Corporate clothing with a logo is, first and foremost, simply clothing for the purposes of the regulation. The regulation looks at the product itself — a polo shirt, an overall, a uniform jacket — and not at who wears it or for what purpose it is ordered. As long as the garment consists of at least eighty percent textile fibres, it falls under the same category as the clothing you buy in a shop. The logo does not change that.
What matters is who bears the obligation. This is not automatically the company that has the clothing printed or distributes it to staff. The regulation places the obligation on the economic operator: the person who manufactures, imports or places the product on the market under its own brand. If you purchase work clothing ready-made from a supplier who sells it under its own brand, the obligation lies with that supplier. If you yourself import textiles and sell or distribute them under your own company name or brand, you may find yourself in that role.
Who is the economic operator in the case of corporate clothing
For an installation company that orders overalls from a specialised supplier, little often changes in practice: the supplier provides the product, places it on the market and bears the obligations that come with that role. The installation company is then a purchaser, not an economic operator. This is different as soon as a company has textiles manufactured abroad, imports them directly and then provides them to staff or customers under its own name. At that point the role shifts, and with it the question of who must have the passport drawn up. What exactly an economic operator entails and where the line is drawn can be found in more detail in the knowledge base with explanations for each role in the supply chain.
Private label work clothing — a collection purchased under its own brand name and resold to other companies — makes this question particularly relevant. The party that places the brand name on the label is in many cases the one designated as the economic operator, even if production is fully outsourced.
Work clothing with a safety function is a separate category
A nuance often overlooked by installation, construction and technical companies: clothing with a protective function, such as flame-retardant overalls or a high-visibility jacket, is usually also personal protective equipment. Such clothing has long been subject to its own safety requirements and inspection rules, separate from the textile regulation. The two sets of rules do not exclude each other, but the safety requirements for PPE are and remain a separate track. In the case of ordinary corporate clothing without a protective function — a polo shirt with a logo, formal business wear — this issue does not apply and only the rules that apply to textiles and clothing in general are relevant.
What this means in practice
The essence is thus twofold. First: the fact that clothing is corporate clothing does not exclude it from the regulation. Second: the question of who is responsible for the passport does not follow from the use of the clothing, but from the role a company plays in the supply chain — purchaser, importer or brand owner. This distinction is precisely where many companies stumble in practice, because a supplier contract often does not explicitly define which role each party fulfils. When drawing up or renewing purchasing conditions, it is therefore useful to explicitly agree with the supplier on this division of roles.
The delegated act that sets out the precise obligations and the date has not yet been published; the European Commission's work plan mentions 2027 as the expected timeframe, with clothing containing eighty percent or more textile fibres as the first category. As soon as that act is in place, this article will be updated. For those who want to know now whether their own position in the supply chain requires attention, the product scan with an indication in a few questions is a first step, and the collection of frequently asked questions provides answers to comparable cases of doubt.
If you need a complete overview of what changes per role and per product group, you will find that in the knowledge base. For your own, specific situation — especially if you are in doubt as to whether your company is designated as an economic operator — a lawyer or the competent supervisory authority is the appropriate point of contact.