what should I pay attention to when choosing a supplier for the product passport

Pay attention to the link with the data registers, not just to a nice dashboard

A software solution for the product passport you choose based on what happens under the hood: how the data are stored, who can access them, and whether the system connects to the registration register that the European Commission is setting up. Article 10 of the ESPR (Regulation (EU) 2024/1781) sets requirements for the passport itself — which data it must contain, how long they are kept, who may modify them — and article 11 concerns the technical design: how the passport is structured, linked to a unique carrier, and read by a QR-code or similar system. A supplier offering this platform must therefore not only sell a solution that produces a passport today, but one that does so correctly over the years to come, even as the technical standards are further developed.

This concerns the technique, not the content of your assortment

The choice of a software supplier is a different question from whether a specific garment falls under the obligation. Which products precisely fall under the digital product passport and when is described in what a digital product passport for clothing and textiles precisely comprises and in the guidance on whether the product passport applies to a specific assortment. This article does not address that substantive scope, nor does it address the costs of a passport — that is covered in the overview of what a product passport for clothing and textiles costs. Here it concerns specifically the criteria by which to assess a supplier or platform, irrespective of who manufactures or sells the product.

The obligation is not yet fixed, the technical requirements are already fixed in part

There is no fixed date on which software choice becomes unavoidable. The delegated act for textiles is expected according to the work plan of the European Commission for ecodesign of sustainable products, with clothing with a high proportion of textile fibres as the first category. As long as that act has not been published, it is not determined from which moment a passport becomes mandatory. What is already fixed are the general requirements for the digital product passport from articles 9, 10 and 11 of the ESPR: these form the framework within which each delegated act for a product category is further developed. A supplier preparing for this now is therefore not too early.

Five points to go through with a supplier

The first question is whether the system can link data to a unique product identification and a carrier such as a QR-code, as article 11 of the ESPR describes. A solution that only generates a loose PDF file does not meet the idea of a passport that is continuously accessible and updatable. The second question is who enters and manages the data: with a private label or import the information often runs through multiple parties, and a system that clearly separates roles and rights — manufacturer, importer, brand — prevents anyone from no longer knowing who made the last update or may do so. The third question concerns the retention period and hosting: article 10 sets requirements for the availability of the passport during the product's lifetime, so a supplier who only offers a subscription for a couple of years without clarity on what happens afterwards leaves a gap in coverage.

The fourth question concerns data sources: can the system import data that already exists elsewhere, such as from a supplier statement, test report or fabric list, or must everything be entered manually. This also touches on the question of who is responsible for translation of data into the languages of the markets where a product is sold — a subject that is further developed in the guidance on who arranges for translation of product passport data. The fifth question is how the system handles changes after publication: a product passport is not a snapshot, and a supplier that offers no version control or adjustment capability makes it difficult to correct errors or update data without going through the entire chain again.

Furthermore, it is worthwhile to look at how a supplier handles the physical aspect of the data carrier: whether the QR code aligns with existing labels and packaging, or whether adjustments are necessary — a question that also comes up when considering whether clothing labels and packaging should now be adapted. Anyone wishing to tackle this step by step will find a sequential approach in the overview of how the product passport for clothing and textiles is being tackled step by step.

Where that is stated: articles 9, 10 and 11 of the ESPR

The basis for these criteria lies in article 9 of the ESPR (Regulation (EU) 2024/1781), which introduces the digital product passport as an instrument, supplemented by article 10 on the specific requirements for the content and availability of the passport, and article 11 on the technical design and operation, including the link with a unique carrier. The regulation itself does not cover a specific product category such as clothing; this is done through delegated acts, the planning of which can be found on the European Commission's website on the regulation for ecodesign of sustainable products.

Anyone who is now orientating themselves towards a supplier can use these five points as a checklist in a conversation or demo, and lay their own situation — assortment, supply chain, existing systems — alongside it to see which supplier fits best there.