DPP vs CE marking for textile products: what is actually different

A recurring confusion in the run-up to ESPR is whether the Digital Product Passport is going to replace CE marking, layer on top of it, or apply to different products entirely. The short answer is: they cover different things, they apply to different (though sometimes overlapping) product categories, and they will coexist. This post walks through the actual scope of each so a UK textile brand can plan for both correctly.

What CE marking covers for textile products

CE marking is a declaration that a product meets specific EU harmonised requirements for health, safety, and environmental protection. For textile products specifically:

• Personal protective equipment (PPE) under Regulation 2016/425. This covers Category I (minimal risk), Category II (moderate risk), and Category III (mortal danger) PPE. Category II and III require third-party conformity assessment.
• Medical devices (some technical textiles) under Regulation 2017/745
• Toys with textile components under Directive 2009/48/EC

Standard consumer apparel, footwear, and home textiles are not CE marked. A cotton T-shirt sold in the EU does not carry CE. A hi-vis workwear jacket classified as Category II PPE does.

What the DPP covers for textile products

The Digital Product Passport under ESPR covers a much broader scope than CE marking for textiles. The expected in-scope categories for the textile delegated act:

• Apparel (all consumer garments)
• Footwear
• Clothing accessories (bags, belts, hats)
• Home textiles (bedding, towels, upholstery fabrics)
• Workwear (whether or not classified as PPE)
• Technical textiles (some categories)

The DPP is not a conformity declaration. It records information: material composition, origin, care instructions, durability, chemical declarations, recycled content, end-of-life routing.

How they overlap

A PPE workwear jacket sold in the EU may carry both:

• CE marking with the four-digit notified body number, declaring conformity with Regulation 2016/425
• A GS1 Digital Link QR code pointing at the DPP with material composition, origin, and end-of-life routing

The CE mark and the DPP QR code are separate marks on the product or its label. They convey different information. A consumer scanning the QR code gets the DPP; a regulator inspecting the product sees both marks.

What CE was never designed for

CE marking is a point-in-time declaration by the manufacturer that a specific product complies with specific safety requirements. It does not:

• Track supply-chain provenance
• Support post-sale repair, resale, or take-back routing
• Provide consumer-facing material composition disclosure
• Enable interoperable data exchange between the brand, distributors, retailers, and end-of-life processors

The DPP is designed for exactly those functions, which is why it is not a replacement for CE marking.

The UKCA question for UK sales

UKCA is the UK's post-Brexit equivalent of CE marking for products placed on the UK market. The UK Government has repeatedly delayed the phase-out of CE marking recognition in Great Britain; as of mid-2026 CE marking remains acceptable for most product categories sold in Great Britain, with UKCA required for a narrowing set. Check the current UK Government guidance for your specific product category.

For textile products, most standard consumer apparel needs neither CE nor UKCA. PPE workwear needs one or the other depending on where sold.

What UK brands should do

Two separate compliance workstreams if you sell PPE workwear or other CE-relevant textile categories:

1. Continue existing CE compliance for any product categories where it applies. Notified body assessments, technical file maintenance, CE declaration of conformity.
2. Add DPP compliance on the same timeline as any other textile brand. Supplier data collection, GS1 Digital Link QR code, passport platform.

If you only sell standard consumer apparel (no PPE, no medical textile), CE marking probably does not apply and you can focus on DPP alone.

Where Filovera fits

Filovera issues Digital Product Passports and does not handle CE conformity assessment (that is a separate specialist service typically involving a notified body). The DPP data model can carry CE declaration references (notified body number, applicable regulation, date of assessment) so that a passport for a PPE product includes the CE conformity context for consumers and regulators who query the QR code.

For the broader UK textile compliance workload, see /uk/uk-textile-compliance-2026-checklist.

CE marking and the DPP are both EU instruments; for how the rest of the world handles product-level compliance, see the country-by-country DPP guide.