Digital Product Passport for footwear
Footwear is the clearest example of why you cannot reason about your obligations from the ESPR framework text alone — it was a named candidate, and the working plan deferred it.
Short answer. There is no scheduled footwear delegated act. The Commission separated footwear from textiles, citing distinct materials, functionality and supply chains, and commissioned a study due by the end of 2027 before reassessing. But footwear is in Annex VII, so the destruction ban on unsold stock has applied since 19 July 2026 for large enterprises.
What is in scope
ESPR Article 18 named “textiles, in particular garments and footwear” as a candidate product group. The working plan exercised the Commission's discretion and split them: textiles proceed with an indicative 2027 act, footwear does not.
The stated reasons were that footwear has distinct materials, functionality and supply chains compared with garments, and lower assessed impacts. A study is to be completed by the end of 2027, after which footwear will be reassessed for a future working plan.
Do not read “deferred” as “exempt”. Footwear is explicitly listed in Annex VII, which means the prohibition on destroying unsold stock and the annual disclosure duty have applied since 19 July 2026 for large enterprises. A footwear retailer can have no passport obligation at all and still be in breach of ESPR today.
Timeline for Footwear
- 16 April 2025 Working plan separates footwear from textiles and defers it, commissioning a study due end 2027.
- 19 July 2026 Destruction ban and disclosure duty apply to footwear for large enterprises, via Annex VII.
- 2 March 2027 Standardised disclosure template for unsold consumer goods applies.
- End 2027 Footwear study due for completion, after which the group is reassessed for a future working plan.
- 19 July 2030 Destruction ban and disclosure duty extend to medium-sized enterprises.
Data the passport has to carry
There is no footwear field list and no act to anticipate one from. What applies today is the ESPR framework's general data elements — which will apply to footwear whenever it is eventually covered — and, more importantly, the unsold-goods regime, which is not a passport obligation at all.
| Field | What it means in practice | Status |
|---|---|---|
| Unique product identifier | Persistent, connected to a data carrier on the product, its packaging or accompanying documentation. | In force |
| Unique operator identifiers | Manufacturer, other operators in the chain, and the EU-established responsible operator. Plus unique facility identifiers. | In force |
| Commodity codes | TARIC or equivalent, used at the customs verification step. | In force |
| Compliance documentation | Declaration of conformity, technical documentation, conformity certificates. | In force |
| Substances of concern | Name or code, location within the product, concentration or range, safe-use instructions and end-of-life handling. Framework-level under Article 7(5). | In force |
What this means if you sell footwear on PrestaShop
Your live obligation is the unsold-goods regime
If you are a large enterprise selling footwear, since 19 July 2026 you may not destroy unsold stock, subject to ten derogations, and you must publish annually on your own website the quantity and weight discarded, the reasons, the treatment routes, and your prevention measures. Micro and small enterprises are exempt; medium-sized enterprises have until 19 July 2030.
The derogation most likely to apply is stock not accepted for donation — which requires you to have offered it to at least three suitable social-economy entities in the EU, or offered it via your own website for at least eight weeks. Keep records for five years from the disclosure date.
Your passport obligation is nothing, for now
There is no scheduled act. Anyone selling you footwear DPP compliance software today is selling you a product for a regulation that does not exist and has not been scheduled.
And from September, your product copy
Directive (EU) 2024/825 applies from 27 September 2026 and bans generic environmental claims and offsetting-based carbon-neutrality claims. Footwear marketing is dense with exactly this language.
How to prepare now
Sort out discard reporting
Work out, concretely, what happens to unsold and returned footwear in your operation — including what your returns processor does with items graded unsellable. Many merchants do not know, and "we send it to a third party" is not an answer that survives a disclosure obligation.
Audit green claims before 27 September 2026
A firm date, entirely within your control.
Watch the study, not the calendar
The end-2027 study is the trigger for any future footwear act. Until it reports, there is nothing to prepare for.
Questions
Is footwear exempt from the DPP?
Why is footwear covered by the destruction ban but not the passport?
We sell both clothing and shoes. Does that simplify things?
Sources
Other product groups
Batteries
The only product group with a binding passport date already set. LMT, EV and industrial batteries above 2 kWh, from 18 February 2027.
Textiles & apparel
First named priority under ESPR, and already subject to the unsold-goods destruction ban that took effect in July 2026.
Tyres
A priority group with an indicative 2027 act, and one that already carries mandatory EU labelling.
Get the data before you need the passport
Whatever your product group, the bottleneck is the same: supplier data you do not have yet. The readiness checklist tells you what to start asking for.