I am a clothing wholesaler, what are my obligations regarding the product passport
As a wholesaler, you are usually a distributor
A clothing wholesaler falls under the ESPR usually in the category of "distributor": a link in the chain that resells clothing to other businesses (shops, retailers, other wholesalers) without having had the clothing produced itself and without placing its own brand on it. This role involves no obligations to compile a product passport yourself. The obligations that do apply centre on checking and passing on: verifying that the passport is present, and keeping it intact during transport and storage under your own management.
What this applies to and what it does not
This role applies to a wholesaler that purchases clothing from a manufacturer or importer and resells it without becoming the owner of the brand or design. It does not apply to a wholesaler that also acts as an importer — that is, that brings clothing directly into the EU from outside and places it on the EU market for the first time. In that case, the stricter obligations of an importer apply, not those of a distributor. Nor does it apply to a wholesaler that has clothing made under its own brand or label: whoever determines how the product looks and under what name it is sold is considered a manufacturer for those products, with the associated obligations. Uncertainty about which of these roles exactly applies is common among businesses that both purchase and carry part of the collection under their own name — whether someone is a manufacturer or importer is then the starting point, not the role of distributor.
No fixed date yet, but a clear work plan
There is no fixed date yet when the product passport for clothing becomes mandatory. The ESPR itself is the framework regulation; the actual obligation for clothing and textiles comes only with a separate delegated act. According to the European Commission's work plan for 2025-2030, that act is expected in 2027, with clothing that consists of eighty percent or more of textile fibres as the first category. Until that act is published, the obligations under Articles 30 and 31 of the ESPR do not yet apply in practice — they are already established in law, however, as a framework that only becomes active once the product group is designated. Once a confirmed date is available, it will be mentioned here.
What a wholesaler can do right now
For now, there is no need to create or have a passport created yourself — that obligation rests with the manufacturer or importer further down the chain. What is useful to know, for when the obligation takes effect: a distributor must then be able to verify when offering clothing on the market that a product passport is present, that the QR code or other data carrier works, and that the required information is available in the language required in the Member State of sale. It is therefore a checking role, not a compiling one. If there is any doubt about the precise content of that checking obligation, the page on the obligations of distributors and traders is a logical next step. For a wholesaler that purchases from a supplier outside the EU, it is furthermore useful to know who in that chain is designated as an importer, as that party bears the obligation to have the passport drawn up — this is set out on the page on a manufacturer outside the European Union. Anyone who is uncertain whether their own business operations still fall within the role of distributor, for example because they also sell under their own name, would do well to clarify that distinction before the obligation takes effect, not after.
The basis: Articles 30 and 31 of the ESPR
This classification follows from Articles 30 and 31 of Regulation (EU) 2024/1781 (ESPR). Article 30 describes the obligations of distributors, Article 31 those of traders in the broader sense; together they determine what is expected of a party that resells products without manufacturing or importing them itself. The regulation makes a distinction between manufacturer, importer, distributor and authorised representative, and the obligations differ per role. Which of those roles applies to a specific company depends on what that company actually does in the supply chain, not on the name the company gives itself. For a broader overview of who fulfils which role throughout the entire chain, from manufacturer to point of sale, is the overview of responsibility for the product passport a good starting point.
A wholesaler wishing to know how their own position relates to suppliers and customers should first establish whether their own role is strictly that of distributor or whether it also touches on importer or manufacturer — after that the obligations in this article will fall into place.
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
A wholesaler purchases clothing or textiles, usually in large volumes, and resells them to shops, other traders or sometimes directly to major customers. Under the ESPR (Regulation (EU) 2024/1781) that role typically falls under the concept of "distributor": a party that places products on the EU supply chain without being the manufacturer or importer. That is a different position from that of manufacturer or importer, with different obligations. Anyone uncertain whether their own situation would rather count as importer — for example because goods are purchased directly from outside the EU — reads that elaborated further on Am I an importer or manufacturer according to the ESPR?.
What is expected of you
Checking whether the product passport is present
Article 30 of the ESPR describes that a distributor checks whether a product to which the regulation applies is accompanied by the required digital product passport and by the associated data carrier (such as a QR code) and information, before the product is offered. For a wholesaler with ten to one hundred employees, this in practice means that the purchasing department or quality control checks with each new supplier or collection whether a passport is present, and not only with the first shipment but structurally, also with reorders and seasonal changes.
Do not supply without passport where required
Where the passport is mandatory, a distributor is expected not to place a product without that passport on the market. For a wholesaler this means that a delivery without a valid passport can be a reason not to resell the shipment, even if the commercial pressure to deliver is high. This directly affects purchasing conditions with suppliers: it is advisable to establish in advance that a passport is part of a complete delivery.
Cooperate with market surveillance
Articles 30 and 31 further describe that a distributor and trader cooperate with competent authorities, including by providing information and documentation on request that demonstrates that a product complies with the requirements. For a mid-sized company this means that there must be someone — often the quality manager or compliance officer — who knows where this documentation is located and who can respond if a supervisory authority requests access.
Do not further distribute products that do not comply
When a distributor has reasons to assume that a product does not comply with the requirements, they are expected not to cooperate with this until compliance has been demonstrated. For a wholesaler this can mean that a batch is temporarily withdrawn from sale pending clarification from the manufacturer or importer.
Pass on information in the chain
Article 31 describes obligations for traders that partly overlap with those of distributors, with a focus on passing correct information to subsequent parties in the chain, such as shops or consumers. For a wholesaler that supplies both shops and other traders, this means that the data carrier and the underlying information must remain intact and accessible when reselling, and must not be accidentally lost when repacking or relabelling goods.
Where things go wrong in practice
A wholesaler takes over a batch from a supplier outside the EU who has never created a passport themselves, assuming that "someone else will have arranged that". No one in the chain feels responsible, and the passport is missing when delivered to the shop.
A wholesaler repacks or relabels goods under its own assortment name, causing the original QR code on the packaging to disappear or become illegible, without a replacement data carrier being added.
For a large order with multiple colours and sizes, the passport is only checked on one reference product from the collection, while each variant may require its own passport with its own data.
A wholesaler assumes that because the brand on the garment is from a well-known party, the responsibility for the passport lies there — without it being established who in practice created the passport and whether that actually happened. This is particularly common in private label collections, where the wholesaler sometimes acts as brand owner without realizing it.
When a supervisory authority makes a request, it turns out that no one within the company knows where the manufacturer's underlying documentation is stored, because it was only exchanged by email and not kept centrally.
What you can record
- A fixed procedure in the purchasing process whereby the presence of the product passport is checked before a shipment is accepted, including who carries out this check.
- Agreements with suppliers on delivery of the passport and the data carrier as a fixed part of the commercial agreement, with a clear escalation if this is missing.
- An overview per collection or batch of which variants (colour, size, composition) have their own passport and which do not.
- A central storage location for documentation that proves a product meets the requirements, accessible to the person responsible for contact with supervisory authorities.
- An internal agreement on what happens when repacking, unpacking or relabelling, so that the data carrier is not lost.
- Clarity about your own role in the chain: whoever acts as a distributor thereby holds a different responsibility than a manufacturer or importer, and that distinction is the basis for all other agreements. More about this is on What obligations does a distributor or trader of clothing and textiles have?.
Once you have put these agreements on paper, you will be considerably better positioned during an inspection or in a dispute with a supplier than a company that still has to figure out who was responsible for what at that moment.
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.