must I indicate in the product passport whether clothing can be repaired
Repair information is standard with the product passport
Yes, repair information is one of the topics that the ESPR explicitly mentions as part of a product passport, and for textiles and clothing it is straightforward that this will be included once the delegated act for this product group is available. The ESPR is a framework regulation: articles 5 to 7 of Regulation (EU) 2024/1781 (ESPR) mention repairability as one of the product aspects for which ecodesign requirements can be set, and article 10 of that regulation determines that the passport must contain the information that follows from the product-specific rules. Whether and how repair information is precisely made mandatory for clothing and textiles is thus not fixed in the framework regulation itself, but is filled in by the delegated act that comes specifically for this product group.
For which products and for which information this applies — and for which it does not
This topic applies to clothing and textile products that will fall under the announced delegated act, with clothing of which eighty per cent or more consists of textile fibres as the first group. What it concerns is not only "can this product be repaired yes or no", but possibly also practical information: where to have a repair carried out, which parts are replaceable, or instructions for minor repairs yourself. What exactly will be included is only fixed once the product-specific rules are published — the framework regulation gives the direction, not the complete list of mandatory fields. This topic is separate from the care label and care symbols, which serve a different purpose; how these two relate to each other is described on the page about the care label in relation to the product passport. It is also not about the question of whether a brand is required to offer repairs itself — that is a completely different kind of obligation than mentioning information about it.
No fixed date yet, but a fixed direction
There is no definitive date yet on which repair information for clothing and textiles must be mandatory in the passport. What is fixed: according to the ESPR work plan 2025-2030, the delegated act for this product group is expected in 2027, with clothing of eighty per cent or more textile fibres as the first category that falls under it. Until the delegated act is published, there is no legal obligation to include repair information in a product passport — simply because the passport for clothing and textiles is not yet mandatory then. As soon as the text of the delegated act is known, the specific date and exact content of the repair requirement will be stated here.
What a brand or importer can do with this
Anyone who is already working on a product passport or is thinking about it, would be well advised to include repair information as a fixed part of the data structure, even if the obligation is not yet definitive. In practice, this means: first establish what repair information is available for a product or can be created — think of a repair guide, contact details of a repair service, or an overview of replaceable parts such as zips and buttons. After that, it is a matter of structuring that information in the same way as other passport data, so that it can later be added to the final passport without much extra work. This aligns with the broader question which data appears in the product passport for clothing and textiles, where repair information is one of the possible categories alongside fibre composition and chemical treatments. It is also useful to think about who will be able to access this information later — a repairer needs different data than a consumer or a regulatory authority, and that distinction is further explained on the page about who may access which data from the digital product passport. A brand that already maintains repair information for its own use — for example for a repair service or warranty policy — already has a basis that aligns well with what can be expected in the passport.
The legal basis: Article 10 and Articles 5 to 7 of the ESPR
The obligation that a product passport can contain information about repair follows from the combination of two parts of the ESPR. Articles 5 to 7 of Regulation (EU) 2024/1781 (ESPR) establish that eco-design requirements may in particular concern repairability, as one of the product aspects that influence the sustainability and circularity of a product. Article 10 of that regulation then determines that the digital product passport contains the information established in the applicable delegated act for that product category. For clothing and textiles, that delegated act does not yet exist; it must still be established and published before it becomes clear which repair-related data will be required and in what form.
What to do now
Whoever now wishes to record repair information can best do so in a way that aligns with the rest of the passport data: structured, per product, and separated from marketing texts. Once the delegated act for clothing and textiles is published, the specific repair information that becomes mandatory and the date from which it applies will be stated here. Until then, building up a basic file — which components are repairable, what instructions exist, what repair services are offered — is a worthwhile preparation that will not be lost.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Articles 5 to 7 (requirements regarding ecodesign, performance and information requirements)
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
Repair information is one of the categories that the ESPR names as possible content of a digital product passport. Article 7 of the ESPR (Regulation (EU) 2024/1781) lists what information requirements can be established for a product category, and data on repairability — such as the availability of spare parts, repair instructions or a repairability score — are explicitly included. Whether this becomes mandatory for clothing and textiles depends on the delegated act that is established per product category on the basis of Articles 5 and 6 of the ESPR. For textiles, that act does not yet exist. What exactly must be done in practice is therefore not yet established — but the possibility that repair information becomes a mandatory part is clear given the earlier signals from the European Commission about textiles as a priority product category.
Repair information can become mandatory, but is not yet
For a company of 10 to 100 employees, this above all means: there is currently no legal obligation to include repair data in a product passport, but it is also not advisable to completely disregard this subject. The structure of the ESPR makes clear that repair information is part of the core of "eco-design", alongside for example sustainability and reusability from Article 5. A company that is already working on setting up the product passport — think of recording the fibre composition or the proportion of recycled fibre — would be wise to also inventory what repair data actually exists within its own supply chain.
If repair information becomes mandatory, that information must be there
Should the delegated act for textiles make repair information mandatory, the question shifts from "must it be included" to "where does that information come from". For many clothing companies, this is a real challenge: repair data does not arise automatically during production, it must be actively collected or prepared. A brand that has clothing made at an external manufacturing facility usually does not have that information in-house, and must then obtain it from the manufacturer or supplier — just as already applies for other data that is included in the product passport for clothing and textiles .
The information must remain correct and up-to-date
Repair information is not static. A spare part that is available today may not be available in two years; a repair instruction can change if a production process changes. Article 10 of the ESPR sets requirements for the reliability and accessibility of data in the digital product passport throughout the entire lifespan of the product. For a company, this means that repair data, once entered, is not a one-time exercise but becomes part of an ongoing process — comparable to the way the data in the product passport must be kept up-to-date.
Where things go wrong in practice
A first situation: a brand assumes that repair information "will come later" and pays no attention to it now, while its own suppliers are not set up at all to provide such data per model or batch. If the obligation comes, the lead time to set this up is suddenly short.
A second situation: a company confuses repair information with the care label or care instructions. These are two different things — one is about washing and ironing, the other about restoration following wear or damage. Whoever mixes these up runs the risk of publishing incorrect or incomplete data. The relationship between these two components is worked out on the page about how the care label relates to the product passport.
A third situation: an importer thinks that repair data is commercially sensitive — for example because it says something about the quality of seam constructions — and therefore wants to shield it. Whether that is possible, and for whom such information may eventually be visible, is a different question from whether the information should be there; these two questions are often merged, when they should be answered separately. See on this subject commercially sensitive data on clothing and textiles and who may access which data from the digital product passport.
A fourth situation: a company publishes repair instructions in one language, while the product is sold in several Member States. As soon as repair information becomes part of the passport, the same language question that is already relevant for other data applies — see in which language the data in the product passport must be presented.
A fifth situation: a brand confuses "repair information" with a repairability score or sustainability label, and thinks it is sufficient to show a score without listing underlying instructions or spare parts availability. This is a related but not identical subject — see also whether clothing receives a sustainability score in the digital product passport.
What you can record
- An overview per product line or model of which repair data already exists: repair instructions, availability of spare parts, contact point for repair.
- Agreements with manufacturers or production facilities on who provides which repair data, and in what format.
- An internal process to review repair data when a production process, material or supplier changes.
- A list of which repair data per market or language area must be available, once this becomes relevant.
- A brief note on the status of the delegated act for textiles, so that it is clear internally that repair information is not currently mandatory, but is being monitored as a possible subject.
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 2026-09-05. Is something not right? Let us know — corrections are given priority.