How does the care label relate to the product passport?
The care label stays, the passport comes alongside it
The care label with washing instructions is not the same as the digital product passport, and one does not automatically replace the other. The care label is the physical label in the garment with the familiar symbols for washing, bleaching, drying, ironing and steaming. The digital product passport is a different type of information carrier: a digital file with product data, accessed via a QR code or comparable data carrier, as the ESPR describes in Article 10. The ESPR does make room in Article 16 for labels that can be made mandatory through a delegated act — physical or digital — alongside or as part of the passport. Whether and how the existing care instructions are included in it is a matter for the delegated act on textiles, which does not yet exist.
Which information this does and does not apply to
This explanation concerns the relationship between two information carriers on a garment: the existing care label and the future digital passport under the ESPR. It does not address whether the care label itself is mandatory or must remain — that is a matter outside the sources used here and will be determined by each delegated act. Nor does it address what content the passport must ultimately contain; Article 10 of the ESPR describes the requirements that a digital product passport must generally meet, but which data is specifically mandatory for clothing will only be confirmed once the delegated act on textiles is published. What is relevant now: Article 17 of the ESPR prohibits labels that could be confused with a label or trademark recognised by the ESPR. This affects the practice in which a care label or proprietary care label inadvertently — or deliberately — resembles an official passport or ESPR symbol.
No fixed date yet, but a fixed order
There is no date yet on which clothing must fall under the digital product passport; the ESPR's work plan mentions 2027 as the expected time for the delegated act on textiles, with clothing of eighty per cent or more textile fibres as the first category. Until that act exists, nothing changes in the care label itself under the ESPR: current practice with care instructions and symbols continues as it is now. What is already established is the framework within which a future passport must fit: Article 10 describes the general requirements for a digital product passport, and Article 16 shows that the legislator treats labels and passport as two separate instruments that can exist side by side. Once the delegated act on textiles is published, it will state whether and how maintenance information is included in the passport, and whether the physical care label changes as a result.
What to do: from label to passport data
For those already working with a product passport, the practical order is as follows. First: the care label in the garment does not need to be changed for now, because the ESPR does not currently require anything specific in that regard. Then: the information on the care label — the care instructions, fibre information, maintenance instructions — is the kind of information that logically also becomes available digitally, because a product passport by definition brings together more data than fits on a small piece of fabric. Those who structure this data now with the manufacturer or importer will not need to do so again once the delegated act is published. Finally: when designing a proprietary care label or trademark, it is advisable to take account of Article 17, which does not permit confusion with officially recognised labels or the future passport symbol — a consideration that can be taken into account now, even though the final design of the passport has not yet been established.
Where it is stated: Articles 10, 16 and 17 ESPR
The relationship between the care label and the digital product passport is established by three articles of the ESPR (Regulation (EU) 2024/1781). Article 10 describes the requirements for the digital product passport as a separate information carrier. Article 16 regulates the possibility to require labels separately from the passport via a delegated act — demonstrating that the legislator recognizes both instruments alongside each other. Article 17 prohibits labels that could be confused with a recognized label or trade mark, which is relevant once a proprietary care label or care symbol touches upon symbols protected by the ESPR.
What to do now
Anyone preparing a clothing line now can leave the existing care label unchanged and at the same time record the underlying data — fiber composition, care instructions, country of origin — in a structured manner with the manufacturer or importer, so that this data can be incorporated into the digital passport without additional effort as soon as the delegated act for textiles is published.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 16 (labels) and Article 17 (counterfeit labels)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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 care label remains in place alongside the product passport
The care instruction on the care label — whether or not to iron, which wash temperature, whether or not to use the dryer — does not disappear with the arrival of the digital product passport. Article 16 of the ESPR (Regulation (EU) 2024/1781) regulates the labels that are on or attached to a product, and the product passport comes there according to Article 10 of the ESPR alongside, not in place of. For a company with 10 to 100 employees, this means in practice that the existing procedure for sewing or printing the care label continues unchanged, and the passport adds a separate, digital layer of information.
The passport is not a replacement, but a supplement
Where the care label shows a limited set of symbols directed at the care of the garment, the product passport is intended to unlock a broader range of data: from fibre composition to chemical treatments to repair possibilities. A company that compiles the passport is well advised to determine in advance which data already appear on the care label and which data must be included separately in the passport — see also which data are included in the product passport for clothing and textiles?. Overlap between label and passport is not in itself a problem, as long as both sources do not contradict each other.
Consistency between label and digital data
Article 17 of the ESPR deals with labels that create a misleading impression or imitate the passport. That article is particularly relevant to the question of whether a physical label may present itself as (part of) the official digital product passport, or vice versa. For the practice of a clothing brand, this means that the information on the care label and the information in the passport must not be contradictory: if the label indicates "do not iron", the passport cannot contain opposite care advice. For companies working with multiple production lines or seasonal collections, this is a point of attention when maintaining the data — see also how often must I update the data in the product passport?.
The QR code as a link between label and passport
The data carrier — usually a QR code — forms the practical link between the physical garment and the digital product passport. This code can be placed on or next to the care label, but does not replace the symbols on the label itself. For companies that have their labels produced by an external supplier, this means that the agreements with that supplier must be expanded: not only the wash symbols, but also the placement and readability of the QR code must be specified.
Where things go wrong in practice
A common situation is that the care instruction on the care label is determined by the textile supplier, while the passport is compiled based on data that come in through another channel — for example from the importer. If these two sources are not compared, there is a risk that the passport shows different care advice than the label on the garment itself.
A second situation occurs with private label collections, where the same basic product comes on the market in multiple variants (different colour, different yarn percentage). The care label is then adjusted per variant, but the passport is sometimes drawn up as a single generic document for the entire line. This can result in a passport showing care information that is correct for one variant, but not for another.
A third situation arises when a company changes the fibre composition — for example by increasing the proportion of recycled material — without reassessing the care instruction. A change in fibre composition can have implications for the wash advice, and these two pieces of data are therefore linked. See also how do I record the fibre composition in the product passport?.
A fourth situation is that the QR code is physically affixed separately from the care label (for example, on a hang tag that is removed after purchase), causing the link between the durable care label in the collar and the digital product passport to disappear over time. For the consumer who washes the garment years later, only the care label remains — which underscores that the label retains its own, lasting function alongside the passport.
A fifth situation is that chemical treatments that affect the care instruction — such as a crease-resistant finish or a water-repellent coating — are mentioned in the passport but have not been incorporated into the care instruction on the label, or vice versa. See also which chemical treatments must I report?.
What you can record
- An overview per product or product line of which maintenance data appear on the care label and which data are (additionally) included in the passport.
- A working agreement with the textile or label supplier on when changes to the care instruction are communicated to the party that compiles the passport.
- A review point when fiber composition or chemical treatment changes, to verify that the care instruction on the label still aligns with the data in the passport.
- An established procedure for the placement of the QR data carrier, so that it does not become detached from the garment and remains linked to the physical care label.
- An internal template in which the care instruction and passport data applicable to each product variant are recorded, particularly for private label lines with multiple variants.
- An overview of who within the company is responsible for keeping this link up to date, and how frequently this is reviewed.
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.