Yes, you can collect the data for the textile passport yourself. Nothing in the regulation requires you to engage an external party for this. The question that matters in practice is not whether it is allowed, but whether it fits your business: how many suppliers do you have, how often does your collection change, and who keeps the data current once something changes.
The boundary between doing it yourself and outsourcing usually does not lie with the initial data collection, but with keeping it up to date. Collecting data once from a handful of fixed suppliers can be done with a spreadsheet. Once you work with multiple suppliers, switch seasons or assemble articles from components of different origins, keeping the data up to date becomes the work that is usually outsourced.
What exactly must be collected
The delegated act that works this out for textiles and clothing has not yet been published; the ESPR work plan mentions 2027 as the expected time, with clothing of eighty percent or more textile fibres as the first category. What is known from the regulation itself: the passport contains data on the origin and composition of a product, data that often already lies somewhere in your business, spread across purchase orders, certificates and correspondence with suppliers.
That scattered state is exactly where managing it yourself becomes difficult. The problem is not collecting one data point, but getting data from different suppliers, in different formats and with varying degrees of completeness, to one place and in one form. Those who do this for a handful of articles often only realize at article twenty or thirty how much time it structurally costs.
What you can realistically do yourself
Requesting data from your own suppliers is work that belongs with your business and that no one knows better than you: you know who your suppliers are, what agreements are already in place and what documents you already have for other purposes. worked out per subject what is needed provides an overview of which data are usually requested and where you probably already find them in your own administration.
Also documenting an initial inventory — which articles you have, from which suppliers, with what documentation — is something you can do yourself without having to buy anything for it. A brief scan that answers five questions shows where you stand gives you an initial direction without immediately committing you to anything.
Where outsourcing becomes more logical
What is less good to do yourself is keeping data current over time, making each data point traceable to the source, and technically linking that data to a QR code that must work for ten years. This is not because the law requires you to outsource this, but because maintaining it becomes a task that remains alongside daily business operations once there are more than a few articles involved.
There is also the difference between a spreadsheet and a platform: a spreadsheet records what you put in it, but does not monitor whether data is still correct, who supplied it, and what changes if a supplier switches. How that traceability works in practice is explained at the page showing where the information comes from.
What remains, even if you outsource
Outsourcing the technical part does not mean the data itself does not have to come from you or your supplier. A platform can host data, organize it and link it to a data carrier, but cannot verify whether a supplier has provided the correct fibre composition. That responsibility, and the question of who plays which role within the chain, remains with the parties involved.
For the precise allocation of that responsibility, and for questions that cannot be answered with a general response, it is advisable to consult the official text or involve a lawyer familiar with your specific situation.
Would you like to first see how much work data collection for your own articles requires, before you choose between doing it yourself and outsourcing? The free quick-scan provides an initial indication for this, and the frequently asked questions about the textile passport answer many of the practical follow-up questions that arise after such an initial inventory.