If you sell clothing or textiles in several EU countries, the shortest reassurance is this: the substantive requirements for the digital product passport are laid down in a European regulation, and a regulation works in the same way in all Member States. So there will be no separate German, French or Spanish passport with different data fields. What can differ per country is not in the passport itself but in the way it is checked and enforced.
That distinction is more important for an entrepreneur than it may seem. A regulation is directly binding, unlike a European directive which must first be transposed into national legislation. For the product passport, this means that Member States cannot adapt the core obligations themselves. Where Member States do have room for manoeuvre is in the designation of the supervisory authority, in the penalties for breaches, and in practical matters such as language.
What is the same everywhere
The regulation determines which product groups fall under the obligation, what data a passport must contain at minimum and how the QR data carrier must work. That core does not change when a product crosses a border. A passport that has been compiled in the Netherlands for a clothing item does not need to be rebuilt as soon as the same product comes on the market in Belgium or Germany. This is also why many companies that sell in multiple countries have the passport compiled centrally rather than separately per market. Those who want to see exactly which data are needed for this will find an overview in the knowledge base with the subjects per situation.
What can differ per country
The first difference is in supervision. Each Member State designates its own market surveillance authority to check whether products comply with the regulation. Which authority that is and how it operates is not determined in the regulation itself but in the national organisation of supervision. For your own situation, the competent supervisory authority in the country where you sell is the right place to ask how checks proceed there precisely.
The second difference is in penalties. The regulation leaves it to Member States how they punish breaches and what fines are appropriate. A fine mentioned in one country therefore says nothing about what applies in another country. Do not invent amounts in advance; as long as delegated acts and national implementing legislation have not been published, this part is not yet fully clear.
The third difference is more practical: the language and accessibility of the information behind the QR code. Consumers in a country generally have the right to information they can understand, which in practice often comes down to the language of the country of sale. A passport designed for the Dutch market may therefore need to be supplemented if the same product is also sold in France or Italy. This is exactly the kind of detail it is good to discuss early with your software supplier or platform, so that multilingualism does not become a problem later.
Why this cannot yet be fully outlined
The underlying delegated act for textiles and clothing has not yet been published; the ESPR work plan mentions 2027 as the expected period, with clothing containing eighty per cent or more textile fibres as the first group. As long as that act is not in place, little can be said with certainty about the precise implementation per country. What is already clear is the structure: one European core, supplemented with national application of supervision and enforcement. Companies that are already exporting would be well advised to keep these two layers separate as soon as there is more clarity.
For anyone who wants to see how these two layers will come together in a company's practice, there is an explanation on the page about how data is processed and where the information comes from how the data is processed into a digital product passport. Questions that come up more frequently at companies selling in multiple countries have been compiled on the page with answers to frequently asked questions.
Would you like to first get a clear picture for yourself of whether and how this affects your products, without immediately creating an account? The free product scan that gives a first indication in a few questions shows you roughly where you stand, and the knowledge base helps further with the topics relevant to your situation.