Digital Product Passport by country: where the EU, UK, US, and China stand for 2026-2028

Quick answer. In 2026 only the EU has a binding Digital Product Passport regime. The UK is consulting. The US has a patchwork of state EPR laws and the FTC Green Guides. China is moving in the opposite direction with new data restrictions. A textile brand selling globally should build its dataset to the EU standard (it is the deepest) and reuse that data to satisfy California SB 707, the CMA Green Claims Code, and FTC enforcement. Building one dataset beats running four parallel compliance projects.

Almost everything written about the Digital Product Passport assumes you sell in Europe and stops at the EU border. That is fine if you are a Berlin-based label with two warehouses in Hamburg. It is not fine if you sell in London, New York, and Shanghai. Each of those markets has its own rule set with its own deadline, its own scope, and (in the case of China) its own active hostility to the kind of transparency the EU is asking for.

This guide is a snapshot of where each major market actually stands on DPP-style regulation as of June 2026. We have tried to be specific about article numbers, dates, and what counts as "in force" versus "expected." If you are reading this in 2027 some of these dates will have moved. Check the relevant regulator before you act on them.

Why a country-by-country guide

The Digital Product Passport is one shape of a wider trend: governments are using product-level data to enforce environmental and social standards that they cannot enforce at the supplier level. Different jurisdictions have reached for different tools to do the same job. The EU built a single horizontal regulation. The US has gone state by state. The UK has gone soft-law first and is now circling back to harder rules. China has built data restrictions that frustrate the transparency model entirely.

If your brand sells across two or more of these markets, you are not picking one regime to comply with. You are running parallel compliance tracks. Knowing where each track currently sits decides how much of your data work you can do once versus the parts you have to redo for each region.

EU: ESPR and the textile delegated act

The Ecodesign for Sustainable Products Regulation (ESPR) entered into force on 18 July 2024 and became operationally live on 19 July 2026. On the same day the European Commission switched on the EU Central DPP Registry, the database every passport now has to register against.

Three pieces of the framework regulation are already binding:

1. Destruction of unsold apparel and footwear is banned from 19 July 2026 for large enterprises (Article 25 of ESPR). Small and medium enterprises get a phased grace period that closes mid-2030.
2. Green public procurement rules apply to Member-State purchasing from 2026 onward.
3. The DPP registry and CEN/CENELEC technical standards are live, so any sector whose delegated act has published can be operated against.

The textile delegated act is the missing piece. The Commission's Working Plan 2025 to 2030 lists textiles and apparel for 2027 adoption (indicative). The JRC preparatory study on textiles reached its third milestone in December 2025. Most observers expect publication between late 2026 and Q2 2027, with an 18-month transition window. Practical compliance for textile brands lands around mid to late 2028. The same Working Plan schedules electronics for 2026 to 2027, tyres and aluminium for 2027, and furniture and construction for 2028.

If you sell textiles into the EU, the dates worth writing on the wall are:

• 19 July 2026: destruction ban live, registry live, framework binding.
• Late 2026 to Q2 2027: textile delegated act published.
• Mid 2028 to late 2028: first operative deadline for textile DPPs.

If you want a deeper walk through what the textile passport will actually contain at the data-field level, the ESPR for small textile brands post covers the 126-field draft from the Trace4Value pilot.

UK: post-Brexit alignment uncertainty

The UK has no Digital Product Passport law. It has signalled three softer instruments instead.

Defra's textile EPR pilot. Between 2023 and 2024 Defra funded a £150,000 industry-led pilot run with the UK Fashion and Textiles Association, the British Fashion Council, and the British Retail Consortium. The pilot studied an extended-producer-responsibility model for textile waste. As of late 2025 the consultation on mandatory take-back, separate collection, and waste reporting had not opened. Expectation is that it opens during 2026.

