My product needs multiple product passports — how does that work together?
One passport per product category, linked where necessary
A product generally receives one digital product passport per product category for which a delegated act applies; where a product is simultaneously subject to multiple regulations, the ESPR's approach is to link these passports to each other via unique identification codes, rather than recording the same information twice. Article 9 of the ESPR (Regulation (EU) 2024/1781) governs the general structure of the digital product passport and takes account of the situation where a product may already be subject to other information requirements under Union law. Article 12 provides for unique identification codes for the product, the economic operator and the establishment, and these codes form the link between different registrations. For clothing and textiles, this means that a simple garment made entirely of textile fibres is expected to require only one passport. A composite product — for example with a component that is not considered textile and falls under a different delegated act — may instead need multiple passports linked to each other.
Particularly relevant for composite products
This situation arises in practice especially with products that consist of multiple separately regulated components: think of a garment with a technical or electronic component, or a product sold commercially as a single unit but consisting of multiple separate items. This does not cover the normal case where a brand combines data from multiple suppliers (fabric, buttons, zips) into one passport for one garment — that is normal data collection for one passport, not a matter of multiple passports. This text also does not address which data belongs in the passport; that is determined per product category in the delegated act. For the vast majority of clothing and textile products that consist of eighty percent or more textile fibres and have no separately regulated component, the approach is one passport, not multiple.
No fixed date yet, nor for the combination
When the obligation for a digital product passport for clothing comes into force is not yet fixed. The European Commission's work plan for 2025-2030 mentions a delegated act for textiles, with clothing of eighty percent or more textile fibres as the first category, expected in 2027. For a product that falls under multiple product categories or regulations, the timing may differ per component: each delegated act has its own date of entry into force and application. This means that the textile component of a composite product may become mandatory at a different time than another component. Until a delegated act is adopted and published, neither component is subject to an obligation for a digital product passport under the ESPR. Once a text is published, the date will be updated here.
What to do: map out components and regulations
If you place a product with multiple components on the market, you can build the overview in this sequence. First: which components are in the product and which of these are purely textile, and which are not. Next: is there already a separate information or registration obligation for a non-textile component known from other legislation, and if so, is identification carried out in a comparable way. Then: ensure that your own business data (market participant, establishment, product model) are recorded unambiguously and consistently, so that they can later serve seamlessly as a unique identifier within the meaning of article 12 — that unambiguity is precisely what makes linking between digital product passports possible. For the textile component, the ordinary route applies: data from the manufacturer or importer are collected, the digital product passport is compiled and hosted for ten years, with a QR data carrier as access. For any other component of the same product that falls under a different regulation, responsibility and completion lie outside the textile digital product passport — that is linked via the unique identifier, not taken over.
Legal basis: article 9 and article 12 ESPR
That a product can have multiple digital product passports, and that linking instead of duplicate recording is the starting point, follows from the general structure of the digital product passport in article 9 of the ESPR (Regulation (EU) 2024/1781), which takes account of existing or parallel information obligations from other Union law. The linking itself runs via the unique identifiers for product, market participant and establishment from article 12 of the same regulation. Both articles govern the framework; the concrete implementation per product group — including any specific rules on combination for composite products — follows from the delegated act for textiles and clothing still to be published.
If you are already placing or preparing a composite product on the market, the most prudent course is to start by mapping out the components and the legislation that may already exist for them, and to organize your own business and product registration as unambiguously as possible. For the textile component of the product, it is sufficient for now to follow when the delegated act for clothing is published; that publication determines both the date and the precise rules on any linking with other digital product passports.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 12 (unique identification code)
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
A garment can be subject to multiple regulations simultaneously. A jacket with an integrated electronic heating element, a backpack with a built-in power bank, or a shoe with a chip for authentication: these are all products where textile rules and other product rules can apply at the same time. The ESPR (Regulation (EU) 2024/1781) is a framework regulation: Article 9 requires a digital product passport, but the precise content and timing of implementation are determined separately for each product category through delegated acts. This means that a product with multiple applications could theoretically fall under the delegated act for textiles and also under that for another product category, if both are declared applicable.
Check whether one product is subject to more than one regulation
For a company with 10 to 100 employees, this primarily means: it is not automatically the case that "clothing" equals "one passport obligation". For products that contain an electronic, electrical or other functional component that itself also falls under ESPR regulation, it is worth checking whether more than one set of requirements applies. This requires examining the product file by product category, not only on the basis of the description "textile" but on the basis of the actual composition and function of the product.
One unique identification code per product, even with multiple passports
Article 12 of the ESPR requires a unique identification code per product. If a product is subject to two regulations, the question arises how that identification relates to any separate passports. The regulation assumes one digital product passport per product, linked to that unique code — not two separate passports that exist side by side for the same physical article. How that identification code is set up in practice is described on the page about how I assign each product a unique identification code.
One data carrier, even if the information comes from multiple sources
Even if the data in the passport come from different regulatory frameworks — for example textile data from the clothing manufacturer and data on an electronic component from a different supplier — the starting point remains that there is one access point on the product. How that QR code ends up on the garment and what practical aspects are involved is explained on the page about how the QR code for the product passport comes onto my clothing and textiles.
Coordinate who provides which part of the data
For a product containing components from different suppliers, the practical question arises of who provides which data and who is responsible for the accuracy of which part. This is not a question that the regulation regulates in detail for every conceivable product combination; it is an arrangement that can be made between the parties in the supply chain, in anticipation of the delegated act that will apply to the relevant product category.
Where things go wrong in practice
A first scenario: a company assumes that "textiles" and "electronics" are separate domains, and treats a product with an integrated electronic component purely as a garment. Once the delegated act for that other product category comes into force, the product turns out to fall under it as well, while the passport process was not set up for that.
A second scenario: two separate passports are inadvertently created for one physical product, because two departments — or two suppliers in the chain — independently have a passport drawn up. This results in two unique identification codes for what is one article, causing confusion for both the seller and a possible regulator.
A third situation: the QR code on the product refers to a passport containing only textile data, while an integrated component requires its own passport data that is not linked to that data carrier anywhere. The consumer who scans the code then gets an incomplete picture of the product.
A fourth situation: for a composite product, the textile data and data on the other component are supplied at different times, without recording who supplied which part and who is accountable for it. If a correction is needed later, it is no longer possible to trace who provided the data.
A fifth situation: the company thinks the problem "will be solved later, once the delegated act is in place", and sets up no internal structure to identify composite products. When the delegated act is in place, the existing collection must then still be searched retroactively.
What you can record
- An overview of products in the collection that contain a non-textile component with a possible own passport obligation, so that this group can be tracked separately.
- An internal agreement on who, for a composite product, is responsible for which part of the data — the clothing manufacturer for the textile, the supplier for the other component.
- A documented procedure for assigning the unique identification code per physical product, so that two codes for one item do not accidentally arise; see the explanation on assigning a unique identification code to each product.
- Documentation on how the product passport is structured when data comes from multiple sources, including date and version of supply per component.
- A documented agreement on the link with your own ERP or inventory system, so that composite products are registered there as recognisable as such; see the page on linking the product passport to your own system.
- A procedure for correcting data in an already published passport, in case it turns out that a component was inadvertently not included; see the page on correcting an error in a published product passport.
Once the delegated act for clothing with eighty per cent or more textile fibres has been published, and once it becomes clear how other product groups relate to this for composite items, this page will be supplemented with the concrete rules that will then apply.
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.