Textile
The DPP for Footwear
Footwear is outside ESPR's first textile wave but inside the destruction ban. What footwear manufacturers should prepare, and when the rules are likely to arrive.
Footwear sits in an odd position in the ESPR debate: it is inside the unsold-goods destruction ban but outside the first textile DPP wave. That distinction is one of the most frequently confused points in the sector.
Why not in the first wave?
The Working Plan limited the first phase of the textile delegated act to apparel and accessories. Footwear has a different material and production structure and needs separate preparatory work. This is sequencing, not exemption. See the ESPR working plan.
Material complexity
A trainer can contain more than 20 distinct materials:
| Component | Typical material | Declaration difficulty |
|---|---|---|
| Upper | Leather, textile, synthetic | Medium |
| Lining | Textile, foam | Medium |
| Midsole | EVA, PU | High (formulation) |
| Outsole | Rubber, TPU | High |
| Adhesive | Solvent or water based | Very high (chemical) |
| Trims | Laces, metal parts | Low |
That structure forces the bill of materials down to material level. See preparing a bill of materials.
Chemical declarations
Adhesives, dyes and surface treatments can contain substances restricted under REACH. SVHC notification and SCIP database duties arise more often in footwear than in apparel. See DPP for chemicals, REACH and SCIP.
The circularity challenge
Footwear is hard to recycle by design: different materials are bonded with adhesives and cannot be separated. A DPP's circularity fields make exactly that visible — and put pressure on design. See circularity and recyclability.
What to do now
- Comply with the destruction ban: map your unsold stock flows today. See the destruction ban.
- Build a material-level BOM before the first wave arrives.
- Collect adhesive and chemical declarations: the longest lead item.
- Track buyer requests: brands ask ahead of regulation. See what retailers ask suppliers for.
Frequently asked questions
Will footwear never get a DPP?
It is expected to. Being outside the first wave means deferred, not excluded.
Are there extra duties for leather?
Origin and chemical processing data are prominent in leather chains, and EUDR can apply to deforestation-linked commodities. See EUDR.
Does my apparel preparation transfer?
Yes. Identity, origin, certificate and supplier data processes are largely shared. See the textile DPP guide.
