What data must I request from my supplier of clothing and textiles?

What you must do concretely

A clothing brand or importer that has the digital product passport compiled is dependent on the data supplied by the manufacturer. The ESPR (Regulation (EU) 2024/1781) stipulates in Article 38 that actors in the supply chain are obliged to provide the information necessary to meet the passport requirements. In practice, this means: whoever purchases from a manufacturer must know what data that manufacturer must supply, and when that data is complete and usable.

What is expected of you

Determining what data the passport requires

Article 10 of the ESPR describes what information a digital product passport must contain; the precise content for clothing and textiles follows from the delegated act for this product group. For a company with 10 to 100 employees, this means that before the supplier is asked for anything, there must be a list of what the passport will exactly require: material composition, origin, care instructions and similar data. Without that list, every request to the supplier is a guess.

Enquiring with the manufacturer or importer

The obligation under Article 38 rests with actors in the supply chain, not automatically with the brand selling the end product. In practice, this means that a brand or importer must take the initiative themselves to request data from the manufacturer, and cannot wait for the manufacturer to supply it spontaneously. For an importer purchasing from outside the EU, this is even more pronounced; what the product passport means when importing from outside the European Union describes what role the importer receives in this regard.

Recording origin and manufacturing

Part of the data that the passport requires concerns where and by whom a garment was made. For a company with 10 to 100 employees, this means that procurement and quality control must know which garment comes from which factory and which country, even if production runs through an intermediary. Whether the country of manufacturing must appear in the product passport goes further into this question.

Dealing with multiple manufacturers per product

Many garments are not made at a single factory: weaving, dyeing, sewing and finishing can be located at different parties. For a company working with multiple links in the chain, this means that it must be clear beforehand who supplies which part of the data, so that no one assumes that another party has already done so. Who supplies which data when a garment is manufactured by multiple manufacturers describes how that distribution looks in practice.

Bring evidence and certificates

Certificates such as GOTS or OEKO-TEX can form part of the substantiation for what is stated in the passport. For a company, this means that certificates should not be requested separately from the supplier inquiry, but as part of the same request: which certificate belongs to which batch of fabric or which garment, and how long is that certificate valid. Whether a GOTS or OEKO-TEX certificate can be used as evidence in the product passport goes further into this.

Where things go wrong in practice

A few situations come up repeatedly with companies requesting data from their suppliers for the first time.

The question is too general. An email with "send us all data for the product passport" often yields nothing usable. A manufacturer does not know exactly what is meant and sends back a few random documents, or nothing at all.

Data come at product level, while the passport is needed at batch level — or vice versa. Material composition can differ per production batch, while a brand sometimes assumes one fixed specification per article number. That mismatch often only becomes apparent when the passport is being compiled.

Certificates have expired or do not apply to the correct batch. A GOTS certificate issued a year ago for a different supplier or a different fabric is sometimes sent anyway because it "is in the file". Without verification, that goes unnoticed.

The supplier responds slowly or incompletely, and no follow-up step has been agreed. When a manufacturer simply does not respond or only provides half of the requested data, there is often no documented agreement about what happens next. What to do if the supplier does not provide the data addresses this situation.

No one checks whether the supplied data is correct. Data are taken over as received, without anyone verifying whether the material composition matches what is actually in the garment. How the data from a supplier can be checked for accuracy describes which steps are appropriate.

What you can record

A number of documents and agreements make requesting supplier data less dependent on chance:

• A fixed data list per product group, so that each supplier receives the same questions and nothing is omitted.
• An agreement in the purchase contract on the supply of product passport data, including what happens in the event of incomplete or late delivery; how the supply of product passport data can be documented in a purchase contract describes what such an agreement might look like.
• An overview of which factory manufactures which part of a garment, with associated contact person, for products that are made through multiple channels.
• A register of certificates per supplier and per batch, with validity date and the product part to which the certificate applies.
• A documented inspection procedure for incoming data, so that discrepancies between what is supplied and what is actually correct are noted before they end up in the passport.
• An agreement on audits at the supplier, for brands that want to establish whether the supplied data matches the actual production conditions; or whether a supplier abroad must be inspected for the product passport addresses this possibility.

Whoever documents these points in advance prevents the compilation of the passport from being delayed by data that still need to be requested, checked or supplemented at the last moment.