in the 2026-2027 horizon, coinciding head-on with the publication window of the first ESPR delegated acts.

The synchronisation of the application dates is a pressure factor for brands. Article 8 of the proposed text establishes a temporary transitional provision of twenty-four months after the entry into force of the amending regulation. During this period, authorities may not prevent the marketing of products that conform to the previous versions of the affected texts on paper support. If the proposal is published in the Official Journal at the end of 2026, the strict obligation to digitalise the declaration of conformity in the DPP will be activated definitively towards 2028-2029.

This deadline overlaps precisely with the ESPR Working Plan 2025-2030 published as COM(2025) 187 final. This document ratifies the apparel and footwear sector as an initial priority, with the adoption of its delegated act scheduled for 2027. The temporal convergence obliges firms to plan their infrastructures assuming a scenario of maximum requirement. The digital passport they design in 2027 must be born prepared to ingest the mandatory legal documentation dictated by the proposal.

Anticipating harmonisation before the delegated act

The regulatory convergence imposed by the proposal COM(2025) 504 demonstrates that the digital passport will not be a static requirement, but a living infrastructure of continuous compliance. Brands cannot wait for the final publication of the delegated act to structure their data: the mismatch between legacy systems and verifiable credentials in JSON-LD format translates into a costly double technical migration for those who improvise.

For textile brands that want to reach their first DPP without paying for that rework: DPP Readiness — the TraceWeave module that is already born on the [CIRPASS](/recursos/glosario/cirpass-2-piloto-dpp) D2.1 schema and the cross-sectoral harmonisation of COM(2025) 504, ready to ingest the declaration of conformity when the textile delegated act is published. → Discover DPP Readiness