does my clothing receive a sustainability score in the digital product passport

What you must do concretely

What is expected of you

The ESPR builds the digital product passport around factual, verifiable data: fibre composition, chemical treatments, origin, repair possibilities. A score that combines all those elements into a single figure or letter is something different from a collection of separate data points, and in that regard there is no framework specific to textiles that has yet been published in detail. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes what the passport must contain and how it must be accessible, but a mandatory sustainability score is not listed as such. Articles 5 to 7 of the ESPR address the ecodesign requirements and performance and information requirements that are worked out per product category — for textiles this is done via a separate delegated act that does not yet exist. What can be inferred, however, is the direction companies can expect.

Collecting data that could feed into a score

Even without an established scoring method, it is practical to have the underlying data in order. Fibre composition, share of recycled material and chemical treatments are each elements that already play a role in comparable scoring systems elsewhere (such as existing voluntary sustainability labels). For a company with 10 to 100 employees, this means that the basic record-keeping that is needed anyway for the passport — see which information goes into the product passport for clothing and textiles — immediately also lays the foundation for a possible future score. No separate exercise is needed as long as the source data is correct and traceable.

Making a distinction between mandatory data and voluntary claims

Some brands already operate their own sustainability score or label, separate from the legally mandatory passport. That distinction is relevant for business operations: data that the ESPR makes mandatory must meet the requirements in Article 10, whereas an own score is a voluntary addition that does not fall under the same rules, but may fall under other legislation (such as advertising and misleading rules, which are not addressed here). A company that already works with its own score would be well advised to document those two data streams separately, so that if the passport is expanded in the future, it is clear which data already meet the statutory source requirements and which do not.

Taking into account the phased approach of the ESPR

The ESPR works with product group-specific delegated acts. For textiles, the expectation is that clothing with a high proportion of textile fibres will be first in line. This means that any scoring requirements, should they come, will likely not apply to the entire assortment at once but will be phased in. For a company with a mixed assortment — for example clothing alongside accessories or interior textiles — it is practical to already inventory now which product categories could fall under the first phase, so that a future scoring requirement does not hit the entire portfolio at once but can be tackled gradually.

Where things go wrong in practice

A recurring point is that companies on their own initiative already attach a score or "sustainability report card" to their clothing, without the underlying data being as well documented as the mandatory passport data. When the statutory scoring requirement comes, it turns out that the company's own approach does not align and the work has to be largely redone.

Another situation: brands that assume that "higher percentage of recycled material" automatically means a better score, and that assumption is already implemented in marketing material. Without an established method, it cannot be said how heavily that element will weigh, and premature claims can be at odds with other rules on misleading sustainability claims.

It also happens that companies delay recording chemical treatments because "that will only be relevant once the score is in place". But the obligation to report chemical treatments is separate from any potential score and follows from the general passport requirements — see which chemical treatments must I report. Those who delay on this are falling behind the statutory basic obligation, regardless of what happens with a score.

A fourth pitfall: the idea that a score, if it comes, is established once and then never changes. Sustainability data such as fibre composition or repairability can vary per collection or production batch, and the question of how often passport data must be updated — discussed at how often must I update the data in the product passport — would apply equally to a future score.

Finally: companies that want to base a score on internal estimates rather than on a recognised measurement method. Once an official method comes, it will likely align with the way other passport values already have to be measured, as described at according to which method must I measure the values for the passport. Internal, unsupported estimates usually do not align with this.

What you can record

• An overview of which sustainability data are already being collected for the passport (fibre composition, recycled content, chemical treatments) and where these are stored.
• A clearly separate administration between mandatory passport data and any company's own, voluntary sustainability claims or labels.
• Documentation of the source and measurement method behind each piece of data that might end up in a future score, so that traceability is in order once an official method is established.
• A classification of your own product assortment according to the likelihood that a product group will fall under the first phase of the ESPR textile rules, so that priorities can be set.
• A procedure to periodically update passport data, even if there is no scoring requirement yet — this aligns with the broader question about data timeliness.
• Internal agreements on communication: which sustainability claims are and are not communicated externally as long as no official scoring method has been established.

Once the European Commission publishes a delegated act for textiles containing a concrete scoring method, this will be added to this page.