If you place finished textile or apparel products on the EU market — including footwear and accessories, and including non-EU brands selling into the EU — you are in scope for the Digital Product Passport. Currently excluded are smart/e-textiles, PPE, medical devices, toys, and intermediate products such as yarns, fabrics, and fibres.
Scope follows the act of placing a finished product on the EU market. The exclusions matter, and the boundary cases are where brands get caught out.
Currently excluded
Smart and e-textiles, PPE, medical devices, toys, and intermediate products (yarns, fabrics, fibres).
The messy boundary cases
Items that blend categories — a bag with embedded electronics, a battery-powered accessory — sit on the edges of multiple regimes and need checking individually before you scope a programme.