How does the QR code for the product passport end up on my clothing and textiles?

What you must do concretely

What is expected of you

The data carrier is placed physically on the product or packaging

Article 11 of the ESPR (Regulation (EU) 2024/1781) requires that the digital product passport is unlocked via a data carrier — in practice a QR code — which is placed on the product itself, on the packaging or on an attached document. For clothing and textiles, a printed or woven label with QR code is most practical, comparable to the existing care labelling. For a company with 10 to 100 employees, this means an adjustment to the production process: the label supplier or garment manufacturer must receive the code before the garment leaves the factory. This requires coordination with the manufacturer or, for private label, with the manufacturing partner that applies the labels.

The code must lead to a functioning passport, per unique product

The QR code is not decoration — it must actually link to the product passport that belongs to that specific product. This presupposes that each product (or each product variant) already has its own identification code; how this is set up exactly is described on the page about how each product receives a unique identification code. For a brand with multiple sizes and colours per model, this is more than a technical detail: it determines whether there is one QR code per model or one per variant, something that is further elaborated on the page about whether each size and colour receives its own product passport.

The data carrier must remain durably legible

Article 11 requires that the data carrier and the information contained in it remain available for the period during which this is relevant for the product. For textiles, this means that a printed label must not fade, come off or become illegible through washing and wear. Companies working with textile suppliers should practically consider wash resistance and durability when choosing labels — this relates to how long a passport must remain available, a question that is addressed separately on the page about how long a product passport must remain available.

The label and QR code must not be misleading

Articles 16 and 17 of the ESPR concern labels in a broader sense and the prohibition of counterfeit or misleading labels. For a clothing brand, this means that the QR code for the product passport must not be confused with other codes on the product — for example a marketing code, a promotional offer or a proprietary quality mark. Where multiple QR codes appear on one garment, distinction between these codes is practically relevant, especially for products that fall under another regulation in addition to the textile passport; this relates to the subject of how multiple product passports for one product work together.

The underlying structure often follows a standard

Article 11 leaves room for technical standards that shape the data carrier. In practice, existing GS1 standards are often consulted for product identification and QR codes, which are also used in other sectors for traceability. What this means for the product passport and whether it is mandatory is set out on the page about what GS1 Digital Link is and whether it is necessary for the product passport.

Where things go wrong in practice

The QR code is ordered outside the production process. A brand has labels printed by a specialized supplier, but the link between QR code and product data is only made after production. The result: boxes of clothing where nobody can say exactly which code belongs to which variant.

One QR code for an entire collection. To save costs, one generic code is placed on all shirts of a line, without distinction between sizes or colours. Once the passport must show different data per variant (for example a different fibre percentage per colour), this no longer works.

The label fades or breaks during washing. With cheap printed labels, the QR code becomes illegible after a few washes. This is particularly a risk when printing directly on fabric instead of using a separate woven or laminated label.

Confusion between marketing QR and product passport QR. Some brands place a QR code on the same label linking to a web shop page or loyalty programme, alongside the code for the product passport. Without clear differentiation, the consumer — and the regulatory authority — cannot tell which code has which function.

No plan for what happens when an importer or brand changes. Clothing is sometimes sold through multiple channels or reintroduced to the market under a different label. If the QR code still points to the passport of the original holder, this creates confusion about who is responsible — a situation that touches on the question of what happens to the passport when a company stops operating or changes ownership, detailed on the page about what happens to the product passport when a company stops operating.

What you can record

• An overview of which supplier or manufacturing partner is responsible for applying the label with QR code, per product line or collection.
• The technical specification of the label: material, printing method and wash resistance, coordinated with the label supplier.
• The link between unique product identification code and QR code, documented per model, size and colour.
• A test procedure to verify before shipment that the QR code actually points to the correct, current passport.
• Agreements with importers or reselling parties about who manages the QR code and the underlying passport when a product changes ownership.
• An internal protocol for the event that an error in a published passport is discovered after the QR code is already on the product; how that process works is described on the page about updating a published product passport.