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Can I link the product passport to my ERP or inventory system?

Linking is the starting point, the technical form is not yet determined

A link between the digital product passport and your own ERP or inventory system aligns with the way the ESPR has set up the passport: data must be machine-readable and interoperable, precisely so they do not have to be entered manually again and again. Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the product passport aimed at interoperability, and article 11 addresses the technical design and its operation, including the way data are exchanged. This means that a link is technically possible in principle. What is still missing is the concrete technical implementation for textiles: which file format, which fields are mandatory and whether a standard API will be introduced, are not yet determined. Those details will follow from supplementary legislation drawn up specifically for clothing and textiles.

Who this applies to and what it does not

The interoperability requirement from article 10 and the technical provisions from article 11 apply to the digital product passport as such, regardless of whether a brand, importer or private label compiles the passport itself or has it compiled. This is therefore a generic requirement within the ESPR, not something that is worked out separately per product category. What does not follow from this is an obligation to build a technical link now, or a guarantee that a particular file format or protocol will prove usable later. Moreover, the passport is not a copy of an ERP system: it contains the data relevant to the passport (composition, origin, care information, and the like), not the complete inventory or order administration. In practice, a link means that some of the product data already present is transferred to the passport, not that both systems merge completely.

When this becomes concrete and what applies until then

There is no fixed date for this obligation yet. The ESPR work programme 2025-2030 indicates that a delegated act for textiles is expected in 2027, and that clothing with eighty percent or more textile fibres will be the first to be addressed. Once that act is published, it will also become clear what technical requirements apply to data exchange, and thus whether and how a link with an ERP or inventory system can look. Until then, only the general provisions from articles 10 and 11 apply: the framework is in place, the technical implementation for textiles is not. Anyone who would like to start building a link now is therefore building on a framework whose details may still shift.

What this means in practice, step by step

First, it is useful to look at which data already exist in your own system and which of those are likely to end up in a passport: fibre composition, country of production, material origin, care instructions. Next, it is practical to record that data as structured as possible, in fixed fields with unambiguous values instead of free text, so that they can later be more easily transferred to whatever format. After that, it is sensible to wait with actually building a technical link or API, because the requirements for textiles have not yet been established; energy put into a specific link now may still require adjustment after publication of the delegated act. What does work already is the supply of data in the way that is currently available: manually, via a file, or via a simple export from the existing system. Texpas compiles the passport from the data supplied by the manufacturer or importer, and already processes that supply without requiring a live link for it. Once the technical framework for textiles is known, it can be assessed whether a more direct link from the ERP or inventory system offers added value.

What this is based on: articles 10 and 11 of the ESPR

The interoperability requirement and the machine readability requirement for the digital product passport derive from Article 10 of the ESPR (Regulation (EU) 2024/1781), which establishes the general requirements for the passport. Article 11 of the same regulation describes the technical design and operation of the passport, including the way in which data is digitally recorded and exchanged. Both articles form the framework within which subsequent, product-specific legislation for textiles must fill in the technical details; that specification does not yet exist for clothing and textiles.

Anyone who now already records data on composition, origin and care in a structured manner in their own system will not have to start over later, regardless of what technical form the connection takes. For the current status of the delegated act and the exact timetable, the official source of the European Commission is the place to watch.

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

The passport must be able to receive data from source systems

Article 10 of the ESPR (Regulation (EU) 2024/1781) sets out requirements for which data must be included in a digital product passport and how that data is accessible. This data does not come from nowhere: it already exists in existing systems such as an ERP package, a PLM system or an inventory management package — material composition, supplier data, batch numbers, care instructions. For a company with 10 to 100 employees, this practically means there must be a connection between the system where this data already exists and the system that compiles and publishes the passport. This can be an automated link, but also a periodic export that is manually uploaded. Both are essentially possible; which form is practical depends on how many products and variants there are and how often data changes.

The technical operation must comply with established standards

Article 11 of the ESPR (Regulation (EU) 2024/1781) describes the technical design and operation of the passport, including the manner in which data exchange takes place. This directly addresses the question of how a link is technically set up: not every export format from any ERP system will fit without modification into what a passport system expects. For a mid-sized company, this means that a translation is needed between its own data structure and the format required for the passport. This is a technical matter, not a legal one — but it does bear on the question what GS1 Digital Link is and whether it is necessary for the product passport, because part of the standardisation expected to take place runs through systems of this kind.

Each product must be traceable to the correct passport data

A link with an ERP or inventory system only works if there is a conclusive way to match a physical product to the correct passport. This requires a consistent key between the systems: the same article number, the same batch code or the same variant identification in the ERP system as in the passport. Without this alignment, there is a risk that a linked system transmits data but to the wrong passport, or that a change in one system does not carry through to the other. This is closely related to the way each product receives a unique identification code; without a clear identification logic, a link between systems is of little value.

Where things go wrong in practice

A first situation that often arises: a company has an ERP system in which articles are recorded per style, but not per colour or size. The passport must be correct at variant level, and it then turns out that the link transmits data that is correct for one size but not for another.

A second situation: data is transferred once when a collection is launched, but a later change in the ERP system — for example a different supplier for a partial batch — is not automatically transferred to the published passport. The passport thus becomes disconnected from reality without anyone noticing, until someone discovers an error and wonders whether a published product passport can still be amended.

A third situation: a link is technically set up by an external IT party, but no one within the company subsequently checks whether the data that ends up in the passport actually matches what is on the label or packaging. A technical link that works is not automatically a link that is correct.

A fourth situation: the inventory system is used to automatically expire passports once a product is sold out, without taking into account the question of how long a passport must remain available. This can lead to a mismatch between what is operationally convenient for inventory management and what is expected with regard to how long a product passport must remain available.

A fifth situation: when a merger, acquisition or cessation of a business unit occurs, the link is disconnected without consideration of who will manage the data afterwards, which again connects to the question what happens to the product passport when a company stops operating.

What you can record

  • An overview of which systems provide which passport data: ERP for material and origin, inventory system for availability, PLM for design and composition data.
  • A documented agreement on the frequency of synchronisation: real-time link, daily export, or manual update per collection.
  • A document describing the identification key used to match a product in the ERP system with the correct passport — including how this works with variants in size or colour.
  • A responsible function or person who checks whether data arriving via the link actually match before a passport is published or updated.
  • A procedure for what happens when there is a change in the source system: who signals this, and how is the change implemented in the published passport.
  • Agreements with an IT supplier or internal IT department on the technical format of the link, including what happens when a system switches or migration occurs.
  • An overview of which data are supplied automatically via a link and which are still added manually, so that there is no gap between what the system thinks it is sending and what actually appears in the passport.

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.