These updates were provided to PPAI’s Product Responsibility Action Group during its June meeting by Karolyn Helda, QIMA, and Rick Brenner, Product Safety Advisors:

EU Digital Product Passport Update

The EU has published a study outlining future DPP requirements for textiles/apparel under the Ecodesign for Sustainable Products Regulation (ESPR), the EU framework under which digital product passports are being developed to provide regulators and consumers with more standardized product data and lifecycle information. Highlights of the study include:

  • Responsible party: The manufacturer or importer must ensure data is accurate, complete and uploaded to digital registry.
  • Expected DPP requirements for textiles:
    • Product ID and classification
    • Durability data (testing likely required, as with batteries)
    • Environmental footprint
    • Compliance docs: Declaration Of Conformity, technical specs, lab test results
  • Access is tiered: Consumers see limited data, market surveillance authorities get full visibility, and recyclers get content-specific data.
  • Timeline:
    • Mandatory digital registry operational: July 19, 2026
    • Delegated acts (detailed requirements): late 2026 or 2027
    • Full enforcement phased in: 2028 to 2030
  • The first six DPP technical architecture standards have been published:
    • EN 18216:2026 – Data exchange protocols
    • EN 18219:2026 – Unique identifiers
    • EN 18220:2026 – Data carriers
    • EN 18221:2026 – Data storage and persistence
    • EN 18222:2026 – APIs and lifecycle management
    • EN 18223:2026 – System interoperability


LEARN MORE: Attend the PPAI Responsibility Summit, September 14-16 in Denver.

U.S. Federal Legislative Update

  • Rep. Lloyd Doggett (D-Texas) introduced the TREE Act (HB 8744) that would ban the import and sale of goods linked to deforestation. The bill mirrors EU deforestation regulations and covers rubber and wood. Doggett is retiring at the end of this term, and the bill currently has no bipartisan co-sponsors, so it is unlikely to advance.


U.S. State Legislative Updates

  • Minnesota: Initial reports on intentionally added PFAS are still due September 15 under Amara’s Law, but an amendment excludes products manufactured before July 1, 2023, from reporting.
  • Michigan: The Hazardous Products Act (HB 5890) has been introduced to prohibit intentionally added PFAS in cosmetics, textiles, etc. The law would allow civil suits and class actions with minimum statutory damages of $500 plus attorney fees.
  • Ohio: A proposed amendment to the state’s Bedding and Stuffed Toys Act (HB 873) would update the definition of “secondhand” to exclude recycled/reclaimed materials, enabling recycled fill (e.g. rPET) in plush toys. Ohio and Massachusetts are the only states with all-new-material requirements.
  • California: July 1 is the registration deadline for companies with $1M+ global revenue selling textiles and apparel in California that are covered under SB 707, the Responsible Textile Recovery Act. (Register here.) A hearing for a lawsuit challenging the state’s selected Producer Responsibility Organization is not until August 7, more than a month after the registration deadline.


ICYMI: California Names Its Textile Producer Responsibility Organization

FDA Expands Approved Sunscreen Ingredients


New Online Regulatory Intelligence Report In Progress

A new, clickable resource for regulatory updates is being developed to aggregate information on CPSC  and FDA recalls, Prop 65 violations, state laws (PFAS, EPR, etc.), federal register updates and law firm articles on relevant product safety topics.

Recall & Product Safety Updates

Of an estimated two dozen CPSC recalls in the last 30 days for product types considered most relevant to the branded merchandise industry, almost half 24 are battery-related, especially button-cell batteries. (View CPSC’s Button Cell and Coin Battery Business Guidance.)

Prop 65 notices of violation for lead appear to have more than doubled year-to-date vs. 2025. Cadmium notices are up significantly, BPA is slightly up; notices for phthalates and PFAS are down. Compliance vigilance remains critical, especially for products going to California.

  • Bounty hunters are the primary driver of Prop 65 NOV volume, with one firm filing more than 4,000 NOVs since 2021.
  • Typical settlement about $100,000 total ($4,000 to the state, $96,000 to the attorney).


China’s Decree 834 and Decree 835

These sweeping new Chinese laws, effective in April, restrict foreign compliance requirements imposed on Chinese suppliers.

  • Buyers cannot cite foreign law (e.g. UFLPA, EU sustainability regulations) as basis for requesting supply chain data.
  • Social compliance failures are not valid grounds to exit a supplier relationship – only quality or delivery failures qualify.
  • CAP remediation can no longer be required; even language must be softened (“are you working on findings?” vs. “remediation”)
  • Audit reports must comply with Chinese law and should be assumed reviewable by Chinese authorities.

China has not issued guidance on the decrees yet, and the scope of enforcement is still unclear. Greater scrutiny is expected on critical sectors (e.g., minerals, medical supplies, semiconductors) than on apparel. This topic will be explored in depth during PPAI’s Responsibility Summit in September (register here).