When does the product passport become mandatory for clothing and textiles?

What you must do concretely

What is expected of you

The obligation to maintain a digital product passport for clothing and textiles does not yet exist. The ESPR (Regulation (EU) 2024/1781) is the framework regulation that creates the possibility, but the actual obligation for a product group arises only with a delegated act per product group, as described in Article 4 and Article 8 of the ESPR. For clothing and textiles, that act does not yet exist. What is therefore expected of you in the meantime is mainly: knowing what you are facing once that act comes, and not being caught off guard.

Knowing whether your products fall within the first round

Article 18 of the ESPR describes how the European Commission prioritises which product groups receive a delegated act first. For textiles, it has already been indicated that clothing containing eighty percent or more textile fibres will be the first to be addressed. For a company with ten to one hundred employees, this means mainly a matter of categorisation: which part of the assortment consists predominantly of textile fibres, and which part does not. A collection of basic T-shirts and trousers is more likely to fall under this than a line with many plastic, leather or metal components. If anyone is in doubt whether a category counts, they will find more detailed information on which products from the clothing and textile sector fall under the ESPR.

Keeping the distinction between "will apply" and "already applies" clear

A delegated act is not a standalone decision that comes out of nowhere; it is the implementation of powers that the ESPR itself already grants to the Commission. This makes the distinction between what will once apply and what already applies sometimes difficult to see in news reports and summaries. For a company, it is practical to keep this distinction sharp internally, precisely because commercial parties — suppliers, software companies, consultants — sometimes have an interest in suggesting urgency that does not yet exist. More background on how such an act works precisely and why it determines what a company must do is available on what a delegated act is and why it determines what I must do.

Following when the act for textiles is published

Once the delegated act for textiles has been adopted, it will contain the actual date on which the obligation takes effect, and the precise requirements for the passport. Until then, any date in circulation is an expectation based on the work plan, not an established fact. For a company, this means that following Commission publications is something that must be revisited at regular intervals, without a concrete action being attached to it yet. The distinction between the ESPR as a framework regulation and the broader European textile strategy in which this regulation is embedded is explained on the distinction between the ESPR and the European textile strategy.

Where things go wrong in practice

A supplier or software partner mentions a firm deadline that is based on nothing. Because the delegated act for textiles has not yet been published, no official date exists. If someone is presented with a definite year-based promise in a quotation or email ("mandatory from..."), it is wise to ask for the source of that date.

A company thinks that the passport applies only to clothing, not to the rest of the assortment. Brands that sell bags, belts or shoes in addition to clothing sometimes automatically assume that those products remain outside the scope. This is not necessarily the case; the classification of accessories and shoes follows its own route, explained on whether the product passport also applies to accessories and shoes.

Work clothing is forgotten in the planning. An importer that mainly supplies retail brands, but also carries a line of work clothing for business customers, often focuses attention on the retail collection and forgets that work clothing deserves its own assessment. See on this whether a product passport is also required for work clothing and uniforms.

Interior textiles are overlooked. Brands that offer curtains, bedding covers or other household textiles alongside clothing sometimes assume that only wearable clothing counts. That too is an assumption that does not necessarily hold; see whether the product passport also applies to household textiles such as curtains and sheets.

Small business, so automatically exempt. Some smaller importers and private label companies assume that an obligation coming from Brussels is mainly intended for large corporations. Whether the size of a business matters for what is expected is not automatically established and deserves its own assessment, to be found on whether the product passport also applies to small businesses.

What you can record

• An overview of your own assortment, divided by product group (clothing with predominantly textile fibres, accessories, shoes, workwear, interior textiles), so that when the delegated act is published, it is quickly clear which part of the collection comes into focus first.
• A list of suppliers and manufacturers per product group, with contact details, so that the data needed for a passport later does not have to be collected from scratch.
• A brief note on the source of each deadline mentioned internally or by suppliers — reference to the official publication by the Commission rather than to a news item or marketing text.
• A recurring agenda item (for example every quarter) to check whether the delegated act for textiles has been published.
• Documentation of the current composition of products (fibre types, origin, production process), which is already relevant for other regulations and can later be reused when compiling a passport. An initial orientation on what such a passport entails is available on what a digital product passport for clothing and textiles is exactly.