What does a supervisory authority ask for during an inspection of clothing and textiles?
Documentation first, the product passport only when the obligation comes into force
A competent authority requests, during an inspection, first and foremost to be able to establish who placed the product on the market and whether that party can demonstrate that it has complied with the applicable rules. Under the general market surveillance regulation (Regulation (EU) 2019/1020), this concerns matters such as the identity and contact details of the manufacturer or importer, technical documentation on the product, and any statements accompanying the product. Once the ecodesign requirements from the ESPR (Regulation (EU) 2024/1781) for clothing and textiles come into force, access to the digital product passport is added: the competent authority can then request to scan the QR code or consult the passport in another way, and to check whether the data in it are correct. At this moment, that specific request for clothing does not yet exist, because the obligation itself has not yet come into force.
For whom this applies, and where the boundary lies
These two regulations target different parties and different moments. Regulation 2019/1020 is the general market surveillance regulation: it gives competent authorities powers to request economic operators — manufacturers, importers, authorised representatives, distributors — to provide documentation and cooperation, for products that fall under Union harmonisation legislation. Article 27 of the ESPR is more specific: that article describes the obligations of manufacturers for products for which ecodesign requirements apply, including the requirements for the digital product passport. For clothing and textiles, those ecodesign requirements do not yet exist. This means that a competent authority can now ask for general product documentation insofar as it is applicable, but not yet for a product passport for clothing — simply because that obligation does not yet exist. For other product groups for which ecodesign requirements already apply, the situation is different; this text specifically concerns clothing and textile products.
When this changes, and what applies until then
There is no fixed date yet for when the passport obligation for clothing comes into force. According to the ESPR's work plan for the period 2025-2030, the delegated act for textiles is expected in 2027, and clothing with eighty per cent or more textile fibres is to be covered first. This is an expectation based on the work plan, not an established date — the delegated act must still be adopted and published before a concrete entry-into-force date is known. Until then, the general market surveillance regulation remains the framework within which a competent authority can request documentation. Once the delegated act for textiles has been published, the date will be stated here.
How to approach this in practice
The order in which this usually becomes relevant looks roughly like this. First, it is important to know who in the supply chain qualifies as a manufacturer or importer, since that party is the one to whom a competent authority will initially turn. Next, it is important that the data currently being collected — origin, composition, technical substantiation — are recorded in a traceable and coherent manner, even though this does not yet have to be in a digital passport. Whoever places clothing or textiles on the market and already organises data on materials, origin and production does not have to collect it again once the passport obligation does apply — the work will already be largely done. Furthermore, it is practical to keep an eye on the publication of the delegated act for textiles, since it will establish both the entry-into-force date and the precise content of the passport obligation. Finally, it is advisable to distinguish between what a competent authority can already request on the basis of the general market surveillance rules, and what is added after the introduction of ecodesign requirements — this prevents prematurely preparing for requirements that do not yet apply, or waiting too long before beginning preparations.
What this is based on
The powers of a competent authority to request documentation and cooperation from manufacturers, importers and other economic operators are derived from Regulation (EU) 2019/1020, the general product safety regulation on market surveillance. The specific obligations of manufacturers regarding ecodesign requirements, including making the digital product passport available, are laid down in Article 27 of Regulation (EU) 2024/1781 (ESPR). Which product categories and which entry date for textiles will apply is determined in a delegated act yet to be published; the ESPR work plan 2025-2030 mentions an expectation for this, not a fixed date.
Businesses that are already placing clothing or textiles on the market can do most by getting their own documentation on origin, composition and production in order and recording it in a structured way — this is work that is useful anyway under current market surveillance rules, and that makes the transition to a mandatory digital product passport much easier once that obligation takes effect.
What this is based on
- Regulation (EU) 2019/1020 (market surveillance and product compliance)
- Regulation (EU) 2024/1781 (ESPR), Article 27 (obligations of manufacturers)
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 market surveillance authority visiting a clothing brand or importer will first and foremost check whether the business can demonstrate what it claims. Regulation (EU) 2019/1020 gives surveillance authorities the power to request documentation and to check whether a product complies with applicable requirements. Once the digital product passport becomes applicable, there is an additional obligation that the data in that passport is accurate and accessible. Article 27 of the ESPR (Regulation (EU) 2024/1781) describes what manufacturers are expected to do in this regard.
