do I also need to create a product passport for workwear and uniforms

Probably yes, if it falls under the textile category

Work clothing and uniforms are textile products, and the ESPR currently makes no general exception for clothing that is not sold to consumers. The regulation focuses on product groups, not on who the buyer is: a polo shirt with a company logo, an overall or a uniform is in terms of material and construction a garment like any other, and thus falls into the same category as clothing sold in a shop. Whether the passport will actually apply to it in practice depends on the delegated act that must establish the precise product groups and thresholds — this does not yet exist for clothing and textiles.

For whom this matters, and where the boundary lies

This subject is relevant for anyone who has work clothing or uniforms made, purchases them, or brings them onto the European market as an importer: catering companies with staff clothing, transport companies with uniforms, companies having promotional clothing with logos produced. The delimitation is not in the question "who wears it" but in "what kind of product is it". A woven or knitted garment made of textile fibres falls into the category that the first delegated act focuses on, regardless of whether it is intended for a shop shelf or a staff wardrobe. What can make a difference, however, is the proportion of textile fibres: the first delegated act is expected to focus on clothing with eighty percent or more textile fibres, so work clothing with a high proportion of other materials — a high-visibility jacket with many reflective plastic strips, for example — may not fall under it until later, or under a different delimitation. Protective clothing with a specific safety function (think of personal protective equipment that already falls under other EU rules) has its own regulatory framework, and it has not yet been established how these two frameworks relate to each other for the product passport. Purely promotional items that are not sold as garments but as giveaway articles are closer to a grey area than a uniform that is simply purchased as work clothing. What the ESPR generally does and does not affect within the clothing and textile industry is clearly described on the page about which clothing and textile products fall under the ESPR.

No fixed date yet, but a clear sequence

There is no yet established date on which the product passport for clothing — including work clothing — becomes mandatory. What is established is the sequence: the ESPR work plan 2025-2030 mentions a delegated act for clothing and textiles that is expected in 2027, with clothing of eighty percent or more textile fibres as the first delimitation. That act must still be drawn up, discussed and published before a concrete obligation date emerges, and only then will it become clear whether and how work clothing fits precisely under it. Until then, there is no obligation to create a digital product passport for work clothing or uniforms. How such a delegated act works exactly and why it determines what will ultimately need to happen is explained on the page about what a delegated act is and why it determines what you must do. As soon as there is a published text with a concrete date, it will be mentioned here.

What this means for those who are already purchasing or having work clothing made now

There is currently no action required, but it is wise to know in advance where the information will need to come from. Anyone who has workwear produced or imported can start by making an overview of the basic data that a passport will need later: material composition per item, country of production, and the supplier or manufacturer who can provide this data. That overview is useful in any case, regardless of the passport. It is then worthwhile to keep track of when the delegated act for clothing is published, as it will determine whether workwear falls under the first batch or a later one. For companies that are themselves small — a local print shop that prints company clothing, a family business that sews uniforms — it is also relevant to know whether an exception for smaller batches will be introduced; that is described on the page about whether the product passport also applies to small companiesAnyone who is unsure whether a specific assortment (think of sportily printed team clothing, or promotional items that are sold half as clothing and half as merchandise) falls under the textile category can best compare that question with the general delimitation on the page about whether the digital product passport applies to their own clothing and textiles.

The legal basis: Article 1 and Article 2 of the ESPR

That the ESPR designates product groups as a whole, and not the user or sales channel of a product, follows from Article 1 of Regulation (EU) 2024/1781 (ESPR), which establishes the subject matter and scope of the regulation at product level. The definitions in Article 2 of the same regulation indicate how a product within the meaning of these rules is delimited, which forms the basis for the subsequent delegated acts that specify the concrete obligations per product group — such as clothing and textiles. That delegated act for clothing does not yet exist, and as long as it has not been published, it cannot be said with certainty how workwear will be treated within it.

Anyone who is now already purchasing company clothing or uniforms would do well to start by putting the material and origin data per item in order, and to keep track of the publication of the delegated act for clothing and textiles — as soon as that becomes known, we will inform you here of what that concretely means for workwear.

