Bangladesh and ESPR: Digital Product Passport Requirements for Bangladesh Exporters to the EU

ESPR Regulation (EU) 2024/1781 applies to all products placed on the EU market, regardless of where they are manufactured. Bangladesh exporters in Garments and ready-made garments (RMG), Textiles, Jute products and other sectors must comply with ESPR Digital Product Passport requirements before their products can enter the EU market after the applicable compliance dates. This page covers what Bangladesh manufacturers and exporters need to know about ESPR compliance.

Bangladesh's Export Profile and ESPR Exposure

Bangladesh exports to the EU include products across multiple ESPR-regulated categories. The key sectors affected are:

• Garments and ready-made garments (RMG)
• Textiles
• Jute products
• Leather and footwear

The EU is a major export destination for Bangladesh manufacturers. ESPR compliance is not optional for products destined for the EU market — it is a legal requirement that will be enforced at EU customs from 19 July 2026 for general DPP compliance, and from 18 February 2027 for the Battery Passport specifically.

ESPR Compliance Requirements for Bangladesh Manufacturers

Bangladesh manufacturers exporting to the EU must complete four steps before their products can legally enter the EU market after the applicable ESPR compliance dates. First, they must appoint an EU Authorised Representative — a natural or legal person established in the EU who is responsible for DPP registration, the EU Declaration of Conformity, and communication with EU market surveillance authorities. Second, they must compile technical documentation for each product model, demonstrating compliance with the applicable ecodesign requirements. Third, they must create a Digital Product Passport for each product model (or individual unit, where required) and register it with a compliant DPP registry. Fourth, they must affix a QR code data carrier to each product or its packaging, linking to the DPP record.

Key ESPR Deadlines for Bangladesh Exporters

EU Authorised Representative: What Bangladesh Manufacturers Need

Under ESPR Article 16, non-EU manufacturers must appoint an EU Authorised Representative before placing products on the EU market. The Authorised Representative must be a natural or legal person established in an EU member state. They are responsible for ensuring the DPP is registered, the EU Declaration of Conformity is drawn up, the technical documentation is compiled, and the CE marking is correctly affixed. The Authorised Representative must be named in the EU Declaration of Conformity and their contact details must be accessible via the DPP.

The Authorised Representative does not need to be the importer or distributor — they can be a specialist compliance service provider. Many Bangladesh manufacturers use EU-based compliance consultancies as their Authorised Representative. The cost of an Authorised Representative service typically ranges from €1,000–€5,000 per year depending on the number of product models and the complexity of the compliance requirements.

Digital Product Passport Registration for Bangladesh Exporters

Once the technical documentation is complete and the EU Declaration of Conformity is drawn up, Bangladesh manufacturers must register their products' Digital Product Passports with a compliant DPP registry. The registry assigns a unique DPP identifier to each product model (or unit, where required) and generates the GS1 Digital Link URL that is encoded in the product's QR code. The DPP data must be kept accurate and up-to-date throughout the product's lifetime — including updates to State of Health data for batteries and updates to spare parts availability for electronics.

Africa's first ESPR-compliant DPP registry — digitalproductpassports.co.za — is available to Bangladesh manufacturers and exporters. The registry supports all ESPR product categories and provides GS1 Digital Link-compliant QR code generation, JSON-LD data hosting, and EU Declaration of Conformity document management.

Bangladesh's ESPR Exposure: The Garment Industry's Biggest Compliance Challenge

Bangladesh is the world's second-largest garment exporter and the EU's largest supplier of ready-made garments (RMG). The EU accounts for approximately 60% of Bangladesh's garment exports. The textile delegated act will be the most significant ESPR development for Bangladesh — virtually the entire export economy is exposed.

The challenge for Bangladesh's garment industry is supply chain transparency. The ESPR textile DPP will require disclosure of manufacturing origin at each production stage, chemical use, carbon footprint, and recycled content. Many Bangladeshi garment manufacturers currently lack the data collection systems to provide this information. Building these systems will require investment in factory-level data collection, third-party auditing, and DPP registration infrastructure.

The Bangladesh Garment Manufacturers and Exporters Association (BGMEA) has begun engaging with ESPR requirements, but the industry-wide compliance infrastructure is not yet in place. Manufacturers who begin compliance preparation now will have a significant competitive advantage when the textile DPP becomes mandatory.

Bangladesh's ESPR Exposure: The Garment Industry

Bangladesh is the EU's second-largest garment supplier after China, exporting approximately €20 billion of clothing and textiles to the EU annually. The ESPR textile delegated act will have a direct and significant impact on Bangladesh's garment industry. Bangladeshi garment manufacturers must prepare for DPP requirements covering fibre composition, recycled content, carbon footprint, water consumption, chemical treatments, and supply chain traceability.

The carbon footprint requirement is particularly challenging for Bangladeshi garment manufacturers. Bangladesh's electricity grid is heavily dependent on natural gas and diesel, resulting in a high carbon footprint for electricity-intensive manufacturing processes such as dyeing and finishing. Bangladeshi manufacturers who invest in renewable energy for their production facilities will have a competitive advantage as ESPR carbon footprint requirements enter into force.

Supply Chain Traceability: The Key Challenge

Supply chain traceability is the most challenging aspect of ESPR compliance for Bangladeshi garment manufacturers. A typical Bangladeshi garment factory sources fabric from multiple suppliers in Bangladesh, India, and China, and uses dyes and chemicals from suppliers in Germany, Switzerland, and other countries. Collecting accurate traceability data for all these supply chain stages requires engagement with multiple suppliers across multiple countries, many of whom may not have the systems or the incentive to provide it.

EU Sustainability Requirements and Bangladesh's Competitive Position

ESPR requirements will create both challenges and opportunities for Bangladesh's garment industry. Manufacturers who invest in sustainability — renewable energy, recycled fibre sourcing, chemical management, supply chain traceability — will be better positioned to meet ESPR requirements and to compete for EU buyers who prioritise sustainability. Manufacturers who do not invest in sustainability risk losing EU market access as ESPR requirements enter into force.