How do I record the fibre composition in the product passport?

The fibre composition comes from your own product data, not from a new test

You record the fibre composition in the product passport by taking over the percentages per fibre type from data that already exists: the technical specification of the article, the composition certificate from your supplier, or the test report of the fabric or knit. This is not a new obligation to have something tested that is not yet known — most brands and importers already have this data, because the fibre composition is already on the clothing label now. The difference with the passport is that this data will then need to be digital, structured and linked to a unique product identification, so that it can be consulted for the entire lifetime of the article. Texpas.eu compiles the passport based on the data supplied by the manufacturer or importer; we do not invent a composition and we do not measure anything — we structure and host what has been supplied, and provide the QR data carrier through which the passport is unlocked.

For clothing and textile products, not for every article at the same time

This topic concerns clothing and textile products within the digital product passport of the ESPR. Within that group, the expectation is that clothing with eighty percent or more textile fibres will be the first to fall under a delegated act — other textile products and blends with a lower fibre content will follow at a later date or under different rules. This is separate from the question of which fibres exactly must be reported and at what level of detail (for example by fibre type, by percentage bandwidth, with or without origin); these choices will be established per product group in the delegated act and are not yet published. This also does not concern the existing obligation to state the fibre composition on the physical clothing label — that is separate from the digital passport and does not change because of it in itself.

No fixed date yet: the work plan mentions 2027 as a target

There is no date yet on which the fibre composition must be mandatory in the digital product passport. The ESPR work plan 2025-2030 mentions 2027 as the expected date for the delegated act for textiles, with clothing from eighty percent textile fibres as the first category, but this is a schedule and not an established obligation. As long as that delegated act has not been published, there is no concrete obligation to include the fibre composition in a digital passport — article 10 of the ESPR does describe the general framework to which a passport will have to comply in future, but that framework only becomes concrete for textiles once the product-specific rules are in place. Until then, there is room to get your own data in order, without a deadline already in place.

How to prepare your data now

Anyone who wants to get started with this begins by collecting the fibre composition per article or per production line, rather than per collection in a general sense — the passport is linked to a unique product, so generic "approximately" percentages will not suffice later. Next, it is useful to check whether those percentages are current per model, colour and batch, since compositions can differ between batches even if the article has the same name. After that, it is advisable to record who determined the composition and on the basis of what — a test report, a supplier declaration — so that there is a trace if the method by which it was determined comes into question. Once the delegated act for textiles is known, that trace is the starting point to determine whether the existing evidence meets the requirements that will then apply, or whether additional information is needed. Texpas.eu processes this data at the moment it is supplied; the more complete and up-to-date your own records per article, the less work it will cost later.

Substantiation: article 10 and article 39 of the ESPR

Article 10 of the ESPR (Regulation (EU) 2024/1781) stipulates that the information in a digital product passport must be accurate, up-to-date and complete, and that this information is linked to a unique product identification with which the passport remains accessible throughout its duration. This article describes the general framework for what a passport must be able to do — it does not itself determine which data are mandatory for textiles, that follows from the delegated act still to be published for that product category. Article 39 of the same regulation concerns the test, measurement and calculation methods by which data are established in the context of the ESPR: these must be reliable, accurate and reproducible, and the Commission may lay down which method applies for each product category. For fibre composition, this means that not only the final result (the percentages) becomes relevant, but also the manner in which they were established — once that has been worked out for textiles.

If you want to be prepared now, map out the fibre composition per article and batch, keep the underlying test reports or supplier declarations, and keep track of the publication of the delegated act for textiles. Once that act is in place and the date is confirmed, this page is where that will be added.

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

Record the fibre composition correctly and completely

The digital product passport contains product information that results from product-specific requirements, and for clothing and textiles, the fibre composition is expected to be part of this. Article 10 of the ESPR (Regulation (EU) 2024/1781) describes that the passport must contain the information established for the relevant product category. For a company with 10 to 100 employees, this means in practice that the composition already listed on the care label must also be available digitally and in structured form — not as free text, but as data that can be read by systems that display the passport. Which fields and layout are involved depends on the implementing rules that still need to be published; an overview of the data categories currently expected is available in which information goes into the product passport for clothing and textiles.

Substantiate the composition with a measurement method

Stating a fibre percentage is one step; being able to demonstrate how that percentage was determined is another. Article 39 of the ESPR describes that values in the passport must be based on established test, measurement or calculation methods. For a company working with suppliers in multiple countries, this means that a supplier certificate or own test report must be present in the background, even if only the final percentage appears in the passport. Which method is expected for which type of claim — laboratory testing, calculation based on purchasing data, or something else — is a subject being worked out further on according to which method must I measure the values for the passport.

Make a distinction between virgin and recycled fibre

Where a product is partly made from recycled material, there is an extra layer beneath the simple mention of "polyester" or "cotton". A company that purchases recycled polyester also faces the question of how that share was determined and on the basis of which evidence. That distinction affects both the composition itself and its substantiation, and is detailed in how do I demonstrate the share of recycled fibre.

Keep the data up to date when composition changes

Fibre composition sometimes changes between production runs — a supplier modifies a yarn mix, or a collection receives a new version with a different share of recycled material. For companies working with small batches and frequent reorders, this is one of the places where the passport is not "fill in once and done". How often an update is needed and what counts as a change in this context is described on how often must I update the data in the product passport.

Where things go wrong in practice

A common situation is that the percentage on the care label and the percentage the supplier documents internally do not match exactly — for example due to rounding or a mixed batch that is sold under a single article number. As long as this only appears on the label, it rarely comes to attention; in a digital passport linked to an article number, such a discrepancy becomes more visible.

A second situation: a brand adopts the composition that the factory provides, without a test report or certificate behind it. This works until a question arises about the substantiation — then there is nothing to refer to.

A third situation arises with blended products with small admixtures, such as a cotton main fabric with a small percentage of elastane. This admixture is sometimes omitted from the passport in practice because it is "not important anyway", whereas the composition in the passport should actually be complete.

A fourth situation arises with recycled material: a supplier claims a percentage of recycled polyester, but the evidence for it (for example, a chain-of-custody certificate) covers a different batch or period than the batch that was actually purchased. That difference often only comes to light when someone places the certificate next to the purchase order.

A fifth, and subtle, situation: the composition is correctly recorded at the time of import, but not updated when a supplier later adjusts the yarn mix for a subsequent production run under the same article number. The passport then continues to show the old composition.

What you can record

The supplier certificate or test report on which the stated percentage per fibre type is based, per article number or per production batch.
An internal overview (template available) in which per collection it is recorded which composition belongs to which production run, so that changes do not go unnoticed.
Correspondence with the supplier about the measurement method used, so that in a later query it is clear whether it is a laboratory test, a calculation or a declaration from the yarn supplier.
For recycled material: the chain-of-custody certificate or an equivalent proof document, linked to the specific batch that was purchased, not only to the supplier in general.
A fixed moment in the procurement process at which it is checked whether the composition on the care label matches the composition shown in the passport, to prevent discrepancies between label and digital data — this also touches on the question of how the care label relates to the passport, as described on how does the care label relate to the digital product passport.
A person responsible within the company (procurement, quality, or sustainability) who is designated as the owner of the fibre composition data, so that changes by a supplier always reach one person rather than being lost between departments.

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.