How do I demonstrate the share of recycled fibre?
No fixed method yet for the share of recycled fibre
You show the share of recycled fibre using a calculation or measurement method that the European Commission still has to establish in a delegated act under the ESPR; that method must meet the requirements for test, measurement and calculation methods set out in Article 39 of the ESPR (Regulation (EU) 2024/1781). Until that act is in place, it is not fixed which percentage, which test standard or which control method is used to substantiate a claim about recycled material. The digital product passport itself, governed by Article 10 of the same regulation, determines that a passport contains product information based on reliable data, but leaves the precise content per product group to separate, product-specific rules. For clothing and textiles, that product-specific implementation does not yet exist. What does exist is the framework: if a method comes, it must be demonstrable, accurate and reproducible, and align as much as possible with existing harmonised standards.
For clothing and textiles, not for raw material or marketing text
This subject concerns clothing and textile products falling under the ESPR work plan, with clothing of which eighty per cent or more consists of textile fibres as the first category to be addressed. It does not concern individual yarns, fibres or raw materials not yet processed into a finished product — these may be addressed at another time or through another act. It also does not concern a claim that a brand currently places on a label or website without reference to the digital product passport; that is a different matter from the question of how the share of recycled material is established and substantiated in the passport itself. And it is not an obligation that currently stands anywhere in concrete terms: it is a component expected to be filled in once the product-specific delegated act for textiles is published.
Date not yet fixed, framework is
When a substantiation requirement for the share of recycled fibre becomes concrete is not yet fixed. Within the ESPR work plan for the period 2025-2030, a delegated act for textiles is expected in 2027, with clothing of which eighty per cent or more consists of textile fibres as the first category. Once that act is published, it will become clear which method applies and from when it is applicable. Until then, there is no legally prescribed ESPR method to substantiate the share of recycled material. Undertakings that already work with recycled material and wish to demonstrate this do so on the basis of their own records, supplier declarations or existing certification systems — not on the basis of a method that follows from the ESPR itself, as that does not yet exist.
What this means for building the file
In practical terms, the sequence is as follows. First: record data on fibre composition and the origin of recycled material with the manufacturer, supplier or importer, regardless of whether a mandatory method already exists — that basis is needed as soon as one does exist. Next: retain which sources, certificates or declarations underlie that data, so that there is a trail back to the original information later. Then: once the delegated act for textiles is published, the already recorded data can be checked against the test method then applicable and supplemented if necessary. Texpas.eu processes in this process the data supplied by the manufacturer or importer into a passport and adjusts the statement on the share of recycled material as soon as the official method is known — responsibility for the accuracy of the underlying data remains with the party that supplies it.
What this is based on: Article 10 and Article 39 of the ESPR
Article 10 of the ESPR determines in general terms which requirements apply to the content and functioning of the digital product passport: the passport contains product information, but the precise specification per product group — including clothing and textiles — follows from separate, product-specific delegated acts that have yet to be published. Article 39 of the ESPR determines that where test, measurement or calculation methods are necessary to meet requirements, those methods must be reliable, accurate and reproducible and based as far as possible on harmonised standards. Together, these articles form the framework within which a future method for the proportion of recycled fibre must fit, without that method itself being yet established. The concrete specification for textiles follows from the product-specific delegated act announced in the ESPR work plan for this category.
If you are already working with recycled material now, you can gain the most by putting the origin and substantiation of that material in order with the supplier or manufacturer, so that information is ready as soon as the official method becomes known — texpas.eu will then process that data in the passport and update the statement as soon as the delegated act for textiles is published.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
The regulation itself is available on EUR-Lex. We provide references for each statement; you do not need to take our word for it.
What you must do concretely
What is expected of you
State the share of recycled fibre accurately and substantiated
The digital product passport requires product information based on the actual composition of the clothing item. Article 10 of the ESPR (Regulation (EU) 2024/1781) stipulates that the data in the passport must be accurate, complete and up to date. For a share of recycled fibre, this means in practice: the percentage shown in the passport must be traceable to a substantiation that the manufacturer or importer can demonstrate themselves. For a company with 10 to 100 employees, this usually amounts to collecting the correct documentation from the supplier before the percentage is entered in the passport — not reconstructing it afterwards.
Measure and calculate according to a fixed method
Article 39 of the ESPR addresses the test, measurement and calculation methods used to determine the values in the passport. Once a method is designated for textiles, it serves as the basis for how the share of recycled fibre is determined and not the manufacturer's own calculation method or an estimate from the supplier. For a clothing company, this means that the choice of a test method or certification system is not an internal decision separate from the regulation: that choice must align with what is prescribed. More on how those methods work is on the page on the method by which values for the passport are measured.
Distinguish the origin of recycled material
A share of recycled fibre can come from different sources: pre-consumer waste (residual material from production processes) or post-consumer waste (used clothing or textiles). The passport asks not only for a percentage, but for data that aligns with the broader fibre composition of the product. This directly touches on the question of how the fibre composition in the product passport is determined: the share of recycled fibre is in practice part of that same composition, not a separate figure alongside it. For a company of modest size, this means that the administration of fibre origin and the administration of recycled share preferably come together in one system, to avoid contradictory figures.
Be able to demonstrate substantiation without disclosing business data
The substantiation of a share of recycled fibre often contains information that a manufacturer does not want to share readily with everyone consulting the passport, such as the name of a specific supplier or an internal test report. The passport itself shows the percentage, but does not automatically show every underlying document. What is and is not publicly visible is linked to the question who may access which data from the digital product passport and to the question of whether certain substantiation can be treated as commercially sensitive. That distinction between the published percentage and the underlying evidence is often new territory for smaller companies, because internal quality documents were previously not linked to a publicly accessible passport.
Where things go wrong in practice
A common situation is that a supplier states a percentage of recycled material on a product sheet without a certificate or test report attached to it. The company placing the clothing item on the market takes that figure over into the passport, while the substantiation is actually lacking.
Another situation: different batches of the same clothing item come from different suppliers or production locations, with a slightly different share of recycled material per batch. When the passport shows one fixed percentage for the entire article, this no longer aligns with the actual composition of each individual batch.
It also happens that a company adds up pre-consumer waste material and post-consumer recycled material into a single percentage without it being clear which calculation method was used. Once a fixed method under Article 39 of the ESPR applies, a company's own calculation method may deviate from what is expected.
A fourth situation arises when the composition of a collection item changes during a season — for example because a supplier switches to a different yarn source — while the passport still shows the original percentage. This raises the question how current the data in the passport must remain: a percentage entered once is not a permanent record.
Finally, it happens that a company keeps a certification mark certificate as the only substantiation, without it being clear which part of the certificate specifically concerns the share of recycled fibre and which part concerns other aspects, such as chemical treatment of the material.
What you can record
- The certificate or test report from the supplier in which the share of recycled fibre per batch or delivery is stated, with a clear date and batch reference.
- An internal note on the calculation method used, so that it is traceable how pre-consumer and post-consumer shares were processed into the percentage in the passport.
- An overview of the test method used or the certification system, linked to what follows from Article 39 of the ESPR once this is developed for textiles.
- An agreement with suppliers on the provision of substantiation with each new batch or collection change, including a fixed moment when this data is reviewed.
- An internal template in which fibre composition and share of recycled material are recorded together, so that these data do not end up separately in different systems.
- A classification of which substantiation documents are commercially sensitive and which data ultimately become visible in the public passport.
This is not legal advice. This page provides general information about the regulations that this platform covers. We are not familiar with your situation. If you are in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-08-22. Is something wrong? Let us know — corrections are given priority.