Verifiable product identification
A surveillance authority will typically start by asking the basics: what exactly is this product, who made or imported it, and how can that be traced. For a business with 10 to 100 employees, this means that product codes, batch numbers and manufacturer or importer details must be consistent between the label, the records and — once applicable — the product passport. If these three do not align, doubt arises about the accuracy of the rest of the information, even before the composition or origin is examined in detail.
Availability of technical and material information
The second expectation is that the underlying data on which the passport is based must be retrievable: fibre composition, origin, substances used, and the substantiation for these from the manufacturer or supplier. This is not something a business can reconstruct afterwards within a few days if the data from the supply chain has not been documented. For businesses working with multiple suppliers, it is practically wise to check what should I pay attention to when choosing a supplier for the product passport, precisely because the quality of this underlying data depends on what the supplier provides and how it is recorded.
Functioning access to the data carrier
A third expectation concerns the QR code or other data carrier on the product: does it work, and does it actually lead to the correct, up-to-date data. A surveillance authority can test this on the spot. For a business, this means that besides content there must also be a technically functioning link, for ten years, even if the product changes hands after sale. Whoever has this built or hosted themselves must take into account that a non-functioning link or an unmaintained page raises as many questions as a completely missing passport.
Correct language and accessibility of data
A fourth point that surveillance can focus on is whether the data is presented in a language and format that the end user or surveillance authority in the country of sale can understand. This is more significant for businesses selling in multiple EU countries. The question of whether the business itself is responsible for translating this data, or whether this is handled elsewhere in the chain, is something many brands struggle with; see on this must I arrange for translation of my product passport data myself.
Responsiveness to enquiries
Finally, a surveillance authority expects a business to be able to respond to questions within a reasonable timeframe, without first requiring an internal investigation into who provided the data in the first place. This requires an internal responsible person or process, even in smaller organisations where this is often done "on the side" alongside other tasks.
Where things go wrong in practice
In practice, problems rarely arise from a single major error, but from an accumulation of small inaccuracies. A few situations that often recur:
A product is sold through multiple channels — own webshop, marketplace, physical store — and the data on the label differs slightly from what is in the underlying system, for example due to an old print run that is still being sold alongside a new one.
The QR code on the garment points to a page that has been moved or is no longer maintained, because the party managing the website is no longer active or the hosting has been changed without the code being updated.
Data on fibre composition have been taken over from the supplier without further verification, and prove in testing to differ slightly from what was stated — with unclear who in the chain made the error.
Stock that has been on the shelf for longer has not been provided with the same information as newer batches, creating two different information levels side by side within a single store or webshop. This is particularly an issue for companies that have not yet looked into what do I do with clothing and textile stock already on hand when the rules come into effect.
Returned products or second-hand items are put back on sale without further checking, whilst no verification has been made as to whether the original data are still correct or can still be linked to the product — a question that arises in does the product passport also apply to second-hand clothing and returns.
What you can record
To be prepared for an inspection, it is practical to have the following matters in order, irrespective of whether an inspection will ever actually take place:
- An overview per product line of which data have been supplied by which supplier or manufacturer, with date and version.
- Proof of the functioning of the data carrier: a periodic check that QR codes still lead to the correct, up-to-date page.
- A documented agreement with suppliers on who supplies and updates which data, including what happens when composition changes.
- An internal point of contact or process for questions from a supervisory authority, so that it does not have to be worked out anew with each question who was responsible for what.
- Documentation on how existing stock and returned items are handled, particularly when these remain on sale alongside newer batches.
For companies that still need to determine how to practically implement these steps, how do I tackle the product passport for clothing and textile step by step provides an overview of the order in which this is usually addressed, and offers what can I do now whilst the rules are not yet final starting points for those who want to get started on this now, even while the exact date of the obligation has not yet been established.
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.