the product passport also applies to household textiles such as curtains and bed linens

What you must do concretely

What is expected of you

The ESPR is a framework regulation: Article 1 makes clear that the regulation applies to products in general, and only per product category via a delegated act is it laid down which requirements exactly will apply and when. For clothing and textiles, it has not yet been published which products exactly fall under the first obligation. Household textiles such as curtains, bed sheets, duvet covers and towels are textiles in the ordinary meaning of the word, but whether they are also textiles within the meaning of the first delegated act is not yet certain. What is expected of a company in the meantime can therefore be split into two parts: what already follows with certainty from the regulation itself, and what only becomes clear later.

Check whether your product is textile within the meaning of Article 2

Article 2 of the ESPR provides the definitions that determine what counts as a "product" and how a product category is defined. For a company with 10 to 100 employees that carries both clothing and home textiles, this means that the company's assortment list cannot be treated as a single whole. A brand that sells T-shirts, but also plaids and table linens, does well to note per product category where it falls: clothing, other textiles, or something that stays out of the first round. This is not a legal exercise in itself, but an organizational step that later, once the delegated act is there, will save much research work. More about the precise definition of product categories is in what is a delegated act and why does it determine what I have to do.

Follow which textile products are first in line

The ESPR work plan names clothing with a share of eighty percent or more textile fibres as the first category for the delegated act expected for this sector. Household textiles are not explicitly mentioned there. For a company that mainly or exclusively manufactures or sells home textiles, this means that there is practically less urgency than for a clothing brand, but not that there is nothing to follow: the work plan extends to 2030 and other textile products may follow in later phases. Anyone who wants to know exactly which products are already mentioned with a date will find that overview in which products from the clothing and textile sector fall under the ESPR.

Make a distinction between clothing, accessories and home textiles in your own administration

Brands that combine clothing with accessories, bags or shoes face a similar question as with household textiles: each category can get its own timeline. It is practical to organize product administration so that you can see per article group under which regulation it potentially falls, rather than having to find out afterwards what applies where for each article. For the question of how this applies to bags, shoes and belts, there is a separate overview: the product passport also applies to shoes, bags and belts.

Do not anticipate an obligation that does not yet exist

There is currently no passport obligation for household textiles, and there is no published date on which it would come into effect. That does not mean there is nothing to do: it means that the effort now lies mainly in putting the basic data in order (fibre composition, origin, production steps) that will later, when a delegated act does exist, be needed again. A business that already keeps these data in a structured way for the clothing line can often apply that same structure to the household textiles line without much adjustment as soon as that becomes relevant.

Where things go wrong in practice

A first situation that often occurs: a brand sells clothing and bedding under one brand name and assumes that what applies to clothing automatically also applies to bedding (or does not apply), without checking. That can go wrong either way.

A second: an importer of curtains and table linens reads messages about the obligation for clothing with eighty percent or more textile fibres, and assumes that this also automatically applies to curtain fabric of the same fibre composition, while the delegated act focuses on clothing products.

A third: a business spends time on the passport for the clothing line, but does not register the fibre composition and origin of the household textiles line, with the result that if the obligation is later expanded, it still has to start from scratch for that line.

A fourth: a wholesaler who buys both clothing and household textiles from the same manufacturer assumes that one set of supplier data for all products is sufficient, without recognizing that a delegated act can require different data per product group.

A fifth: samples and showroom models of a new household textiles line are placed in the same administration as sales-ready stock, making it unclear which pieces will later actually fall under a possible obligation; the question of how this applies to samples in general is set out in do I need a product passport for showroom samples that are not sold.

What you can record

• A product category classification of your own assortment (clothing, household textiles, accessories, other), with a note per category on whether and when a passport obligation is known.
• Fibre composition and origin data per product line, also for lines for which there is currently no obligation, so that this data does not have to be collected again later.
• A fixed moment (for example every quarter) to check whether there is news about the delegated act for textiles, and who within the company monitors this.
• An overview of suppliers per product category, so that if a new obligation arises, it is immediately clear from whom which data must be requested.
• Documentation of samples and showroom pieces separate from sales stock, with a brief description of the status of each piece.

Those who want to read more broadly about what is already established for clothing itself will find that in does the digital product passport apply to my clothing and textilesand a general introduction to the background of the passport is in what is a digital product passport for clothing and textiles.