According to which method must I measure the values for the passport?
The method is set out in the delegated act, not left to free choice
The way a value for the digital product passport is measured or calculated is not up to the brand or importer itself. Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that the European Commission shall lay down, for each product group, the test, measurement and calculation methods according to which the requirements set out in Articles 5 to 7 are to be demonstrated. Those methods must be accurate, reliable and reproducible, and where possible aligned with harmonised standards. For textiles and clothing, that specific method does not yet exist: it will only come with the delegated act for this product group. Until then, there is therefore no prescribed calculation method to establish, for example, a carbon footprint, a recycling percentage or a sustainability score for clothing within the passport framework.
What this applies to and what it does not
This system applies to all product groups under the ESPR, not only textiles: batteries, furniture, electronics and textiles will each receive their own delegated act with their own measurement requirements, even though the general framework is laid down in the same articles. What does not follow from Article 39 is a ready-made method that can already be applied to a clothing product now. The article describes the process and the quality requirements that a method must meet once it is established, not the formula itself. Moreover, this part only applies to values that are included in the framework of ecodesign requirements and the product passport; other obligations that a brand may already have under, for example, labelling of fibre composition or chemical substances, fall under other legislation and therefore do not automatically follow the same measurement method.
No date yet, but an order
There is no established date yet for when the measurement method for textiles and clothing will be published. What is known from the work plan for ecodesign and product passports 2025-2030 is: the delegated act for textiles is expected in 2027, with clothing containing eighty per cent or more textile fibres as the first category. This is an expectation from a work plan, not a commitment and not statutory text with a fixed date. Until the delegated act exists and is published, there is no officially prescribed measurement or calculation method for textiles under the ESPR. Once that act is published, it will set out which method applies, and this page will be updated with the concrete reference.
What can be done now
Anyone thinking about the product passport now can prepare a number of things in advance without having to wait for the final method. First: the data that will need to be measured or calculated later comes from somewhere — from the manufacturer, from the supply chain, from certificates or test reports. It makes sense to map out now which data are available and by what method they were obtained, even if that is not yet the method that the delegated act will later prescribe. Second: existing harmonised standards and common life cycle assessment methods give an indication of the direction in which the Commission is likely to be looking, since Article 39 explicitly refers to them as a preferred source. That is no guarantee that exactly that standard will be designated, but it is not a bad place to base the initial data collection on. Third: keeping an eye on the publication of the delegated act is more prudent than investing now in a fully developed, final measurement method — that could differ from what a brand had chosen itself. Finally: the platform compiles the passport on the basis of the data provided by the manufacturer or importer, and applies the method that is applicable under the legislation in force at that time; once the method for textiles is established, it will be incorporated into the way passports are compiled.
What this is based on: Article 39 and Articles 5 to 7
The obligation to establish a test, measurement or calculation method before a performance or information requirement can be applied in concrete terms follows from Article 39 of the ESPR (Regulation (EU) 2024/1781). That article links the method directly to the requirements that the Commission establishes per product category on the basis of Articles 5 to 7 of the same regulation — the provisions that describe the ecodesign requirements and the performance and information requirements in general terms. Because those requirements for textiles are only specified in concrete terms in a delegated act yet to be published, the associated measurement method has not yet been established. The official texts of both provisions are in the sources listed below, for those who wish to check the precise wording.
Those who wish to stay informed of when the delegated act for textiles is published can keep an eye on this page: as soon as the method is published, the specific reference will be added here.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 39 (test, measurement and calculation methods)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (requirements regarding ecodesign, performance and information requirements)
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 delegated act designates the measurement method
For each value that will be included in the product passport, there will be a specified method of measurement or calculation. Article 39 of the ESPR (Regulation (EU) 2024/1781) stipulates that the Commission designates testing, measurement and calculation methods per product group, and that these methods align as much as possible with existing European or international standards. For clothing and textiles, this designation does not yet exist: the delegated act for this product group is expected around 2027 in the ESPR work plan 2025-2030, with clothing of eighty percent or more textile fibres as the first category. For a company with 10 to 100 employees, this means above all that current preparation must focus on having the underlying data available, not on already committing to a single calculation method.
Data must be compatible with a method that is still to come
Articles 5 to 7 of the ESPR distinguish between ecodesign requirements, performance requirements and information requirements. A performance requirement (such as a limit value for microfibre release or a minimum share of recycled fibre) can only be verified once the associated measurement method is established. For a company, this means that data already being collected — test results from a supplier, certificates, laboratory reports — must preferably remain traceable to the original test conditions. A test report without mention of the standard or test method used will later be difficult to convert to the value that the delegated act ultimately requires.
Existing standards as an intermediate step
As long as the definitive method is not designated, it is common practice for companies to rely on standards already customary in their sector, for example for fibre composition or wash fastness. This is not an obligation that follows from Article 39, but a practical choice: the more consistent current testing practice is structured, the smaller the chance that data will later need to be re-measured according to a different method. If you now already establish how fibre composition is determined, you build a file that will likely remain largely reusable.
Where things go wrong in practice
A first situation: a test report from an external party states a percentage or value, but not which standard or test conditions were used. Without that information, it cannot later be determined whether the value is comparable to what a future method requires.
A second situation: different suppliers in the chain test the same property — for example the share of recycled fibre — according to different methods, without this being noted. When compiling the passport, a value is then created that is not one-to-one traceable to a source. If you need to demonstrate how the share of recycled fibre is substantiated, you benefit from a fixed, documented test method per supplier.
A third situation: a company adopts a value from a chemical analysis report without stating when and under what conditions testing was carried out. When questions arise about which chemical treatments must be reported that is a weak point in the file, because the value cannot be substantiated if the original test report is not retained.
A fourth situation: an internal testing department uses its own, non-standardised measurement method because it is cheaper or faster, without this being documented anywhere. Once the delegated act designates a standard method, it then becomes apparent that earlier measurements are not comparable and must be performed again.
A fifth situation: a company assumes that the measurement method for the passport is the same as that for the care label, whereas that is not necessarily the case. The care instruction and the passport serve different purposes and may rely on different standards; how the care label relates to the passport is therefore a separate question that cannot automatically be answered with the same test data.
What you can record
- Per measured or calculated value: which standard, test method or calculation method was used, by whom, and on what date.
- The test report or certificate itself, with reference to the test conditions, kept as underlying evidence with the value in the passport.
- An overview per supplier of the test method used, so that in case of doubt it can be quickly determined whether values are mutually comparable.
- A note with each value not yet measured according to a designated method, so that when the delegated act is published it is clear which data may need to be revised.
- A reference to the source of the value in the internal administration, linked to the part of which data are included in the textile passport, so that test method and data field remain linked.
- A procedure for how often test results are repeated or checked, to be aligned with the question how current the data in the passport must be.
We monitor the publication of the delegated act for clothing and textiles and will update this page as soon as the method for this product group is designated.
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.