When your company is included
Whether the regulation is relevant to you does not depend on how many people work for you or what your turnover is. It depends on two other things: what role you have in relation to a garment or textile product, and whether that product will fall under the first category that becomes mandatory. An installation company that has workwear printed with its own logo can thereby come into view, whereas a shop that only resells existing branded clothing usually will not.
The core of it is this: the obligation affects those who place a product on the EU market or are responsible for it — the manufacturer, the importer, or the brand that has a product made under its own name. If you are such a party, there is a greater chance that this affects you. If you are only a reseller of another's brand, responsibility usually lies elsewhere in the supply chain. What those roles precisely entail is set out in the concepts from the regulation listed.
Your role in the supply chain matters greatly
HR managers and office managers who have workwear or representative clothing made with their own company logo often do so through a supplier that actually produces the garment. Who in such a cooperation is regarded as the first responsible party differs depending on the situation: sometimes it is the supplier, sometimes the company that places the order and applies its own brand. That distinction does not lie in a simple rule of thumb, but in the way the regulation defines roles such as manufacturer, importer and brand owner.
For private label, a similar question often applies. A brand that has clothing produced by an external factory and sold under its own name typically acts in practice as the party responsible for the product, even though the factory does not itself stand behind it. This is a recurring theme for SMEs working with private label, and it is precisely why your own role must first be clear before you can assess whether something applies to you.
The product must fall within the first category
Besides the role, the product itself matters. The delegated act that makes the obligation concrete is expected according to the European Commission's work plan for 2027, and the first product group that falls under it is clothing with eighty percent or more textile fibres. Other textile products and accessories will follow at a later date, in an order that the Commission has yet to determine.
That means a company that places only leather bags, shoes with a lower textile content or non-textile accessories on the market will for now fall outside the first round — even if the product seems related at first glance. For companies working with mixed collections, it is therefore possible that part of the assortment comes into view earlier than the rest.
What is not yet finalised
The date on which the obligation actually enters into force is not yet fixed. The Commission's work plan names 2027 as the moment when the delegated act is expected, and common estimates point to around 2029 for the moment when clothing must actually have a passport. As long as that act has not been published, this is an expectation and not a fixed fact. Once the official text is available, that is the time to review your own situation again, for example with the help of the source reference that accompanies each topic in the knowledge base.
The precise elaboration for smaller companies and for niche applications — think of workwear in small batches — is also not yet fixed. Such details typically follow only with the delegated act itself, and not with the framework regulation that is already in place.
Check for yourself whether this applies to you
Because role and product together determine whether the obligation applies, a general answer for "SMEs" cannot be given. What is possible: assess your own situation against the two factors stated above, and document that for when the delegated act is published. In a few questions you can see where your situation stands approximately, without needing an account for that.
For those who want to know where the information on this site comes from and how it is maintained, that is explained on the page about how we work. For your own, specific situation — especially if you are in doubt about your role in a particular supply chain — a lawyer or the competent supervisory authority remains the appropriate party to provide clarification.
Do you still have a question after reading that was not addressed here? Then check the questions other entrepreneurs ask us, or take the free quick-scan to see in a few minutes which topics may be relevant for your company.