What can I do now while the rules are not yet final?

Start collecting data now

While the delegated act for textiles has not yet been published, the most meaningful step right now is to put in order the basic data about a product: fibre composition, country of production, materials used, and where possible data on origin and processing further down the chain. This data will form the core of each digital product passport, regardless of the precise content of the final rules. Anyone who documents this information in a structured manner now will not have to wait until the obligation exists to begin — and will be better positioned when the act is published than those who only start then.

For whom this is already relevant

This is especially relevant for brands, importers and private label operators who place clothing and textile products on the European market, and who will be affected by the announced prioritisation of textiles within the ESPR work plan. It does not apply to companies that sell exclusively outside the EU, and it is not an announcement of an obligation that is already fixed — the delegated act does not yet exist. What is certain is that clothing with a high share of textile fibres will be addressed first within the textile work plan. For accessories, footwear or mixed products with a lower fibre content, it is not yet clear whether and when they will fall under the same rules; preparation on the main points (material data, origin) is useful, but a statement on the precise scope cannot be made at this time.

The date is not yet fixed

There is no final date yet for when the digital product passport for textiles becomes mandatory. What is certain: within the ESPR work plan, a delegated act for this product group is expected, with clothing containing eighty per cent or more textile fibres being addressed first. Once that act is published, the actual entry date and the precise product description will follow. Until then, there are no obligations for textiles from the digital product passport itself — the obligation only arises with the delegated act, as the ESPR provides in Article 18 for the prioritisation and planning per product group. This page will be updated as soon as a published date is available; until then, any date mentioned is an expectation, not an established fact.

How to prepare

The practical sequence starts with mapping what is already available. First: check which data about a product is already in place with the manufacturer, supplier or importer — such as fibre composition, country of origin and chemical treatments used. Often this information is already scattered across procurement files, certificates or supplier declarations, but not centrally and not in a form that a passport can use directly.

Next: check which links in the chain can provide this data. The ESPR sets out requirements in Article 38 for actors in the supply chain, meaning that the responsibility for providing correct data does not rest solely with the brand or importer, but is distributed across the chain. It is therefore useful to already inventory which suppliers can provide which data, and where gaps still exist — for example with sub-suppliers further down the chain who are not yet accustomed to providing data in a structured manner.

Then: set up a central location where this data comes together per product, even if there is no mandatory passport yet. A simple internal overview per product line — fibre composition, origin, supplier, any certifications — will save work later, regardless of the exact form the final passport takes.

Finally: stay informed about the publication of the delegated act for textiles, so that the transition from internal data collection to an actual passport can be made quickly once the obligation and date are known.

Where this is set out: Article 18 and 38 ESPR

That textiles as a product category are prioritized within the work plan, and that the actual implementation per product category proceeds via a delegated act, follows from Article 18 of the ESPR (Regulation (EU) 2024/1781), which governs the prioritization and planning of product categories. That responsibility for product data does not lie with one party but is distributed across the supply chain, follows from Article 38 of the same regulation, which sets requirements for actors in that chain. Together, these articles provide the basis for what can already be foreseen now: which product category is up next, and who will then have to be able to supply which data — without this already establishing a date or a concrete obligation for textiles.

If you want to start now, it is wise first to map your own product data and supplier chain, and only then to look at a system or platform for the actual digital product passport — the latter can only be completed once the delegated act is in 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

What is expected of you

The delegated act for clothing and textiles does not yet exist. This does not mean there is nothing to do. The ESPR itself (Regulation (EU) 2024/1781) is already in place, and Article 18 describes how the European Commission prioritises product groups and develops the requirements for them. For clothing with eighty percent or more textile fibres, that development is to be done first. Those who wait to prepare for this will start with a blank page in a few years' time. Those who bring order to their own product data now will be better positioned then.

Knowing which products will fall under the regulation

For a company with 10 to 100 employees, this means in particular: drawing up an overview of the assortment by material composition. Products that consist predominantly of textile fibres come into view first. An assortment with many mixed products, accessories or products with a low textile percentage requires more investigation to determine what will and will not fall under the regulation in future. That overview does not need to be complete or final, but it does provide a starting point. On Does the digital product passport apply to my clothing and textiles? is how that delimitation is assessed in practice.

Bringing data about the supply chain into order

Article 38 of the ESPR describes the role of actors in the supply chain in making available the information needed for the product passport. A manufacturer, importer or brand that relies on suppliers for material data, origin and composition, would be well advised to already inventory which suppliers can provide which data, and which cannot. In a company of this size, that information is often scattered within: in procurement, in quality, sometimes only at the supplier itself. Mapping that fragmentation is work that can be done now, regardless of the exact requirements that are still to come.

Getting to know a supplier or service provider before it becomes necessary

Compiling, hosting and disclosing a product passport is specialist work. Time is needed to understand what a supplier does and does not do in this regard, and what data a company must provide itself. That investigation time is available now, and it will not be available later once the obligation comes into effect. On what should I pay attention to when choosing a supplier for the product passport is where that assessment process revolves around.

Gaining insight into the costs involved

A product passport entails costs for collecting data, compiling the passport and managing it over the years it must remain available. Having an indication of that cost item now helps in making budget choices, even if the exact requirements have not yet been determined. See What does a product passport for clothing and textiles cost? for the factors involved in this.

Where things go wrong in practice

A first situation that often recurs: a company waits until the delegated act is published before doing anything, and only then begins collecting material data from suppliers. That collection takes time, especially when suppliers are in other countries and are not used to this kind of request.

A second situation: data on material composition does exist somewhere, but not in a place where someone can quickly find it. It is scattered across procurement files, old emails and loose spreadsheets with different employees.

A third situation: a company assumes that the supplier "will handle that", without this ever having been discussed. Article 38 describes the role of actors in the chain, but who supplies which data within a specific business relationship is something the parties themselves must lay down.

A fourth situation: a brand focuses only on new collections and forgets that there is also inventory that still needs to be sold when the rules come into force. What happens with that is a question that deserves separate attention; see What do I do with clothing and textile stock already in place when the rules take effect?.

A fifth situation: a company quickly adapts labels and packaging, assuming that this must be done now, while the exact form of the data carrier has not yet been determined. See must I already adapt my clothing labels and packaging for the product passport for what is and is not wise to do already.

What you can record

An overview per product line of the material composition, with a separate column for products that consist of eighty percent or more textile fibres.
A list of suppliers with details on which data they can already provide on material, origin and composition, and which they cannot.
Internal agreements on who within the company is responsible for collecting and keeping product data up to date.
An initial inventory of the costs expected for compiling and hosting a passport, as a basis for future budgeting.
A file with the steps already taken towards a chosen supplier or service provider, including the questions put to them.
An overview of the current inventory position per product group, so that when the delegated act is published it is quickly clear which inventory still falls under old rules and which under new rules.

Anyone building up this type of file now does not have to start from scratch later. The complete approach, step by step, is described on 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 2026-08-22. Is something wrong? Let us know — corrections are given priority.