What does the product passport mean if I sell clothing and textiles through an online marketplace?

The passport obligation stays with the product, not with the sales channel

Selling via an online marketplace does not change whether a garment must have a digital product passport. The passport belongs to the product itself, linked via the QR code on the label or packaging. Whoever manufactures or imports a garment and places it on the market is the one who must have the passport compiled — regardless of whether the product subsequently reaches the consumer through their own store, their own webshop or via a marketplace such as Bol, Amazon or Zalando. In addition, the marketplace itself, as a platform, has its own role: Article 35 of the ESPR (Regulation (EU) 2024/1781) describes obligations specifically for online marketplace providers and search engines, separate from the obligations that rest on the manufacturer, importer or trader.

For brand owners and importers, not for private sales

These rules are written for parties that place clothing and textiles on the market as a business: brands, importers and private label contractors, and the traders and distributors who resell these products — Articles 30 and 31 of the ESPR apply lighter obligations to them than to the manufacturer or importer. What does not fall under this, or at least not without further consideration: private sales between consumers, for example second-hand clothing offered by a private individual via a marketplace. The ESPR is aimed at products placed on the market in the context of a commercial activity, and the precise definition of what this includes in the resale of used clothing is not developed in the articles that apply here. For that situation, the official text and any further guidance is the appropriate source.

No fixed date yet, but a timeline

There is no fixed date yet for when the product passport for clothing becomes mandatory, including for sales via a marketplace. The ESPR itself is a framework regulation; the actual obligation for a product category only arises with a delegated act for that category. For textiles, such a delegated act has not yet been published. According to the European Commission's work plan for 2025-2030, it is expected in 2027, with clothing consisting of eighty per cent or more textile fibres as the first category. Until that act is published and becomes applicable, there is no obligation to have a digital product passport — not for the manufacturer or importer, not for the trader, and not for the marketplace. As soon as more information about the final date is available, it will be updated here.

What this means for the sales chain

The first step is to determine which role applies: whoever has the garment made or imports it will be responsible for having the passport compiled — this will be based on the data that this party provides, regardless of which channel the product is sold through. Whoever only resells clothing without being a manufacturer or importer themselves falls more under the lighter obligations for distributors and traders from Articles 30 and 31: think of checking that the passport is present and not themselves altering or removing what has already been applied. The second step is to check how the marketplace itself handles this: platforms receive their own obligations via Article 35, which may mean that a marketplace will eventually set its own requirements for listings, for example around displaying the QR code or providing passport data on the product page. The third step is practical: the QR data carrier and the underlying passport data travel with the product, so a garment that is sold through multiple channels — own store, own webshop, marketplace — only needs one passport. There is no need for a separate passport per sales channel.

The legal basis: Articles 30, 31 and 35

That the obligation attaches to the product and not to the sales channel follows from the design of the ESPR: the regulation assigns different roles to manufacturers and importers on the one hand (Article 30 and 31, obligations of distributors and traders) and providers of online marketplaces and search engines on the other (Article 35). These articles describe separate obligations for separate parties in the chain, which indicates that the legislator sees sales via a marketplace as an additional link, not as a replacement for the obligations already resting on the manufacturer or importer.

If you are already working with textiles and selling via a marketplace, it is best to get your own data on material composition, origin and production in order, so that it is ready as soon as the delegated act for textiles is published — and in the meantime keep an eye on announcements from the European Commission about that act.

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

An online marketplace itself receives its own set of obligations under the ESPR, separate from those of the sellers who use it. Article 35 of the ESPR (Regulation (EU) 2024/1781) addresses specifically providers of online marketplaces and search engines. Additionally, the usual requirements for distributors and traders under Articles 30 and 31 of the ESPR continue to apply — and a marketplace can, depending on the role it fulfils, be regarded as acting in multiple capacities at the same time.

The marketplace as a conduit for information

For a provider of an online marketplace, the primary concern is that the information associated with a product listing — including data from the digital product passport — is made visible to the potential buyer before that buyer purchases. The marketplace is not the one who compiles the passport or invents the data, but rather the one who ensures that a QR code or comparable data carrier is visible with the listing. For a company with 10 to 100 employees that operates its own webshop or platform where third parties also sell, this means that the way product pages are constructed must provide space for this data carrier and that there must be a process to check whether sellers actually provide that information.

The seller on a marketplace remains responsible

Whoever sells via a marketplace does not change their own position in the chain by doing so. A company that is a manufacturer, importer or distributor remains so — the marketplace is a sales channel, not a party that takes on the company's own obligations. What those own obligations are exactly depends on the role: a company that has clothing made under its own brand and brings it to market falls under a different set of obligations than a company that resells existing textiles from a third party. For the distinction between those roles, the page Am I an importer or manufacturer according to the ESPR? is a logical starting point.

If the marketplace acts as a distributor or trader

In some setups, the marketplace itself takes on the role of distributor or trader — for example when inventory is stored and shipped via the marketplace, or when the marketplace itself acts as a selling party to the outside world. In that case, the marketplace is subject to the same obligations as any other distributor or trader under Articles 30 and 31 of the ESPR, such as checking whether a product is accompanied by the required information before it is offered for sale. What those obligations entail is set out on the page What obligations does a distributor or trader of clothing and textiles have?.

Visibility of the data carrier in the listing

A recurring practical point is that the QR code or other data carrier must be visible with the listing itself, not only after purchase or solely on the physical product once it has already been delivered to the customer's home. For companies selling via multiple marketplaces at the same time — their own webshop, a large marketplace, and perhaps a second platform in another country — this means that on each of those channels separately it must be checked whether the data carrier is displayed correctly, because the technical layout of product pages differs per platform.

Where things go wrong in practice

A common situation is when a company assumes that the marketplace "will handle it" because it has its own obligation under Article 35. However, the marketplace only ensures that information is made visible — it does not itself retrieve that information from the manufacturer and does not compile a passport.

A second situation: a product is shown correctly on the company's own webshop with a QR code, but the same listing on a marketplace lacks the data carrier because the product feed exported to the platform does not include that field. The problem then lies not in the data itself, but in the technical connection between the company's own system and the platform.

A third situation arises when a company sells products via a marketplace that are supplied by a manufacturer outside the EU, without it being clear who in that chain fulfils the role of importer and is therefore responsible for the passport. The marketplace plays no role in this — that responsibility lies with the party that brings the product onto the EU market, as described on the page My manufacturer is located outside the European Union — who will arrange the product passport then?.

A fourth situation: private label sellers who assume that, because the product is sold under their own brand and via a marketplace, the obligation lies with the marketplace or the manufacturer. Those who use their own brand typically have their own position in this, as explained on the page I sell clothing and textiles under my own brand — what obligations do I get?.

A fifth situation occurs with companies that do not run their own marketplace but do sell on one, and who think that as a "small player" they remain out of the picture. The obligations that apply to manufacturers, importers or distributors do not depend on company size or the chosen sales channel.

What you can record

An overview of all sales channels (own webshop, marketplaces, platforms in other EU countries) with a check per channel to verify that the data carrier appears correctly in the product display.
Agreements with the marketplace or platform on how product data, including the link to the digital product passport, is transmitted via the feed or API.
An internal assignment of the role that the company itself fulfils per product line — manufacturer, importer, distributor — so that it is clear who in the organisation is responsible for providing passport data.
Documentation of the origin of products sold via marketplaces, including data of the manufacturer or importer, so that when questions arise from a marketplace or supervisory authority it can quickly be demonstrated who has supplied which information.
A fixed procedure for checking new listings before publication, so that a missing data carrier is noticed before the product is visible to customers.

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.