EU product compliance · Footwear

Digital Product Passport for Footwear

EU labelling and sustainability rules are expanding to footwear. Footwear must comply with existing EU labelling rules under Directive 94/11/EC and REACH chemical restrictions. There is no ESPR delegated act for footwear, so no passport is required. What does apply already: since 19 July 2026 large enterprises may not destroy unsold footwear under ESPR Art. 25(1) and Annex VII.

ESPR passport status

No adopted rule

Footwear labelling

94/11/EC

Destruction ban, large firms

19 Jul 2026

Applicable EU regulations

Regulations covering footwear

Ecodesign for Sustainable Products Regulation

(EU) 2024/1781 (ESPR)

Active

Framework regulation. Footwear may be covered alongside textiles in a future delegated act, but none has been adopted. The Art. 25 destruction ban already covers footwear for large enterprises.

Key articles

  • Art. 9 - Passport mandatory only via an Art. 4 delegated act
  • Art. 25 and Annex VII - Destruction ban, live since 19 July 2026

Footwear Labelling Directive

Directive 94/11/EC

Active

Requires labelling of footwear with material composition of upper, lining, and outer sole using standard pictograms or text.

REACH Regulation

(EC) No 1907/2006

Active

Restricts chemicals in footwear including chromium VI in leather, certain dyes, and other substances of concern.

Key articles

  • Annex XVII - Entry 47 (chromium VI)
  • Art. 33 - SVHC communication

Key dates

Compliance timeline for footwear

Each entry is tagged with how firm it is. Binding means the date is fixed in the Official Journal. Adopted means the instrument exists but the date has not arrived. Indicative means it comes from a Commission working plan or our own estimate and is not law.

In force

Binding

Footwear Labelling Directive

Directive 94/11/EC requires material composition labels for the upper, lining and outer sole on all footwear sold in the EU.

Directive 94/11/EC, as transposed by your Member State

18 Jul 2024

Binding

ESPR enters into force

Framework law only. It creates no passport obligation for footwear.

Reg. (EU) 2024/1781

19 Jul 2026

Binding

Destruction ban applies to large enterprises

Large enterprises may no longer destroy unsold footwear. Medium-sized enterprises follow on 19 July 2030; micro and small are exempt.

ESPR Art. 25(1) and Annex VII; Delegated Reg. (EU) 2026/296

Not scheduled

Indicative, not law

Footwear passport delegated act

No footwear DPP delegated act has been adopted and no adoption date has been fixed. Footwear would most likely be handled alongside textiles, which are themselves unlikely to apply before mid-2029.

ESPR Art. 9(1) requires an Art. 4 delegated act; none adopted

What compliance reviewers look for

DPP data requirements for footwear

Where no delegated act has been adopted for this category, the list below is our reading of the likely data set, not a legal requirement. Collecting it early is still the work that takes the longest. Everything below is supported out of the box in LabelEU.

Materials and composition

  • Upper material (leather, textile, synthetic)
  • Lining and sock material
  • Outer sole material
  • Recycled content share per component

Chemical safety and origin

  • Chromium VI compliance (< 3 mg/kg)
  • REACH SVHC declaration
  • Country of manufacture
  • Supply chain traceability data

Durability and circularity

  • Durability testing results or rating
  • Repair and resoling information
  • End-of-life collection and recycling guidance
  • GS1 Digital Link URL and QR code

How LabelEU helps

Built for footwear compliance

Component-level materials

Record materials separately for upper, lining, insole, and outer sole, matching the structure required by Directive 94/11/EC.

Chemical compliance tracking

Track chromium VI levels in leather, restricted dyes, and REACH SVHCs with threshold alerts for each substance.

Durability and repair data

Add flex resistance, abrasion test results, and resoling instructions. Show consumers the longevity and repairability of your products.

Product examples

Common footwear and their key requirements

Leather dress shoes

  • Leather type and chromium VI compliance
  • Upper/lining/sole material labels
  • Resoling and repair information

Running shoes

  • Synthetic material breakdown
  • Recycled content per component
  • Durability test results

Children's sandals

  • Chemical migration safety (REACH)
  • Material composition labelling
  • Country of origin and traceability

Frequently asked questions

Common questions about Digital Product Passports for footwear.

Ready to create footwear passports?

Ship the QR with confidence today and keep updating the passport as your supply chain evolves.

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