What data goes into the product passport for clothing and textiles?

What you must do concretely

The ESPR (Regulation (EU) 2024/1781) stipulates in Article 10 what a digital product passport must be able to contain, and in Articles 5 to 7 which categories of information are to be made mandatory via a delegated act for each product group. For clothing and textiles, that delegated act does not yet exist, but the structure of the regulation does show which types of data come into play: product identification, material composition, origin, chemical properties, and data on repair and processing at the end of life. Below is an overview of what a company can practically expect from this.

What is expected of you

Record product identification

Every passport begins with a unique identification of the product: a product code or model number, linked to the manufacturer or importer responsible for the data. For a company with 10 to 100 employees, this means primarily an administrative exercise: existing article numbers and production codes must be unambiguously linked to one digital passport per model or batch, without duplications or confusion between seasonal collections.

Include fiber composition and material data

The composition of the textile is core data: which fibers, in what proportion, and whether recycled material is incorporated into it. This aligns with information already on the current label, but the passport requires a structured, digitally readable recording instead of a text line on a small tag. Companies working with multiple suppliers do well to determine now how they record fiber composition and, where applicable, how they demonstrate the proportion of recycled fiber. The latter usually requires evidence that goes beyond a supplier declaration alone.

Report chemical treatments and microfiber release

The information requirements from Article 7 of the ESPR are also directed at substances used during production or finishing, such as dyes, coatings or impregnating agents. For a company, this means that communication with production sites about which chemical treatments must be reported must take place early in the supply chain, not only when compiling the passport. In addition, the broader discussion around textiles also looks at microfiber release during washing; whether and how this becomes a fixed part of the passport is not yet crystallized, but it is data whose source (test report, lab value) can be documented now. See whether microfiber release from textiles must be recorded.

Describe maintenance, repair and end of life

Article 5 of the ESPR mentions durability, reusability, repairability and recyclability as possible performance requirements. For clothing, this can translate into data on maintenance and repair options. A company that already keeps care labels and maintenance instructions can reuse that information, although the relationship between the care label and the passport is a matter that requires further clarification. The question also arises whether it must be indicated whether clothing can be repaired as part of this list: practically, this means that product information that currently lies with an after-sales or customer service department may in future become a structured part of the passport itself.

Account for a possible sustainability score

There is discussion of a score or similar indicator that summarizes a product's sustainability performance. What this concretely means for clothing and whether it becomes a mandatory part of the passport is described in the question of whether clothing receives a sustainability score in the digital product passport. For a company, the key now is mainly to have the underlying source data (material, origin, test results) in order, so that a score — if it comes — can be derived from it without the entire product administration having to be reorganized.

Where things go wrong in practice

A first recurring situation is that fiber composition appears on the garment label, but is not recorded as a separate, structured dataset in the product management system — meaning that when compiling a digital product passport, it must be manually retyped from thousands of articles.

A second situation arises when suppliers in different countries use different units or test methods for the same property, without clarity on which method was applied. This makes data incomparable between collections or seasons.

A third problem is the absence of a single owner for product data within the company: procurement, quality control and marketing each maintain their own version of "the" product information, with mutual discrepancies that go unnoticed until a digital product passport must be compiled.

A fourth situation is that companies receive chemical information from their production facility in a form that cannot be traced back to a specific article or batch, meaning that information cannot be linked one-to-one when filling in the digital product passport.

A fifth, common situation is uncertainty about who will be permitted to access which data: companies suspect that commercially sensitive information will become public, while who may access which data from the digital product passport contains nuances, and whether commercially sensitive data on clothing and textiles must be made publicly available is a separate question that is not automatically answered with "yes".

What you can record

• An overview per article number of fiber composition, raw materials used and any recycled content, with source attribution (supplier declaration, certificate, test report).
• Documentation of the measurement method used for technical values, so that it can subsequently be traced which standard was used to determine a figure.
• A central point of contact or department responsible for keeping product data current, including agreements on when data will be reviewed.
• Correspondence with production facilities on chemical treatments used, kept per batch or production order.
• Maintenance and repair information that already appears on labels or in customer service documentation, consolidated in a single overview per product model.
• An internal overview of which data are considered commercially sensitive and why, in preparation for the question of which information will subsequently be public and which will not.