Must I include the country of manufacture in the product passport?

What you must do concretely

What is expected of you

Whether the country of manufacture must later be submitted as separate data in the product passport is not yet established. The ESPR itself (Regulation (EU) 2024/1781) states in Article 10 which types of information a product passport can contain, but the precise data fields for clothing and textiles will only be determined in the delegated act that has yet to be published for this product group. As long as this does not exist, no one can say with certainty whether "country of manufacture" will become a mandatory field, an optional field, or will not appear at all. What can be described: what is practically expected of a company in the meantime, and why this data point is on the radar in the first place.

Keep track of where sewing, cutting and finishing takes place in the supply chain

Article 38 of the ESPR obliges actors in the supply chain to provide relevant information to the person compiling the product passport. For a company with 10 to 100 employees, this means in practice that someone must know where manufacturing actually takes place — not just which manufacturer was purchased from, but in which country the garment was physically made. For private label and smaller brands, this is often far from self-evident: procurement takes place through an intermediary, and the country on the invoice is not necessarily the country of manufacture. Anyone who brings structure to this now will not have to do so under time pressure later.

Make a distinction between country of origin and country of manufacture

A common assumption is that "country of origin" (as used for customs or labelling) is the same as the country where the garment was manufactured. This is not necessarily the case: a fabric can be woven in one country, dyed in a second, and sewn in a third. Which of these steps will later be decisive for a possible passport field depends on the delegated act. Until then, it is advisable to record these data separately rather than treating them as a single "country" field, so that later it does not have to be worked out retrospectively which country belonged to which step.

Traceability down to supplier level

Article 38 refers to the provision of information by actors in the supply chain. For a company that works with multiple manufacturing facilities — sometimes per collection, sometimes varying per order — this means that the question "where was this made" must be answerable per product, and not per brand or collection. For companies that work with multiple manufacturers for a single product, this is an additional point of attention; my garment is manufactured by multiple manufacturers, who supplies which data goes into greater detail on how that division can be made in practice.

Where things go wrong in practice

The country on the invoice is adopted as the country of manufacture. When importing from outside the EU, documents often show the country of dispatch or the country of the exporter, not necessarily the country where the clothing was made. Anyone who equates these two without verification risks recording data that is incorrect.

When production locations change, only one country is recorded. Some brands have the same style manufactured at different facilities in different seasons, depending on capacity. If the country of manufacture is only recorded with the first order and not rechecked with a subsequent order, the record no longer matches actual production.

An intermediary is treated as a source of information while that party does not know it themselves. When purchasing through an agent or trading company, it is not self-evident that this party knows exactly in which factory, let alone in which country, the garment was manufactured. An inquiry with the intermediary then yields an assumption, not a fact.

Country of manufacture and country of origin are used as synonyms in internal systems. If the ERP or PLM system only has one "country field", that field is sometimes filled in for customs purposes and later used uncritically for other purposes. As soon as two different meanings are needed, this creates noise.

It is assumed that this data will certainly become mandatory, and it is anticipated that a format that does not yet exist will be used. Investing time in a fixed template before the delegated act exists is asking for double work. See also what is a delegated act and why does it determine what I have to do.

What you can record

• Per production location: the country where the making-up (sewing and finishing) actually takes place, separate from the country of origin for customs or labelling purposes.
• An overview of which manufacturer or workshop was involved in which order or collection, so that the country of making-up is traceable down to product level and not only to brand level.
• Agreements with suppliers on the provision of this information, recorded in the purchasing contract; see how do I record the delivery of passport data in my purchase contract for an approach to this.
• A standing question in the checklist towards suppliers on the country of making-up, alongside the other data already being requested; what data must I request from my clothing and textile supplier provides an overview here.
• A check step on the correctness of the stated country, especially for imports from outside the EU, where documentation does not always clearly reflect the country of making-up; see how do I check if my supplier's data is correct and, specifically for imports, what does the product passport mean if I import clothing and textiles from outside the European Union.
• A file per product group or collection in which country of making-up, country of origin and the underlying supporting documents (invoices, certificates of origin, audit reports) can be found separately from each other, so that a later passport field can be filled with minimal reworking.