texpas.eu
Log in Sign up

What does the product passport mean if I import clothing and textiles from outside the EU?

Importers have their own obligations under the ESPR

Anyone who imports clothing or textiles from outside the EU is designated as an importer by the ESPR and thus has a specific role in the digital product passport system, separate from the manufacturer. Article 29 of the ESPR imposes a number of obligations on importers: to verify that a digital product passport exists and that it meets the requirements, to provide their own name and contact details, to keep documentation, and to cooperate with supervisory authorities when requested. In addition, customs plays a role in the import process itself: Article 15 of the ESPR provides that customs may check, when releasing a product into free circulation, whether a passport is present and whether the data in it corresponds to what is required. The product passport thus affects not only the manufacturer in the country of origin, but also the person bringing the product into the EU.

Who this applies to and which products

This applies to anyone acting as an importer in practice: the person who brings a garment or textile product from a country outside the EU onto the EU market for the first time. An EU retailer or wholesaler that purchases from a supplier already established in the EU does not act as an importer in this respect, even if the product was originally made outside the EU — the importer obligations then rest with the party that imported it earlier. For brands and manufacturers that produce themselves within the EU, these specific importer obligations do not apply; the manufacturer obligations apply to them instead. This topic is also limited to what is asked of the importer itself: which data exactly must be included in the passport and how that data is recorded follows from other parts of the ESPR and from the delegated act specifically drawn up for textiles and clothing.

No fixed date yet, but a clear direction

When these obligations become concrete for clothing and textiles is not yet fixed. The ESPR work plan for 2025-2030 mentions a delegated act for textiles expected to be adopted in 2027, with clothing containing eighty percent or more textile fibres as the first category. Until that delegated act is in place and the entry into force date mentioned in it is known, the importer obligations from Article 29 and the customs checks from Article 15 do not yet apply specifically to clothing and textiles. As soon as the act is published and a concrete date is known, it will be stated here.

What an importer can prepare now

In practice, this comes down to the following for an importer, in the order in which it is usually addressed. First, it is important to clarify whether one's own role in the supply chain is actually that of an importer within the meaning of the ESPR, meaning who brings the product onto the EU market as the first actor from a third country. Next, it is important to gain insight into what data the manufacturer or supplier outside the EU already records about the product, since the passport is compiled from that source data and an importer usually has to be able to rely on that in practice. After that, it is relevant to think about how one's own name and contact details are made available with the product, as Article 29 requires, and how documentation is kept so that it can be shown upon request. Finally, it is advisable to take into account that customs may ask for the passport when releasing a product into free circulation; a supplier or platform that has the passport ready before the shipment crosses the EU border prevents this from having to be arranged during the import process itself.

The basis: Article 15 and Article 29 of the ESPR

What is stated above follows directly from two articles of the ESPR (Regulation (EU) 2024/1781). Article 29 describes the obligations of importers, including checking for the presence and conformity of the digital product passport and providing their own data. Article 15 regulates customs controls relating to the digital product passport, specifically when placing products on the market. For precise wording and the full text, the regulation itself is the appropriate source.

If you are already importing clothing or textiles from outside the EU, it is best to start by mapping out what data your own suppliers already record about material, origin and composition, so that this foundation is in place as soon as the delegated act for textiles and the associated date become known.

What this is based on

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

Whoever imports clothing or textiles from outside the EU is, according to the ESPR, the importer — and that is a designation with its own obligations, separate from what the manufacturer does on the other side of the world. Article 29 of the ESPR (Regulation (EU) 2024/1781) sets out what is expected of importers once products fall under a delegated act. Article 15 adds the customs dimension: the digital product passport also plays a role at the border.

Verify that the product complies with the requirements before it is placed on the market

For a company of this size, this typically means that someone within the company is responsible for this check, before the shipment is actually offered on the EU market. This is not a matter of sending the manufacturer an email and waiting — it is about a check that the company itself can demonstrate it has carried out. For clothing and textiles, this means in practice: checking whether a digital product passport exists, whether that passport is attached to the correct product, and whether the data contained in it corresponds to what is actually being imported.

Verify that the digital product passport is present and accessible

The importer is expected to verify that the passport exists and is accessible via the data carrier (usually a QR code) on the product or packaging. For an importer working with multiple manufacturers — for example, a jacket from manufacturer A with a lining produced elsewhere — it is useful to know who supplies which part of the data; see my garment is manufactured by multiple manufacturers, who supplies which data. This prevents a passport from existing but being incomplete for the product as it is actually sold.

Include own name and contact details

Article 29 requires importers to state their name, registered trade name or trademark and contact details on the product, packaging, or accompanying documentation. For an importer who is not themselves a manufacturer, this is a concrete, one-off action per product line — but one that is easily forgotten when the packaging has already been determined by the manufacturer.

Take corrective measures in case of non-compliance

When an importer has reasons to believe that a product does not comply with the requirements, he is expected not to place it on the market until compliance is achieved — and to inform the manufacturer and the market surveillance authorities if the product is already on the market. This requires an established process: who assesses a warning, and what happens to a shipment that is already in transit or already in storage.

Keep documentation and show it to authorities

Article 29 requires the importer to keep a copy of the digital product passport (or the information that should be contained in it) and to show it to supervisory authorities on request, even when the manufacturer is located outside the EU and is not directly accountable to the supervisor.

Take customs controls into account

Article 15 of the ESPR links the digital product passport to the customs procedure: when putting products into free circulation, the presence of the passport may be part of what is checked. For an importer, this means that a missing or non-functioning passport is not only a market problem, but potentially also a problem at the border itself, before the product reaches the importer's storage.

Where things go wrong in practice

A few situations come up repeatedly with companies importing from outside the EU:

  • The manufacturer supplies a general digital product passport for a collection, but the importer sells a variant (different colour number, different fibre mix) for which the data does not match exactly.
  • The QR code on the label points to a page that no longer exists or is not available in Dutch, and the importer only notices this after complaints from a retail chain.
  • A shipment is delayed at customs because no one within the company could explain what the passport refers to or who compiled the data.
  • The importer assumes that the manufacturer "will take care of the passport", without this being documented anywhere — and discovers during an inspection that nothing has been supplied. See also My supplier does not provide the data — what can I do?
  • For a garment that is partially made up abroad, it is assumed that the country of making-up is not relevant to the passport, whereas this can be information that is requested — see Must I include the country of manufacture in the product passport?

What you can record

For an importer working with foreign manufacturers, it is practical to arrange a number of things in writing in advance rather than relying on everything being correct upon delivery:

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.