Your sustainability claims become a legal question on 27 September.

• You sell apparel, footwear or accessories into the EU under your own brand
• You use words like sustainable, eco, conscious or climate neutral anywhere customer-facing
• You import goods manufactured outside the EU
• Your material and origin data lives in supplier emails and spreadsheets
• Nobody in your company owns product compliance as a named responsibility

Under the ESPR the economic operator, meaning whoever places the product on the EU market, compiles the technical documentation, issues the EU Declaration of Conformity and carries the liability. There is no third-party certification scheme for the Digital Product Passport. Anproba provides preparation, data and platform services.

1. 01Day 1

   Scoping call

   Catalogue size, markets, which claims are live and who owns them internally. Fee is fixed at the end of this call, before any work starts.

2. 02Week 1

   Claims inventory

   We collect every customer-facing environmental statement: product pages, hangtags, packaging, campaigns, collection names, social.

3. 03Week 2

   Data gap analysis

   For each claim, what evidence the directive requires, whether you hold it, and whether what you hold would actually stand up.

4. 04Week 2–3

   Remediation plan

   Ranked by exposure, not by ease. Each item gets an owner, a date and a decision: substantiate, reword or withdraw.

5. 05Week 3

   Handover and walkthrough

   A working session with the people who will execute it, usually marketing and product together, because the fixes land in both.

EmpCo DirectiveDirective (EU) 2024/825

Shorthand for the EU directive on empowering consumers for the green transition. It amends EU consumer law to prohibit three commercial practices: generic environmental claims a trader cannot substantiate, sustainability labels not based on a third-party scheme or established by public authorities, and claims that a product is climate neutral on the basis of emissions offsetting. Member States had to transpose it by 27 March 2026 and the rules apply from 27 September 2026.

Generic environmental claim

A broad environmental statement made without a specified, substantiated property: "eco-friendly", "green", "conscious", "kind to the planet". The test is whether the trader can demonstrate recognised excellent environmental performance relevant to the claim. A specific, verifiable statement about a named property is a different thing and remains permitted.

Substantiation

The evidence behind a claim: specific, verifiable and held before the claim is published rather than assembled after it is challenged. For a textile claim this usually means supplier documentation tying a named property, such as fibre content, recycled share or country of manufacture, to the actual product being sold.

Self-created sustainability label

A sustainability marker a company devises for itself, such as an in-house eco icon, a green leaf badge or an own-brand sustainability rating, rather than one resting on a third-party scheme or established by public authorities. Displaying one becomes a prohibited commercial practice on 27 September 2026, however well founded the underlying work is.

Digital Product Passport (DPP)

A structured set of product data, reachable from the physical item and from online points of sale, that follows a product through its life. It has four parts: a unique identifier, a data carrier such as a QR code, hosted passport data with role-based access, and registration in the EU registry. The data stays with the economic operator; the registry holds identifiers and metadata.

ESPRRegulation (EU) 2024/1781

The Ecodesign for Sustainable Products Regulation, the framework law that introduces the Digital Product Passport and sets ecodesign requirements across product groups. The ESPR itself binds nobody in a given sector until a delegated act for that sector is adopted.

Delegated act

The secondary legislation that turns a framework regulation into concrete obligations for one product group. For textiles it will fix which data the passport must carry, the conformity procedures, and how long brands have to comply. The ESPR Working Plan 2025–2030 schedules adoption for late 2027; the compliance date is set inside the act itself, customarily 18 to 24 months later.

Economic operator

Whoever places a product on the EU market. Broadly, the party that first makes it available in the EU under their own name or brand. Importing from outside the EU usually puts a brand in this role. The obligations and the liability sit here, which is why it matters who in a supply chain actually holds the position.

EU Declaration of Conformity

The signed statement in which the economic operator declares that a product meets the applicable EU requirements, backed by technical documentation they compile and keep. It is issued by the party placing the product on the market, not by a supplier, a consultancy or a software provider.

Data carrier

The physical link between an item and its passport data, typically a QR code on the product or its label. The Commission expects the passport to be reachable both from the physical product and at online points of sale.