can I use my GOTS or OEKO-TEX certificate as evidence in the product passport

What you must do concretely

GOTS, OEKO-TEX, an OCS certificate for recycled material: many clothing brands and importers already have those documents, often for years. The question is not whether such a certificate is valuable — it is — but whether it can come in one-to-one as evidence in the digital product passport. The answer is more nuanced than "yes" or "no".

The ESPR (Regulation (EU) 2024/1781) stipulates in Articles 5 to 7 that products must meet ecodesign requirements and that information about this must be available. How those requirements are precisely measured and demonstrated is set out in Article 39: it concerns the test, measurement and calculation methods used to determine whether a product meets the requirements. An existing certificate may be relevant to that substantiation, but the regulation itself does not stipulate that every certificate automatically and unconditionally counts as evidence within the passport. This is precisely why this question cannot yet be answered with a simple "yes, that works": the delegated act for textiles must still determine which methods and thus which forms of evidence are recognised for clothing and textiles specifically.

What is expected of you

Determine what a certificate precisely demonstrates

A GOTS certificate says something about the biological origin of fibres and about social and environmental criteria in the production chain. An OEKO-TEX certificate (depending on the type, such as Standard 100 or STeP) says something about harmful substances in the end product or about the production process. Neither certificate is designed to provide all the information that the product passport will subsequently require. For a company of 10 to 100 employees, this means in practice: the certificate in itself probably does not answer the full information question from Articles 5 to 7 of the ESPR, but can form part of the substantiation alongside other data.

Check whether the test method aligns with what the regulation requires

Article 39 of the ESPR concerns the methods by which performance is determined. Certification schemes such as GOTS and OEKO-TEX work with their own test protocols, which are not necessarily identical to the methods that the European Commission will establish in a delegated act for textiles. For a company, this means it is worthwhile to document per certificate which test method was used, so that it can later be assessed whether that method aligns with what is prescribed for textiles. You can read more about how these rules for clothing are developed in the section on what a delegated act is and why it determines what you must do.

Ensure that the certificate matches the correct product and the correct batch

Certificates are often issued at the level of a factory, a collection or a specific yarn batch, not automatically at the level of each individual product that requires the passport. For a company working with multiple suppliers, it is practically relevant to establish which certificate applies to which production. This aligns with the question of what data you actually request from a clothing and textile supplier: a certificate number without a clear link to the relevant batch or collection has little evidentiary value.

Prevent a certificate from giving a misleading picture

Article 40 of the ESPR concerns the prevention of circumvention and deterioration of performance. That article is not specifically written for certificates, but the underlying rationale is relevant: information in the passport must represent the actual situation of the product, not a more favourable picture than practice. For a company, this means that an expired certificate, or a certificate describing an earlier version of a product, is not incorporated into the passport without verification.

Where things go wrong in practice

An importer links a GOTS certificate to an entire product line, whereas the certificate only applied to part of the yarns. A spot check reveals that the rest of the batch contains uncertified cotton.

A brand uses an OEKO-TEX certificate that has since expired, because nobody keeps track of the validity date alongside the date the product came to market.

A private label company receives only a scan of a certificate from the manufacturer, without the underlying test report. If it later turns out that the data needs to be verified, there is nothing to fall back on — see also the approach in the section on how you verify whether your supplier's data is correct.

For a product manufactured at multiple factories, a weaver's certificate is mistakenly attributed to the entire garment, whereas the manufacturing phase — sometimes at a different facility — is not included. The question of who supplies which data is addressed in the article on multiple manufacturers within one product.

A company that sources from outside the EU adopts a certificate without verifying whether the certifying body and the scope of application match what is expected in the EU, something that relates to the broader questions around imports from outside the European Union.

What you can record

• Per certificate: the certificate number, the validity period, the certifying body and the exact scope of application (raw material, factory, collection or batch).
• A link between the certificate and the specific production or purchase order to which it applies, so that a certificate is not used independently for products for which it was not issued.
• The underlying test report or audit report, not just the certificate itself, so that the test method used is clear in light of Article 39 of the ESPR.
• An agreement with the supplier on the timely communication of expired or replaced certificates, recorded in the purchase contract — see the reference points in agreements on the supply of passport data in the purchase contract.
• An internal list of which certificate types (GOTS, OEKO-TEX Standard 100, OEKO-TEX STeP, OCS and the like) are relevant for which part of the information requirements from Articles 5 to 7 of the ESPR, so that upon publication of the delegated act it can be quickly assessed which certificates already align and which additional data are still needed.