What is a digital product passport for clothing and textiles?
A digital passport with product information, linked to a QR code
A digital product passport is a digital file with data about a product, which can be retrieved by anyone in the supply chain via a data carrier — usually a QR code on the label. For clothing and textiles, this concerns information that is often currently scattered: material composition, origin, repair options, and data on recycling and waste management. Instead of this information being on separate labels, websites or in separate documents, it is brought together in a single digital file that is linked to the specific product or product group. The passport does not replace existing labelling that is mandatory under other rules, but adds a digital layer to it that is searchable and interchangeable for supervisory authorities, recyclers, trading partners and consumers.
For clothing with predominantly textile fibres, not for each garment equally
The obligation under the ESPR is a framework law: it establishes that a digital product passport can be created for product groups, but the details are filled in per product group via a separate delegated act. For textiles and clothing, the starting point is that clothing with a share of eighty per cent or more textile fibres will be addressed first. This means that a swimsuit with a high synthetic or elastane content that falls below that threshold may be addressed in a later phase, or may fall under other rules. The obligation under the ESPR also does not apply to second-hand clothing that was already on the market before the rules enter into force, and does not apply to product categories that have not yet been designated. For those who operate internationally, it is relevant that this concerns products placed on the market in the EU — not production or export activity alone.
The date is not yet fixed: first the delegated act must be in place
There is no fixed entry date yet for the digital product passport for clothing and textiles. What is fixed is the route to it: the European Commission is working according to a work plan for 2025–2030 in which a delegated act for textiles is expected in 2027, with clothing of eighty per cent or more textile fibres as the first category. A delegated act is the supplementary regulation in which it is only then concretely established which data must be in the passport, for which products exactly, and from when. Until that act is published, there is no passport obligation for textiles and clothing. Companies that are already making preparations now — organising data, getting supplier information in order — are doing so in anticipation of rules that still have to be established, not because an obligation is already in force. As soon as the delegated act is published, the date will be updated here.
Start with the data, not with the technology
For a clothing brand or importer, the first step is not to choose a QR code supplier, but to map out what data about a product already exists and where it comes from: fibre composition from the manufacturer, country of production, any certifications. Much of that information is already documented somewhere, often with the supplier or importer, but not in a form suitable for a digital passport. The second step is to determine which link in the supply chain can best provide and maintain that data — this is usually the one that places the product on the EU market first, i.e. the manufacturer or importer. The third step, which only becomes relevant once the rules for textiles are concrete, is to actually compile and host the passport and affix the data carrier to the product. Those who follow this sequence will not have to start from scratch when the obligation enters into force, but will already have the source data in place.
Where this follows from: article 9 and article 10 of the ESPR
The basis for the digital product passport is laid down in Article 9 of Regulation (EU) 2024/1781 (ESPR), which establishes that a digital product passport may be made mandatory for designated product categories. Article 10 of the same regulation describes the requirements that such a passport must meet, such as the link to a data carrier and the accessibility of the data. Both articles are generic: they apply to product categories in general and only become concrete for textiles once the announced delegated act for that sector has been adopted and published.
If you want to start now, it is best to begin by organizing your own product data — material composition, origin, supplier information — so that it can be used immediately when the textile rules become concrete. For current information and the exact legal text, the official EUR-Lex page of the ESPR is the appropriate source.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
- Regulation (EU) 2024/1781 (ESPR), Article 10 (requirements for the digital product passport)
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
A digital product passport is, in short, a digital file attached to a product and containing information on, among other things, material composition, origin, repair options and recyclability. Article 9 of the ESPR (Regulation (EU) 2024/1781) describes that the passport must be accessible via a data carrier, usually a QR code, and that the data remain available for the duration of the product's life. Article 10 of the ESPR sets out which technical and substantive requirements apply to that passport, such as the way data are stored, who may modify them and how the carrier is affixed to the product or packaging.
For a company with 10 to 100 employees, this breaks down into a number of practical obligations.
Gather and structure data
The passport is nothing more than the sum of data that already exist somewhere in the chain: fibre composition, country of production, chemicals used, certifications. What changes is that this data must be structured and machine-readable in one place. For a brand that currently works with spreadsheets and loose certificates, this means an inventory: what data exist, where are they, and what is still missing. Companies working with multiple suppliers find that this obligation is primarily a coordination matter: the manufacturer or importer compiles the passport, but depends on what suppliers provide.
Affix the data carrier
Article 9 of the ESPR describes that the passport must be accessible via a physical carrier on the product. For a clothing brand, this means an adjustment to the production process: a label, hang tag or woven code must be added when the garment is made or packaged. This is an operational change that requires time to arrange with the production partner, especially when that partner is located outside the EU.
Keep data current and available
A passport is not a snapshot. Article 10 of the ESPR sets out requirements for the storage and accessibility of data, meaning that the party responsible for the passport must have a system with which data can be updated or corrected. For smaller brands, this is often the reason to outsource this part to a platform, because building and maintaining such a system in-house requires an investment that is out of proportion to the size of the collection.
Determine whether and when it applies
Not every garment or textile product is subject to this obligation in the same way or at the same time. Which products in the clothing and textile industry fall under the ESPR? describes the demarcation, and Does the digital product passport apply to my clothing and textiles? helps translate this into a concrete assortment. For many companies, this is the first step, because investing in data collection without that demarcation being clear costs time and money that may not have been necessary afterwards.
Where things go wrong in practice
A number of situations come up repeatedly in practice.
First: companies assume that the passport is a one-time action, while Article 10 of the ESPR actually sets requirements for keeping data current. When a collection changes or a supplier changes, the passport must move with it — this is often forgotten until it is too late.
Second: the data carrier is only taken into account late in the production process, which means labels or hang tags still have to be adjusted at the last minute. This causes delays in delivery to retailers or webshops.
Third: companies do collect data, but not in a form that is machine-readable or transferable. A pdf with specifications is not a digital product passport as described in Article 9 of the ESPR; the structure and accessibility of the data are part of the requirement.
Fourth: no distinction is made between different product categories within your own assortment. A brand that combines clothing, accessories and interior textiles runs the risk of applying the same approach everywhere, whereas the product passport also applies to shoes, bags and belts and the product passport also applies to household textiles such as curtains and bed linens show that the demarcation can differ per category.
Fifth: companies wait to prepare until the exact obligation date is known, while the underlying delegated act has not yet been published. When does the product passport become mandatory for clothing and textiles? and What is a delegated act and why does it determine what I must do? describe why that date is not yet set and what is already known.
What you can record
- An overview of which product categories in your own assortment fall under the ESPR (Regulation (EU) 2024/1781), including any borderline cases such as workwear or samples.
- An inventory per supplier of which data (fibre composition, origin, chemicals, certificates) are already available and which are still missing.
- Agreements with production partners about the moment at which a data carrier (label, hang tag, woven code) is added in the production process.
- A person responsible within the organisation for keeping passport data up to date, including a process for changes with new collections or supplier changes.
- Documentation of the demarcation between product categories, for example for workwear or accessories, so that it is clear which approach applies where.
Companies that are unsure whether this obligation affects them as a small business will find initial guidance in Does the product passport also apply to small businesses?
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.