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

Workwear and uniforms are textile products, and the ESPR makes no distinction in Article 1 and Article 2 of Regulation (EU) 2024/1781 based on the purpose for which clothing is worn. A polo shirt with company logo, an overall, a nursing uniform or a uniformed jacket for security personnel fall under the same product category as clothing sold in a shop. Moreover, the regulation itself does not yet determine which product groups must have a passport and on which timeline — that is worked out per product group in a delegated act. What exactly that is and why that act is decisive for what a company must do is explained on the page about what a delegated act is and why it determines what you must do.

In practice, workwear is subject to the same type of obligations as other clothing, with a few points of attention that are specific to this category.

Determining whether the product falls within the scope of application

For a company that has workwear produced or imported, this initially means an inventory: which clothing items are purchased, who is the manufacturer or importer thereof within the meaning of the regulation, and does the item fall under the textile category that the delegated act will designate. A company of 10 to 100 employees that, for example, has company clothing with a logo printed by a third party, would do well to determine in advance which responsible party in that chain applies. A general overview of which products from the industry fall under the ESPR is on the page about which clothing and textile products fall under the ESPR.

The distinction between personal protective equipment and ordinary workwear

Not all workwear is the same. An overall without a protective function is a regular textile product. Clothing that is primarily intended to protect the wearer — flame-resistant clothing, clothing with chemical protection, high-visibility clothing with a safety standard — generally falls under separate legislation for personal protective equipment. That distinction is relevant because it determines which regime applies alongside or instead of the ESPR. For a company of this size, this is a moment to review your own product list to see what is purely representational textile and what has a protective function.

Keep documentation regardless of who the end user is

The fact that workwear is not sold to a consumer, but is issued to one's own employee or delivered to a company for use by staff, does not change who in the chain is responsible for compiling the product passport. A company that has uniforms made and distributes them itself to its own locations functions in practice as the party placing the product on the market, and that is a position that calls for the same underlying data as with ready-made clothing: material composition, origin and the other data the product passport requires.

Where things go wrong in practice

A common assumption is that workwear is "internal use" and therefore falls outside the legislation. There is no distinction in the text of the regulation that is formulated in that way; it is about placing a product on the market, not about who the ultimate wearer is.

Another situation that is often overlooked: a company outsources the production of staff clothing to a supplier who delivers the clothing ready-made with a logo. Both parties then sometimes assume that the other is responsible for the product passport data, while neither has explicitly established that.

We also see that companies with a mix of protective and non-protective clothing — for example, a warehouse worker who wears both a high-visibility jacket and a regular polo shirt — place all clothing under one regime, while the two product types may fall under different legislation.

A fourth situation: small batches of workwear, for example twenty jackets for a sales team, are regarded as "not a production line" and therefore not included in the administration, while the size of the order in itself says nothing about whether the product falls under the legislation. Anyone wondering whether the size of their own company justifies an exception will find an explanation on the page about whether the product passport also applies to small companies.

A fifth situation arises in companies that have samples or test models of new uniforms made before placing a large order; the question of whether such a test model already falls under the obligation is a different matter than the definitive order and is addressed on the page about samples and showroom models that are not sold.

What you can record

An overview of all workwear items that the company has produced or imported, with the fibre composition and supplier for each item.
An agreement with the supplier or clothing manufacturer about who provides the data for the product passport and who maintains it during the useful life of the item.
A classification of your own range into "regular workwear" and "personal protective equipment", so it is clear which regime applies to which item.
Recording of the date and version of each design, especially for clothing that is replaced or modified periodically (for example with a new house style).
A file for each purchase order with the underlying material certificates, even if the order is small.
References to the broader context of your own obligations: what the product passport entails is described on the page about what a digital product passport for clothing and textiles is exactly, and when the obligation for the sector comes into force is stated on the page about when the product passport becomes mandatory for clothing and textiles.

Once the delegated act for textiles has been published and it is clear whether and how occupational clothing is specifically mentioned in it, we will update this page.

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.