must I arrange for translation of my product passport data myself
Translation is not yet fixed, but the data comes from you
The ESPR stipulates that a product passport must be created and what it must contain, but does not specify in so many words who is responsible for translating it into other languages. What is certain: the content of the passport — the data on the product, the materials, the origin — comes from the manufacturer or importer themselves. A platform such as texpas.eu processes that data into a passport and supplies the QR data carrier, but the source text and its accuracy are and remain the responsibility of whoever places the product on the market. Translation is in practice an extension of that same responsibility: whoever supplies the text also determines in which language or languages it becomes available.
For whom this applies and what remains open
This subject concerns clothing brands, importers and private label parties who will have to supply a digital product passport for clothing and textiles. This specifically concerns the language in which the passport data is presented to a consumer, trader or supervisor in a country other than where the product was produced. What is not covered here: the question of whether a passport must exist at all (that is governed by Article 9 of the ESPR), and the question of which data it must contain (that is governed by Article 10). The technical standard for the QR code or data format is also a separate matter. Languages are an implementation question that only becomes concrete when the delegated act for clothing and textiles exists — and that does not yet exist.
A nuance that is often missed: a passport that is sold in several EU countries will in practice almost certainly be available in several languages, simply because a consumer in a shop must be able to understand the information. However, this is a practical expectation based on how consumer information is treated elsewhere in the EU, not a literal text from Article 9 or 10 on language obligations specifically for the textile passport.
No fixed date yet, but a fixed order
There is no date on which a language obligation for the product passport comes into force, because that obligation is not yet explicitly worked out in the current texts. What is certain is the sequence: first comes the delegated act for clothing and textiles, which is currently expected in the ESPR work plan 2025-2030 with clothing containing eighty per cent or more textile fibres as the first category. That act will contain the product-specific requirements, and something about language may also be included in it — for example whether the passport information must be available in the language of the country of sale, as is customary for other consumer information in the EU. Until that act is published, this part is not filled in and the date for it is not yet fixed either. As soon as that changes, it will be updated here.
What to do with this until the rules are fixed
The first step is to get the passport data itself in order in the source language, because without a correct, complete base text, translation is nothing more than a technical post-processing problem. Anyone who already works with different sales markets is well advised to think about which languages are relevant for their own sales channels — this is the same consideration that is already being made for washing instructions, packaging texts and safety information, and that can serve as an example. A second point is to ask any software partner or service provider for the passport how they handle multilinguality: can the system handle multiple language versions of the same dataset, and who provides those versions with content. This is a question that fits well with the broader consideration described at what should I pay attention to when choosing a supplier for the product passport.
Furthermore, it is wise not to wait with your own preparation until the delegated act is in place. Anyone who takes steps now — collecting, structuring and checking data, and checking whether their own product administration can feed a passport — will be in a better position as soon as the obligation becomes concrete. An overview of those steps is at what can I do now whilst the rules are not yet final. Anyone who wants to understand how the process from passport to QR code works in broad outline, including where language might play a role, will find that at how do I tackle the product passport for clothing and textile step by step.
The legal basis: Articles 9 and 10 of the ESPR
Article 9 of the ESPR (Regulation (EU) 2024/1781) requires a digital product passport and describes its general design, including the accessibility of information for different users. Article 10 of the same regulation sets out which data the passport must minimally contain and who is responsible for it — namely the person placing the product on the market. Neither of these articles currently contains a detailed language rule specific to the product passport for clothing and textiles; that detail will, if it comes, be set out in the product-specific delegated act that still needs to be published for this sector.
Anyone who wants to start with their own product data now would do well to structure that data in such a way that a later translation step does not mean restarting the entire process — that is work that is needed anyway for the passport itself, and that saves time later.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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
The ESPR sets out in Article 9 and Article 10 which data must appear in a digital product passport and how that is technically disclosed, but does not provide a written list of languages in which this must happen. What does follow from those articles is that the passport must present the information in an accessible way to the user — and "accessible" is typically defined in practice by product information standards also in terms of the language of the market where the product is sold. For a clothing brand or importer, this means a number of practical considerations.
Determine in which language or languages the passport will appear
For a company with ten to one hundred employees operating in several EU countries, the first question is not "how do I translate", but "which markets does this passport apply to". A passport offered only in English appeals to some customers but not necessarily to all. This requires a choice upfront: a separate passport text per language area, or one base text with translated layers on top.
Ensure that the source data is correct and unambiguous
Translation starts at the source. The data that goes into the passport — fibre composition, origin, washing instructions, repair information — is supplied by the manufacturer or importer. Unclear or ambiguous source text inevitably produces a less reliable translation. This is one of the places where passport quality is determined before translation is even considered.
Ensure consistent translation across product lines
With an assortment of dozens or hundreds of items, there is a risk that the same term (for example a fibre type or a care instruction) is translated differently in one language version than in another, or differently than for a comparable product in an earlier collection. This is not a legal problem in itself, but it is a source of confusion for customers and for a supervisory authority comparing data.
Record who does which step in the translation process
Because texpas.eu compiles the passport from the data supplied by the manufacturer or importer, the translation step is part of a chain: supply, compilation, hosting, disclosure via the QR data carrier. Who in that chain is responsible for which language version is something that is agreed per collaboration — the regulations do not prescribe how this role division should be handled.
Where things go wrong in practice
Only the source language is supplied. An importer supplies product data in one language and assumes that "the supplier will take care of that", while the service provider only compiles what is supplied. Without agreement, the translation question remains unresolved between the parties.
Automatic translation without review. Machine translation of technical terms like fiber composition or care symbols can lead to shifts that in textiles are slightly different from general consumer texts. A word that correctly conveys a washing instruction in one language may have a slightly different meaning in another language.
Different translations for the same product in different channels. A webshop text, a care label and the digital passport are translated by different people or departments, resulting in the three texts no longer saying the same thing about the same garment.
Translation is only done afterwards, after the first sale. The passport goes live in one language "to save time", with the intention to update later. In the meantime, the passport is already linked to the QR data carrier on the product and in circulation among customers in other language regions.
No established source of the source text. When a translation error is noticed, it is no longer possible to trace which version was the original text provided by the manufacturer and which was the translated derivation. This makes correcting unnecessarily difficult.
What you can record
- An overview of the language regions in which the product is sold, linked to the question of which passport language applies.
- The source text per data field (fiber composition, origin, care, repair information) as provided by the manufacturer or importer, separate from the translated versions.
- An agreement with the service provider or supplier about who performs the translation step and who checks the translation before it is linked to the QR data carrier — a point that also comes up with what should I pay attention to when choosing a supplier for the product passport.
- A version history per language version, so that when the source text changes, it is clear which translations still need to be updated.
- A fixed terminology list for repeated terms (fiber names, washing instructions, warranty terms), so that translations remain consistent across collections and product lines.
- A control point before the label or packaging with the QR data carrier goes out, in line with the questions that come up with must I already adapt my clothing labels and packaging for the product passport.
- A note of the status of your own approach, so that it can be adjusted as soon as there is more clarity — useful in combination with what can I do now whilst the rules are not yet final.
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 2026-09-05. Is something not right? Let us know — corrections are given priority.