must I already adapt my clothing labels and packaging for the product passport

No, not yet mandatory — but something worth planning for now

There is currently no legal obligation to adapt clothing labels or packaging for the digital product passport. The delegated act that will regulate this concretely for clothing does not yet exist: according to the work plan under the ESPR (Regulation (EU) 2024/1781), it is expected in 2027, with clothing that consists of eighty percent or more textile fibres as the first category. As long as that act has not been published, there is also no fixed date on which the QR data carrier must appear on the label or packaging. This does not mean there is nothing to do — it only means that there is currently no action that flows from a legal obligation.

Which type of adaptation this does or does not apply to

The distinction that matters here is between two very different things: adding a QR code or other data carrier to a label or packaging, and adapting the existing mandatory labelling requirements (fibre composition, care instructions, country of origin where applicable). Only the first is connected to the product passport and therefore still has no fixed date. The existing labelling obligations from other legislation remain fully in force and are separate from this process. Furthermore, it is important that the requirements for the passport itself — what information it must contain, how the data carrier must work — are still being established per product group through separate delegated acts based on Article 18 of the ESPR. For clothing, that act does not yet exist, while for other product groups such rules may already be in preparation or established. Suppliers with multiple product categories would be well advised not to confuse these two tracks.

When this will become relevant, and what applies until then

There is no fixed date to mention here. What is certain: the work plan under the ESPR mentions 2027 as the expected period for the delegated act that will address clothing with a high share of textile fibres first. A delegated act regulates, among other things, how the passport must work technically and which data carrier (usually a QR code) goes with it, as provided for in Article 11 of the ESPR. Only once that act has been adopted and published will it be clear from which point a label or packaging must contain the data carrier, and for which products exactly. Until that time, there is no obligation to adapt labels or packaging accordingly. This is not an assumption but a direct consequence of how the ESPR is structured: the general regulation provides the framework, but the concrete requirements per product group — including any transition periods — only come with that separate act.

What can be done now, in the order that makes sense

First, it is useful to look at what is already established regardless of the date: the mandatory basic information about a garment (material, origin where relevant, care instructions) does not change because of the product passport, so no adjustment is needed for this process. After that, it is more sensible to look at your own data management than at the label itself: what information about a product is already recorded, where does it come from, and is it available per item or batch. This is work that will be necessary anyway once a passport needs to be compiled, and it can begin now without requiring any physical changes to label or packaging. An overview of this approach in order can be found on the page on the step-by-step approach to the product passport. Only in a later phase, once the delegated act exists and the requirements for the data carrier are established, does it become relevant to determine whether a QR code fits on an existing label, an additional label is needed, or packaging needs to be adapted — that is also the moment when suppliers of labels and packaging actually need to produce something different. For those who want to see now what can already be tackled without that certainty, that information can be found on the page about what you can already do now while the rules are not yet final.

The basis: articles 18, 11, 38, 16 and 17 of the ESPR

The fact that requirements are established and prioritised per product group follows from article 18 of the ESPR (prioritisation and planning), in which clothing is designated as an early category within the work plan. The technical design of the passport itself — and thus also the data carrier that would need to end up on a label or packaging — follows from article 11 of the ESPR (technical design and operation of the digital product passport). Article 38 of the ESPR governs the requirements for actors in the supply chain, which becomes relevant once the obligation actually comes into force and it must be clear which actor supplies which data. Apart from that, article 16 (labels) and article 17 (counterfeit labels) of the ESPR already apply in general terms to how labels may relate to the sustainability image of a product, but those articles do not in themselves create an obligation to add a QR code now.

What to do with this information

In concrete terms, this means that there is currently no reason to have labels or packaging reprinted because of the product passport, but it is wise to get your own product data in order so that a later adjustment does not cause delay. Anyone wanting to know what that means in costs once it does come to that will find an indication on the page about the costs of a product passport.

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 question of whether labels and packaging need adjustment now falls into two parts: what the regulations prescribe about labelling, and what is practically wise to do now. That distinction is important, because the delegated act for clothing does not yet exist.

The QR data carrier must be placed on the product in a specific way

Article 11 of the ESPR (Regulation (EU) 2024/1781) governs the technical design and operation of the digital product passport, including the way in which the data carrier — in practice a QR code — is linked to the product. For a company with 10 to 100 employees, this means that at some point a physical or digital carrier on the garment, the label or the packaging must refer to the passport. How and where exactly that must happen will only be concretely specified in the product-specific delegated act. Until then, there is no requirement that specifies exactly how a label for clothing must look.

Labels must not mislead about sustainability properties

Article 16 of the ESPR concerns labels in general terms, and article 17 prohibits counterfeit labels that give the impression that a product meets certain requirements when it does not. This concerns not only the future product passport, but all claims that already appear on labels or packaging now. For a clothing brand, this means that labels that already contain sustainability claims, or that refer to a certification, must be based on something somewhere. That is a different point of attention than the product passport itself, but it runs through it nonetheless: anyone adjusting labels now does well to also take these provisions into account.

The order of implementation is not up to the individual company

Article 18 of the ESPR describes how the European Commission prioritises which product groups are addressed first, and on what basis that happens. For clothing and textiles, that process is underway, but the date of the delegated act is not yet fixed. For a company, this means there is no individual choice about when the obligation comes into force — that order and that moment are determined centrally. What a company can determine for itself is the moment at which it prepares.

Obligations differ per role in the chain

Article 38 of the ESPR distinguishes between actors in the supply chain: manufacturer, importer, distributor. For a label or private label brand that has clothing produced, this means that the question "who must adapt the label" does not have the same answer for every business. An importer who places clothing under its own brand on the market has a different position than a manufacturer who produces for multiple brands. Anyone who wants to know more about this in relation to their own product category should read on at Does the digital product passport apply to my clothing and textiles?

Where things go wrong in practice

A common situation is that a business is already having large quantities of labels or hangtags printed with a QR code that points to its own website, assuming that this is already "the" product passport. Without the technical requirements from Article 11 being established, it cannot be said whether that carrier will meet the requirements later.

Another situation: a brand is already adding sustainability claims to the label ("circular", "sustainably produced") to get ahead of the expected rules, without these claims being substantiated. This directly touches on Article 17 on counterfeited labels, aside from the product passport.

A third situation arises for businesses that have large batches of clothing with a fixed label produced in a country outside the EU, with a long lead time between order and delivery. If production is now fixed with a label that is not adaptable, this could become a problem later if the data carrier still has to be added or modified.

A fourth situation: confusion between the care label (with fibre composition, which is already mandatory under other legislation) and the future product passport label. Some businesses think that the existing label already meets the requirement, while it is a different obligation.

A fifth situation is when a business does nothing at all and only takes action once the delegated act has been published, while adapting packaging design, printed materials and supplier agreements in practice takes more time than expected.

What you can record

An overview of which labels and packaging are currently in use, per product line, including who designs and prints these.
Agreements with suppliers and printers on the possibility of adding a QR code or data carrier later, so that existing stocks of labels or packaging do not become worthless.
A list of sustainability claims that are already on labels or packaging, together with the substantiation available for these.
An overview of the role your business plays in the supply chain (manufacturer, importer, distributor), as a basis for later determining who carries which obligation.
A record of decisions about label design and packaging, so that it can later be traced why certain choices were made and on the basis of which information.

For businesses that want to know what can already be concretely tackled, apart from this waiting approach, without the risk of wrongly invested printed materials, there is the page What can I do now while the rules are not yet final? For those who prefer a complete overview of the entire process, from first preparation to going live, that can be found at How do I approach the product passport for clothing and textiles step by step?

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.