CMA Green Claims Code. On 22 January 2026 the Competition and Markets Authority issued strengthened guidance on environmental claims under the Digital Markets, Competition and Consumers Act 2024. Two pieces matter for textile brands:

• The CMA can now directly enforce consumer protection law and issue fines up to 10 percent of global annual turnover, or £300,000 if greater, with daily penalties for continuing non-compliance.
• Liability extends across the supply chain. A retailer that repeats a supplier's environmental claim is treated as having made the claim. Brands must take "reasonable steps" to verify the data behind any green statement they pass on.

In practice the CMA Green Claims Code does the job of a passport for the moment: if you make any claim about sustainability, recycled content, or origin on a UK product, you need verifiable data behind it. The mechanism is different from a DPP (a complaint-led enforcement model rather than a registry-based one), but the underlying data requirement is similar.

Eventual ESPR alignment. The UK government has not committed to transposing ESPR. The pragmatic expectation in the industry is that London will align partially during 2027 to 2028, either through a domestic Product Sustainability and Eco-Design framework or through equivalence recognition for goods placed on both markets. If you sell in both Great Britain and the EU, the cleanest planning assumption is to build for ESPR and treat UK compliance as a subset.

United States: a patchwork of state and federal rules

There is no federal DPP in the US. There are four moving pieces that together do part of what a passport would do.

California SB 707 (Responsible Textile Recovery Act of 2024). Signed in September 2024 and now the first statewide textile extended-producer-responsibility programme in the country. The 2026 schedule:

• 27 February 2026: CalRecycle approved Landbell USA as the Producer Responsibility Organisation (PRO).
• 1 July 2026: registration with the PRO opens for any producer with more than 1 million dollars in annual global sales that places apparel or textile products on the California market.
• 2026 to 2027 cycle: flat 1,000 dollar annual registration fee funds a statewide Needs Assessment.
• 1 July 2030: full programme implementation.

SB 707 is not a passport. It is an EPR scheme. The producer pays for end-of-life management and reports on what was placed on the market. The data requirement is lighter than ESPR but the producer definition is broad: brand owners, importers, and own-brand retailers are all in scope.

New York Fashion Sustainability and Social Accountability Act. Re-introduced for the 2025 session as S4558A and A4631B. The Assembly did not vote on the Fashion Act before the 2026 session closed, so it has not passed. If enacted it would require fashion companies with global revenue above 100 million dollars doing business in New York to map and disclose supply chains from raw material through production, set Paris-aligned climate targets, and contribute to a remediation fund. A re-introduction in 2027 is likely. Brands that meet the threshold should plan as if it will pass, because the data work to comply with it overlaps heavily with ESPR.

FTC Green Guides. Last finalised in 2012, with a revised version proposed in late 2022 and still pending as of June 2026. The FTC has signalled that a refresh is expected later in 2026, though leadership changes have repeatedly pushed the date. Even without the update, enforcement under the existing guides has been active: consent decrees in 2024 and 2025 against carbon-neutral, biodegradable, and unqualified recyclability claims set the substantiation bar. Any claim on a label or product page has to be supported by competent and reliable evidence (Section 260.2 of the existing Guides).

The patchwork problem. A US brand selling nationwide already has to satisfy California SB 707 reporting, FTC substantiation for any claim, the New York Fashion Act if it passes, and state-level chemical disclosure rules in California (Proposition 65) and Washington (Safer Products for Washington). None of these alone is a Digital Product Passport. Together they reach roughly two-thirds of what an ESPR-grade dataset would already cover.

China: GB/T standards and the social-credit overlay

China's textile labelling regime sits inside the GB and GB/T standards system. The mandatory parts are:

• GB 18401: national basic safety standard for textile products. Hard mandatory for any textile sold in mainland China.
• GB 5296.4: mandatory care-labelling and instruction marking for textiles and apparel sold domestically.
• A growing list of voluntary GB/T standards (with GB/T 5296.4 as the recommendatory counterpart) covering fibre content declaration, traceability, and recycled content claims.

