Footwear under ESPR and the Digital Product Passport
Footwear is outside the first Working Plan, and a delegated act could follow a scoping study expected by late 2027. Large footwear enterprises already face the confirmed Article 25 destruction ban on unsold goods from 19 July 2026.
Key dates for this sector
9 February 2026
Locked
Locked
Article 25 unsold-product rules finalized: derogations act Reg. (EU) 2026/296 and disclosure-format act Reg. (EU) 2026/2.
Watch items
- The Article 25 destruction ban applies to large enterprises for unsold footwear from 19 July 2026, and any derogation requires five-year record-keeping. Locked
- The ESPR delegated act for footwear is not in the first Working Plan; earliest realistic compliance would be 2030 or later. Signaled
What to do now
Large enterprises with unsold footwear inventory should focus on Article 25 compliance; no ESPR DPP action is required yet, but watch the scoping study expected late 2027.
Sources: Reg. (EU) 2026/296: Article 25 Derogations · COM(2025) 187: Working Plan · Verified 10 August 2026
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Frequently Asked Questions
When does ESPR apply to footwear?
Signaled: not in first Working Plan; scoping study expected late 2027. Key date: Scoping study expected late 2027. This timeline is signaled, not an adopted act; plan against date ranges rather than fixed deadlines.
What should footwear companies watch?
The Article 25 destruction ban applies to large enterprises for unsold footwear from 19 July 2026, and any derogation requires five-year record-keeping. The ESPR delegated act for footwear is not in the first Working Plan; earliest realistic compliance would be 2030 or later.
What should footwear companies do now?
Large enterprises with unsold footwear inventory should focus on Article 25 compliance; no ESPR DPP action is required yet, but watch the scoping study expected late 2027.