my garment is manufactured by multiple manufacturers, who supplies which data

What you must do concretely

What is expected of you

A garment rarely comes from a single address. The fabric comes from a spinning mill, the cloth is dyed by another company, the garment is sewn by a third party, and the brand that puts the garment on the market is located at yet another address. For the digital product passport, this is not a technical detail — it determines who must provide which information and who is responsible for ensuring that the whole is correct.

The manufacturer remains ultimately responsible

Article 27 of the ESPR places the obligations for the digital product passport on the manufacturer. This is the person who puts the product on the market under his name or brand, even if that manufacturer has never touched a needle. For a company of ten to one hundred employees, this usually means that the brand or importer that puts the collection together is the party that must ensure the passport is correct — not the factory that cut and stitched the garment. Practically, this changes nothing about who does the sewing work, but it does change who receives the bill if the data is missing or incorrect.

Actors in the supply chain provide input, not output

Article 38 of the ESPR concerns the parties before the manufacturer in the chain: the spinner, the weaver, the dye house, the sewing workshops. They must pass on the information that arises within their link to the next party in the chain — ultimately that information reaches the manufacturer who must compile the passport. For a company that works with multiple factories, this means the chain only works if every link actually passes on its part. One factory that does not record fiber origin is enough to make the entire passport incomplete.

The passport must form one complete whole, regardless of the number of suppliers

Article 10 of the ESPR describes what the digital product passport must comply with: it must be linked to a specific product and the required information must be complete and correct. That article makes no distinction based on how many manufacturers have worked on a garment. For a company with a dispersed production chain, this means that someone must bring together all the partial data into one passport per product — this is not automatically the factory that last stitches the label in.

Where things go wrong in practice

A number of situations recur regularly in a dispersed production chain.

The garment factory thinks the fabric supplier has already passed on the fiber data, and vice versa. Both parties assume the other will handle it, and nobody checks. The result is a data gap that only becomes apparent when the passport needs to be compiled.

Two factories provide conflicting information about the same batch of fabric. For example, a different fibre percentage, or a different country of origin for the fabric than for the garment assembly. Without a fixed procedure to flag such discrepancies, they only come to light during an inspection.

One of the factories in the chain is replaced, but nobody updates the recorded data. The passport continues to refer to the old supplier, while production has since moved elsewhere.

No distinction is made between the country where the fabric was woven and the country where the garment was assembled. This may seem like a detail, but it is precisely the kind of question a customs authority or inspector may ask about; see also Must I include the country of manufacture in the product passport? for how these two relate to each other.

When importing from outside the EU, it is assumed that the foreign factory is already familiar with European regulations and automatically complies with them. This is an assumption, not a certainty — the party bringing the product onto the EU market remains responsible for being able to demonstrate that the data is correct. What this specifically means for imports is described on What does the product passport mean if I import clothing and textiles from outside the EU?

What you can record

In a chain with multiple manufacturers, it helps to establish in advance who supplies what, rather than discovering this only when compiling the passport.

• An overview per production line of which factory supplies which part — spinning, weaving, dyeing, assembly — with the data belonging to each stage. See What data must I request from my supplier of clothing and textiles? for a starting point per stage.
• Contractual agreements on data provision, preferably included when beginning cooperation with each factory, not afterwards. An example of what such an agreement might look like is on How do I record the supply of passport data in my purchasing contract?
• A fixed method for checking supplied data for internal inconsistencies, especially when multiple factories provide data about the same materials. See How do I verify whether my supplier's data is correct?
• Certificates per factory, such as GOTS or OEKO-TEX, linked to the specific part of production they relate to — not to the garment as a whole if the certification only covers one stage.
• A procedure for changes, so that replacing a factory or subcontractor also results in an update to the recorded data, instead of the passport referring to a party no longer in the chain.
• A list of contact persons per factory who are responsible for providing data, so that there is a clear point of contact if information is missing — what to do if that delivery fails to materialize is on My supplier does not provide the data — what can I do?