How often must I update the data in the product passport?
Current upon changes, not according to a fixed schedule
The ESPR does not impose a fixed timespan on updating a product passport. What is established: the information in the passport must be accurate, complete and current for as long as the product is on the market. In practice, this means an update is warranted at the moment the underlying data changes — not on a fixed rhythm such as 'once a year' or 'once per quarter'. If the fibre composition, supplier, model changes or information is added about repair or reuse, the passport should reflect that. If the product remains unchanged, there is no reason to make adjustments.
Which products and which data this applies to
This principle applies to the digital product passport as the ESPR will prescribe it for product categories, and therefore also for textiles and clothing once the delegated act for that sector is in place. It concerns the data included in the passport: product information from the manufacturer or importer, and possibly data added later in the supply chain, such as repair or maintenance history. It does not concern how often a consumer consults the passport — that is up to the user — nor does it concern the retention period for which a platform keeps the passport online after a product is no longer sold. The latter is a separate matter: Texpas hosts a passport, for example, for ten years as part of its own service provision, independent of the question of when its content is updated.
No fixed date yet, but an expected timeline
For textiles and clothing there is no binding obligation yet: that only arises with the delegated act that the European Commission must adopt for this product category. According to the ESPR work plan for the period 2025-2030, that act is expected in 2027, with clothing consisting of eighty per cent or more textile fibres as the first category. An exact date on which the obligation to maintain a current passport for textiles enters into force is therefore not yet fixed. Until the act is published, there is no legal obligation for these products to maintain a digital product passport — let alone an obligation to update it at a specific time. Once that date is known, this page will be updated accordingly.
How to approach this in practice
Those already thinking about a product passport would be well advised not to view the update question as an agenda item ('when should we review it again?') but as a process that runs alongside changes in the product or supply chain. In concrete terms, this means: first establish internally which data will appear in the passport and who is responsible for it — usually the manufacturer or importer for core data. Next, set up a way to flag changes in that data: a new supplier, an adjusted composition, a different model sold under the same reference. Then agree a line with the party hosting the passport — at Texpas this is the party that processes the data into a passport and supplies the QR data carrier — on how and how quickly a change is implemented. Finally, it is important to distinguish who may add which information: Article 10 of the ESPR provides that different actors in the supply chain, such as a repairer, can add data to the passport without being able to modify the manufacturer's core data. If you clarify this distinction beforehand, you avoid dispute later over who should have made an update.
Where this follows from: article 9 and article 10 of the ESPR
The basis for this lies in Article 9 of the ESPR (Regulation (EU) 2024/1781), which introduces the digital product passport and requires that the information contained in it is accurate, complete and up to date. Article 10 of the same regulation elaborates on this with the technical and organisational requirements for the passport, including the question of which actors in the chain may consult, add or modify data. Neither of these articles specifies a fixed deadline or frequency for updating data; the obligation is formulated in material terms — the content must be correct — rather than procedurally with a fixed calendar.
Textile or clothing manufacturers that are already placing products on the market and want to see what a product passport looks like in practice can review the Texpas setup and have data recorded for when the obligation for textiles takes effect; those who wish to be informed as soon as the delegated act and the associated date are known should keep an eye on this page.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (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
Articles 9 and 10 of the ESPR (Regulation (EU) 2024/1781) describe the digital product passport as a carrier layer with data linked to a specific product or product model. The regulation outlines the main principles for updating: data must be accurate at the moment the product is placed on the market, and the link between passport and product must remain intact during the retention period. What this concretely means for data maintenance will be further specified per product category in the delegated act for textiles, which has not yet been published. What can already be described is which types of data require maintenance and why.
Static data usually remain unchanged
Part of the passport content is fixed once a product leaves the factory: the fibre composition, the country of production, the chemical treatments used. For a company with 10 to 100 employees, this means that this part of the passport is in practice compiled once, during the production of a particular batch or collection. As long as the product remains unchanged, there is no reason to update this data. How this data is precisely recorded is described on the page on how to record the fibre composition in the product passport.
Product modifications require a new or amended registration
When a product changes in the meantime — a different yarn supplier, an adapted finish, a different fibre mix for the same collection — the question arises whether the existing passport still fits the product. The regulation starts from the link between passport and product; if the two no longer match, that is a practical risk, even though there is not yet a concrete deadline in the text for how quickly it should be corrected. For a company with multiple production lines or seasonal collections, this is often the moment when an adjustment in the administration is easily forgotten, because the change is implemented in procurement or production, but does not automatically reach the passport.
Data from a third party remain dependent on that party
Some parts of the passport, such as the share of recycled fibre, rely on a statement or certificate from a supplier. If that supplier adjusts its own substantiation — a new certificate, a different batch with a different percentage — this flows through to the passport of the end product. For a medium-sized company, this means that maintaining the passport is not just an internal matter, but also depends on how well information exchange with suppliers is organised. More on the substantiation of such claims is on the page on how to demonstrate the share of recycled fibre.
The accessibility of the QR data carrier must be maintained
In addition to the content of the passport, Article 10 also addresses technical availability: the data carrier must remain readable and functional during the retention period. For a company, this is less a question of "how often do we update content" and more a matter of technical maintenance: does the link behind the QR code remain functional, does the hosting party continue to exist, does the link to the correct product model remain accurate when a collection is phased out. This is precisely the part that a platform like texpas.eu safeguards for the ten-year term, regardless of whether the underlying company itself makes changes.
Where things go wrong in practice
A few situations come up regularly in the practice of clothing brands and importers.
A collection is slightly adjusted after the first production run — a different finish against wrinkles, a different dye — without anyone explicitly checking whether this affects the data already in the passport, for example on chemical treatments.
A supplier delivers a new certificate for recycled material, but this certificate only reaches the purchasing department and not the person managing the product passport, as a result the product passport continues to show an outdated percentage.
A product is discontinued, but the product passport remains active without any notation that the model is no longer sold, which can be confusing for anyone consulting the product passport via the QR code.
Maintenance instructions on the care label change following a product adjustment, but the change is not implemented in the product passport, whereas both should be aligned with each other — see also how the care label relates to the product passport.
A company assumes that the product passport, like the labelling, is established once and then never touched again, whereas in fact the link between product and product passport is a continuing point of attention whenever something changes to the product.
What you can record
- An overview of which data in the product passport are static (fibre composition, country of production) and which depend on external parties (recycled content, certificates).
- An internal agreement on who is responsible for notifying the person managing or having the product passport managed of product changes.
- A log of changes per product model, so that it can be traced afterwards when a data item was adjusted and on the basis of what substantiation.
- Agreements with suppliers on how and when certificates or declarations are provided, in particular for components such as the proportion of recycled fibre.
- An overview of discontinued product models, so that it is clear which product passports are still active and which must only remain accessible for the retention period.
- A regular check during collection changes or adjustments to finishing, dye or yarn, to assess whether this has implications for data already established, including the question of whether repair options are still correctly described.
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.