Who is responsible for the product passport for clothing and textiles?
The manufacturer bears the responsibility, not the shop
The manufacturer is responsible for the digital product passport for a clothing item or textile product. Article 27 of the ESPR (Regulation (EU) 2024/1781) describes the obligations that come with this: the manufacturer ensures that the passport is available with the product and that the information in it is correct. Who qualifies as a "manufacturer" in practice is not always the party that weaves the fabric or sews the clothing item. In most cases, it is the one who places the product on the EU market under their own name or brand — thus also a clothing brand that has it produced abroad, or an importer who sells under its own label. The platform texpas.eu plays a supporting role in this: it compiles the passport from the data supplied by the manufacturer or importer, hosts the passport for ten years and supplies the QR data carrier by which the passport can be consulted. The responsibility for the accuracy of the underlying data remains with the manufacturer or importer themselves.
For clothing brands, importers and private label — not for resellers
This obligation is directed at the party that places a clothing item or textile product on the EU market for the first time. This affects clothing brands, importers from outside the EU and companies that operate under private label, because they are in most cases the one designated as the manufacturer. It does not apply to shops or platforms that resell products already placed on the market — they act as a distributor, not as a manufacturer, and Article 27 is aimed at the manufacturer. Nor does every textile product fall under the same rules from the start: the European Commission's action plan for 2025-2030 mentions clothing with eighty percent or more textile fibres as the category that comes first. Products that fall outside this will await a later delegated act or may fall outside it altogether — this is not yet determined.
A date that is not yet fixed: first the delegated act
There is no fixed date yet on which the obligation for clothing and textiles becomes effective. What is established is the route to it: the ESPR itself (Regulation (EU) 2024/1781) is the framework regulation, and the actual obligation for a product category only arises through a delegated act that is established specifically for that category. According to the Commission's action plan for 2025-2030, that delegated act for textiles is expected in 2027, with clothing of eighty percent or more textile fibres as the first category. Until that act is published, there is no concrete obligation for this product category on the basis of this action plan. Once the delegated act is in place, it will also establish the date on which the obligation comes into effect — that date will be updated in this place as soon as it is known.
What this means for those who must prepare a passport
Those preparing for this should start by asking whether they fall within the definition of manufacturer: do they place the product on the EU market under their own name or brand, or only as an intermediary? Next, it is relevant to consider whether the product falls within the first product category — clothing with eighty percent or more textile fibres — because that comes first according to the action plan. After that, it is practical to map out in advance which data will be needed: material composition, origin, and supply chain data, since these typically form the basis of a digital product passport under the ESPR. Because the delegated act has not yet been published, it is not yet possible to comply with a concrete obligation now — but it is possible to get data in order in advance, so that the transition will be easier later.
The legal basis: Article 27 and Article 9 of the ESPR
This explanation follows from two articles of the ESPR (Regulation (EU) 2024/1781). Article 27 describes the obligations of manufacturers, including the provision of a correct and available digital product passport. Article 9 describes what a digital product passport contains and what conditions it must meet, such as the link to a data carrier. Together, both articles form the framework within which a delegated act for a specific product group, such as textiles, is further specified.
Those wishing to start now can begin collecting data on materials, origin and supply chain of their own collection without waiting for the delegated act — this is the basis on which a passport will later be built, regardless of the exact implementation date.
What this is based on
- Regulation (EU) 2024/1781 (ESPR), Article 27 (obligations of manufacturers)
- Regulation (EU) 2024/1781 (ESPR), Article 9 (digital product passport)
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 ESPR (Regulation (EU) 2024/1781) places responsibility for the product passport primarily with the manufacturer. Article 27 of the ESPR sets out a series of obligations that come with that role. Who exactly "the manufacturer" is is not always the party that physically makes the clothing — it can also be a company that puts a product on the market under its own name. Uncertainty about this is one of the most common bottlenecks, and it is worth considering first to determine whether a company qualifies as an importer or manufacturer under the ESPR.
Ensure that the passport exists and is correct
Article 27 of the ESPR describes that the manufacturer is responsible for the accuracy and completeness of the information in the passport. For a company with 10 to 100 employees, this means in practice that the data on materials, origin and composition that presumably already exist in a technical file, purchasing specification or supplier declaration can be reused — but must be checked and up to date at the time the passport is compiled.
Ensure that the passport is linked to the product
Article 9 of the ESPR describes the requirements for the digital product passport itself, including the link with a data carrier — in practice a QR code on the product or the label. For a clothing brand, this means there must be a procedure to link each batch, or even each item, to the correct passport. With small runs with many variants (colours, sizes, minor material changes per delivery) this is a practical task that goes beyond creating a single passport once per collection.
Ensure that the passport is retained
The passport must remain available even after a product has long been sold. For a company that would have to manage this itself, this means an obligation that does not stop at the point of sale, but extends over the entire period during which the product can still be on the market or is still in use by consumers.
Ensure that the role in the chain is clear
Whoever has a collection made by a third party does not automatically stay out of the picture. In private label collections the question of who actually qualifies as the manufacturer is not always straightforward, and the same applies to companies that sell under their own brand while production is outsourced externally. A wholesaler that repacks, relabels or resells clothing under its own name should also determine which role fits, because that determines which obligations from Article 27 of the ESPR apply.
Where things go wrong in practice
A first recurrent situation is that a company assumes the manufacturer abroad will arrange the passport, while no explicit agreement has been made about it. Once the manufacturer is located outside the EU, the practical responsibility often shifts to the party that brings the product onto the EU market — this is a question that deserves separate attention when the manufacturer is established outside the European Union .
A second situation arises with collections sold through multiple channels, including an online marketplace. The marketplace itself is not automatically the party that provides the passport, but expectations about this between brand and platform are not always documented — something to think through when selling via an online marketplace.
A third situation is the assumption that a distributor or trader has no role at all because they did not commission the product themselves. A distributor typically has different obligations than a manufacturer, but "different" is not the same as "none" — see on this the obligations of a distributor or trader.
A fourth situation is that the data do exist, but are scattered across procurement, quality control and marketing, without one department having an overview of the connections. In the event of an inspection or a question from a buyer, it then turns out that no one has the complete picture.
A fifth, often underestimated situation: the product passport is created, but not updated when the collection changes — a different yarn supplier, an adjusted fibre composition — meaning the passport no longer matches the product actually being sold.
What you can record
- An overview of who in the supply chain acts as manufacturer, importer, distributor or dealer, per collection or product line.
- Written agreements with the manufacturer or producer about who supplies the data for the passport and who verifies it.
- A fixed procedure for linking QR codes or other data carriers to batches and variants, including what happens when colours or materials change.
- A storage agreement: who ensures the passport remains available, and for how long, even if the cooperation with a manufacturer or platform ends.
- An internal point of contact or process owner for the product passport, so that responsibility does not get lost between departments.
Anyone who is not yet certain whether the passport applies to a specific collection at all, would be well advised to check this first with whether the digital product passport applies to their own clothing and textiles, before working out the roles in the supply chain.
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.