The short answer
Whether the textile passport applies to clothing currently in your warehouse depends on the moment when that clothing is actually sold or delivered, not on the moment when it was produced or purchased. The regulation points to the so-called placing on the market: the moment when a product is first made available on the EU market. Inventory that has been lying in a warehouse for years and is only sold after the date when the obligation takes effect can thus still fall under the obligation.
At the same time, this is one of the points that have not yet been definitively worked out. The delegated act that makes the obligation concrete has not yet been published; it is expected in 2027 within the ESPR work plan for 2025-2030, with clothing that consists of eighty percent or more textile fibres as the first category. Only when that text is available will it be clear how existing inventory is handled and what transitional rules apply.
What 'placing on the market' means
The term 'placing on the market' is a fixed concept in European product legislation and refers to the moment when a product is first made available on the market, regardless of whether that happens via a webshop, a physical store or a wholesale channel. It is therefore not about the moment of production, import or stocking, but about the moment when the product reaches the customer. For companies working with seasonal collections, this can mean that clothing now purchased is only 'placed on the market' several months or even a year later.
Inventory that remains longer in stock
For clothing that has already been sold or delivered before the obligation takes effect, the situation is different from clothing still waiting for a buyer in the warehouse. Supervisory authorities typically look at the moment of actual market introduction in such matters, not at the production date. This means that a collection produced some time ago but only sold after the effective date could potentially still fall under the obligation. What transitional periods or exemptions the delegated act will include in this regard is not currently known.
What this means for seasonal collections
For companies working with inventory cycles of multiple seasons, such as outerwear or basic collections that last for years, this is more than a theoretical question. A garment designed and ordered now could very well reach the customer only after the obligation's effective date. It is therefore advisable to take into account when planning new collections the possibility that data on fibre composition, origin and care will be needed at a later date, even if the order is placed now.
This also affects the agreements you make with suppliers. If you now conclude a contract for a collection that will only be delivered in a year's time, it is wise to specify what data the supplier can provide and at what point in time. the knowledge base with explanations per situation provides an overview of the topics involved, from fibre composition to origin information.
What you can do now
Because the exact effective date and transitional rules are not yet fixed, there is no reason to accelerate inventory reduction or hastily adjust purchasing plans. However, it is advisable to already identify which products in your assortment fall under the category of clothing with a high share of textile fibres, since those will be the first to be affected. With a few questions to get an initial indication shows where your company stands, providing insight without requiring you to create an account immediately.
It is also useful to discuss now with your software supplier or internal administration how data per product batch are recorded, so that you do not have to reconstruct afterwards which fiber composition belongs to which inventory batch. On the page on how data collection works explains where the information for a passport comes from and how that process works in practice.
For the precise explanation of concepts such as 'placing on the market' and the consequences thereof for your specific situation, it is advisable to consult the official text or involve a lawyer. Supervisory authorities in the Netherlands and other EU countries are the designated party to answer questions about enforcement; this article describes the system, not the outcome for an individual company.
Curious where you stand
If you want to know whether your product assortment falls within the first category of the obligation, gives the overview of frequently asked questions a practical starting point. If you prefer a direct indication for your own situation, then the free quick-scan is a good first step without any obligations attached to it.