What changed in 2026 is the layer on top. State Council Decree No. 834 on industrial and supply chain security came into force on 7 April 2026 with no transition period. Article 13 restricts in-country information gathering related to supply chains, which directly affects ESG due diligence, supplier audits, and Tier 2 and Tier 3 traceability work performed by foreign brands inside China. The same regulation gives the State Council broad countermeasure authority over foreign actors.

The practical effect is the opposite of a Digital Product Passport. Western transparency rules ask brands to publish more about their Chinese suppliers. Decree No. 834 makes collecting that data riskier. Brands sourcing from China should expect more reliance on certified third-party verifiers, less direct supplier audit data, and growing tension between EU ESPR reporting expectations and Chinese data restrictions.

China has not announced a Digital Product Passport equivalent and there is no public consultation on one as of June 2026. What it has built is the apparatus to score, restrict, and penalise supply chain behaviour through the corporate social credit system, which operates on data the state collects rather than data the brand publishes. That is a different model and it is not converging with the EU approach.

Honorable mentions: Australia, Canada, Japan, India

Australia. Consultations on reforms to the federal Modern Slavery Act began in late 2024 and decisions are expected during 2026. The Anti-Slavery Commissioner has recommended a mandatory risk-based due diligence obligation and a power to declare specific products or industries as high-risk. Cotton and textiles are explicitly named as primary targets. Fashion brands selling in Australia with annual consolidated revenue above 100 million Australian dollars already report under the existing Act; the 2026 reform is expected to add diligence and remediation duties on top.

Canada. Bill S-211 (Fighting Against Forced Labour and Child Labour in Supply Chains Act) has been in force since 1 January 2024. The 2026 annual report was due by 31 May 2026 for any reporting entity with at least 20 million Canadian dollars in assets, 40 million in revenue, or 250 employees. The Act is a disclosure regime, not a passport, but the supply chain mapping required to file overlaps with ESPR Tier 1 and Tier 2 traceability.

Japan. No DPP legislation in train. The METI Guidelines on Respect for Human Rights in Responsible Supply Chains (revised 2024) operate as soft law. Japanese brands targeting the EU market are preparing for ESPR; the domestic market is not driving its own requirements.

India. No DPP legislation. The Quality Control Order regime under the Bureau of Indian Standards is the current quality and safety baseline. Indian exporters to the EU are increasingly receiving DPP-readiness clauses from European buyers, which is pulling ESPR-style data work into the supplier base even without a domestic rule.

For brands selling globally: what to build first

If you sell textiles across the EU, the UK, and the US, the order to tackle compliance is not the order regulators rolled the rules out. It is the order driven by data dependency.

Build the EU dataset first. ESPR has the deepest field requirement (the Trace4Value pilot landed on roughly 126 data points across composition, origin, durability, circularity, and chemical content). Every other regime asks for a subset of that. Building once at EU depth means you have most of California SB 707 producer registration, CMA Green Claims Code substantiation, FTC Green Guides backing, and Bill S-211 supply chain mapping already covered.

Pick stable identifiers next. A textile DPP only works if every product has a persistent unique identifier and every supplier has one too. GS1 Digital Link is the standard the EU has effectively chosen. We wrote a longer piece on GS1 Digital Link for textile DPP for the detail. Using GS1 identifiers gives you portability into California's PRO registration data model and into any future UK scheme that aligns with ESPR.

Decide where the data lives third. This is where the build-or-buy question becomes regional. A US-only brand can defer this longer than a brand selling into the EU. We covered the trade-off in build or buy a Digital Product Passport. The short version: if you are SMB-sized and selling in more than one of these regions, a hosted platform is faster than building.

Then layer regional add-ons. California SB 707 needs producer registration and end-of-life reporting, not full passport data. The CMA Green Claims Code needs evidence files for any claim you make on UK product pages. Bill S-211 needs an annual report. None of these are heavy lifts on top of an EU dataset; each is heavy if you start from scratch when the regional deadline lands.

The regulatory map looks fragmented because it is. The data map underneath does not have to be. The brands that come out of the 2026 to 2028 window in good shape will be the ones that decided early to build the data once and route it to each regulator on its own deadline.