the product passport also applies to shoes, bags and belts

What you must do concretely

What is expected of you

The ESPR is a framework regulation: Article 1 makes clear that the regulation itself contains no direct obligation per product group, but lays the foundation on which it is determined separately per product group what will apply. For clothing and textiles, that process has progressed furthest, but shoes, bags and belts are not "textile" in the sense in which this platform treats them — and that distinction is relevant for these products.

Determining whether the product contains textile fibres or not

Article 2 of the ESPR (definitions) works with a broad product description that in principle can encompass virtually any physical product. Whether a product group actually receives obligations depends on the delegated act that the European Commission draws up for it. For clothing, the starting point so far is: clothing with a share of textile fibres of eighty percent or more. A leather bag or a leather belt without significant textile content falls outside that description. A canvas bag with a leather strap, or a sneaker with a textile upper, is less clear — determining what the main material is and how the future act for footwear and accessories will delineate that is something to keep following. A company that carries both clothing and bags or shoes does well to determine per article group which material category it falls under, rather than having to reconstruct that later.

Keeping your own assortment breakdown current

For a company with 10 to 100 employees, this primarily means: organizing the product catalogue so that material composition is findable per item or item group, not only when a specific enquiry comes in. If a company sells clothing, bags and shoes under one brand, it runs the risk that attention to the digital product passport remains focused on the clothing lines, while the rest of the assortment falls out of view — with the result that when a delegated act for footwear or leather goods does come, the company has to start from scratch. More on the scope of what does and does not count is available on which products from the clothing and textile sector fall under the ESPR.

Making a distinction between ESPR obligations and other legislation for these product groups

Shoes, bags and belts may already fall under other obligations separately from the digital product passport — think of chemical substance rules or producer responsibility that can vary per Member State. That process runs independently of the ESPR and is not replaced by it. For more information on how extended producer responsibility relates to the digital product passport, see what is extended producer responsibility for textiles and does it relate to the product passport.

Keeping track of when a delegated act for this product group is published

Because Article 1 of the ESPR leaves the scope per product group to be determined via separate delegated acts, for shoes, bags and belts there is no published text yet that makes concrete whether, and from what date, a passport obligation will apply. This is a different process from that for clothing, and it can have a different timeline and different thresholds. What a delegated act precisely is and why it is decisive for the actual obligation is explained on what is a delegated act and why does it determine what I have to do.

Where things go wrong in practice

A few situations that regularly come up with companies that carry bags, belts or shoes alongside clothing:

• A mixed assortment is treated as a single whole. A brand that sells jeans, canvas bags and leather belts under one line sometimes assumes that what applies to the trousers automatically also applies to the bags and belts. Material composition and product category determine that separately, however.
• Leather and textile variants of the same model are not distinguished. One shoe model that is made in a canvas and a leather version may be treated differently in terms of future classification, while the administration does not yet make this distinction.
• Accessories are forgotten when preparing for the passport. Attention goes to the core products (shirts, trousers, jackets), while belts, bags and scarves are taken along as a by-product without anyone having checked how they are materially composed.
• A sneaker with textile upper is categorized as a "shoe", done. Whereas the proportion of textile fibres is precisely the criterion that may determine whether a future act on clothing-related rules will also be declared applicable to such a product.
• There is a wait for something "official" to come for these product groups, without anyone following the EU work plan — with the result that a company only discovers late that an act is in preparation that affects its own assortment.

What you can record

• An overview per article group (clothing, bags, belts, shoes) with the estimated proportion of textile fibres versus other material, so that it is clear which lines may fall under a future act first.
• A separate note per product category on applicable legislation outside the ESPR, such as chemical substance rules or producer responsibility, so that not everything falls on the digital product passport's plate.
• A designated person or moment (for example quarterly) to check the EU work plan for delegated acts for new product groups.
• Documentation from suppliers on material composition per item, including for accessories — this is the same underlying information that will be needed in case of a future passport obligation and that is already useful now to maintain an overview.
• A brief internal explanation of the difference between what is already established for clothing and what remains open for other product groups, so that sales, purchasing and compliance use the same information. Background on that broader picture can be found on what the ESPR changes for the clothing and textile industry and at what is the difference between the ESPR and the European textile strategy.