How do I approach the product passport for clothing and textiles step by step?

How to approach the passport step by step

The digital product passport for clothing and textiles is established in five main steps: gathering product data, choosing a service provider or system to set up the passport, converting the data into a passport that meets requirements, linking a QR code or similar data carrier to the product, and keeping the passport accessible throughout the product's lifetime. For clothing brands and importers, that process does not start with the QR code, but with the question of which data already exist: fibre composition, origin, country of production, any certifications. Those who have that data in order only need to ensure it is recorded and disclosed in the right way. Those who do not have it start with the manufacturer or supplier, because that data cannot be invented or estimated.

For eighty per cent textiles, not for all clothing

This step-by-step plan applies to clothing and textile products that will fall under the forthcoming delegated act of the ESPR. That act first focuses on clothing that consists of eighty per cent or more of textile fibres. Products with a lower textile content — think of clothing with a lot of leather, metal or plastic parts — do not automatically fall under the same first batch. This also specifically concerns the digital product passport under the ESPR; other obligations regarding clothing, such as labelling of fibre composition under separate textile legislation, continue to apply separately and are not included here. For brands that sell both clothing with a high textile content and products made of other materials, the distinction is therefore relevant: it determines which part of the assortment will first have to deal with the passport.

Start date not yet fixed, but a work plan is in place

There is no fixed date yet on which the product passport for clothing becomes mandatory. What is fixed is the route to it: in the ESPR work plan for the period 2025-2030, a delegated act for textiles is expected in 2027, with clothing consisting of eighty per cent or more of textile fibres as the first category. That delegated act must still be drawn up and published before a concrete implementation date becomes known. Until then, there is no legal obligation to already use a digital product passport for clothing. That does not mean there is nothing to do: the time until the publication of the act is precisely the period in which data can be put in order, so that the transition later will not be rushed. As soon as the delegated act is published, the date will be added here.

The steps in the order that works

In practice, the approach amounts to the following. First: map out which product data are already available at the manufacturer, importer or your own purchasing department — fibre composition, country of origin, certifications used, repair and maintenance information. Next: check which data are missing and request them from the party that does have them, usually the manufacturer. Then: make a choice for a way to record that data in a passport that meets the formal requirements, including the link to a QR code or other data carrier that will be placed on the product or label. Next: actually put the passport online and keep it accessible, because the passport must remain accessible throughout the product's useful life, not just at the time of sale. Finally: set up a process to keep the passport up to date when the product changes, for example if the composition is adjusted or a new supplier is used. For brands working with texpas.eu, this amounts to providing the product data; the compilation of the passport, hosting it for ten years and providing the QR data carrier is taken over from that point onwards.

The basis: articles 9 and 10 of the ESPR

This approach follows directly from the design of the digital product passport as laid down in the ESPR. Article 9 of Regulation (EU) 2024/1781 describes what a digital product passport is and that products falling under a product-specific measure must be provided with such a passport, linked to a data carrier. Article 10 of the same regulation sets out the requirements the passport must meet: what data it must contain, who must have access to it, and that the passport must remain available throughout the life of the product. Which product groups are subject to requirements and when — such as clothing with a high textile content — is not determined in these two articles themselves, but in the product-specific delegated acts drawn up on the basis of the ESPR, such as the one for textiles expected by 2027.

Those who want to start now can begin collecting and organising product data at the manufacturer or importer without waiting for the delegated act — that work is necessary anyway once the passport becomes mandatory, and then does not have to happen under time pressure.

What this is based on

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 digital product passport does not arrive on your desk all at once. It is a sum of smaller steps, and these can be divided into a couple of obligations described in Article 9 and Article 10 of the ESPR (Regulation (EU) 2024/1781). The exact conditions under which this applies to a specific clothing item will only be determined once the delegated act for textiles has been published — see Does the digital product passport apply to my clothing and textiles?What can already be seen is what steps a company of 10 to 100 employees must take once that time comes.

Collecting and organizing product data

A product passport is only as good as the data that goes into it: material composition, origin, care instructions, and depending on the final requirements, possibly more. Article 9 of the ESPR names the passport as a carrier of this product information. For a company of this size, this often means that data which is now scattered — at the supplier, in an Excel file, in an old purchase order — must be brought together for the first time in a fixed structure. This is less a legal task and more an administrative one: who has what data, and where is it located.

Ensuring the passport meets technical requirements

Article 10 of the ESPR sets requirements for the form of the passport: it must be machine-readable, linked to a unique identification, and accessible via a data carrier (such as a QR code) on the product or packaging. This is usually the part that a company does not build itself, but outsources to a platform or software provider. The practical question then is not "how do I build this", but "to whom do I give my data, and will that party still exist in ten years" — a consideration that is discussed more extensively at what should I pay attention to when choosing a supplier for the product passport.

Linking the passport to the physical product

A passport that exists only in a system does not suffice. There must be a physical or digital carrier on the product or packaging through which a user or supervisor can access the data. This directly affects the way labels and packaging are already structured, and the question of whether something needs to be changed now is different from the question of whether the passport is already mandatory — see must I already adapt my clothing labels and packaging for the product passport.

Keeping data available and up to date

The passport is not a snapshot at the point of sale, but something that must remain accessible as long as the product is in circulation. For a company of 10 to 100 employees, this means an organizational agreement: who is responsible if a product is recalled, a supplier changes, or a certificate expires. This is less a matter of technology and more a question of who within the company is the owner of that information.

Where things go wrong in practice

A number of situations come up repeatedly in practice.

Data that is held by a supplier abroad often arrives in a language that is not automatically suitable for the end user in your own market. Anyone who assumes that a passport can simply remain in English or in the source language will encounter a question that needs to be answered first — see must I arrange for translation of my product passport data myself.

Another common situation is that a company waits until the delegated act is in place, and then has to arrange everything at the same time in a short period: organize data, choose a supplier, adapt labels. This leads to rushed work at a time when there is little room to do it calmly.

Inventory that is already in place at the moment the rules come into force is a third source of confusion. Part of the collection is then already produced, packaged and sometimes already at the retailer. The question of what should happen with it is different from the question of what applies to new collections — this distinction is worked out at What do I do with clothing and textile stock already in place when the rules take effect?

Secondhand clothing and returns also create uncertainty: companies that, alongside new collections, also run a secondhand or outlet line often do not know whether the same obligations apply to them as for the first sale.

Finally, there is the situation in which a company chooses a software package without carefully considering what happens if that package ceases to exist, while the product passport must remain accessible for ten years. This is a choice that receives little attention at the moment of signing, but can be a problem years later.

What you can record

A few things can already be put down on paper, even without the definitive requirements being known:

An overview of which product data (material, origin, maintenance, certificates) per item are already available and with whom.
An agreement with suppliers about in which language and in which format they will supply data.
A designation within the company of who is responsible for keeping product data up to date after sale.
An overview of the current inventory and production cycles, so that it will be clear which batches fall under old and which under new rules.
A first inventory of possible suppliers for the technical side of the product passport, including questions about continuity and data management.

Anyone who wants to start now without waiting for the definitive rules will find a broader overview of what is sensible in that regard at What can I do now while the rules are not yet final? And anyone who wants to know what this will roughly cost in time and resources, before steps are taken, will find an indication at What does a product passport for clothing and textiles cost?

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.