The short answer
A supplier is, in short, the party that places a clothing item or textile product on the EU market for the first time under its own name or brand, or that has it manufactured and sells it under that name. In practice, this is often not the factory where the clothing item is sewn, but the company that puts the label on it: the brand, the importer that purchases directly from outside the EU, or the private label party that has a collection produced and sells it under its own name.
This term was not chosen lightly from a linguistic perspective. The regulation places responsibility for the digital product passport with the supplier, regardless of where production itself takes place. Anyone wondering whether this applies to their own business does not look at the question "do we manufacture this product", but rather at the question "under whose name does this product reach the consumer".
Why this single term carries so much weight
Textile chains often span multiple countries and multiple links: a fabric woven in one country, cut and sewn in another, and then sold under a brand based in the Netherlands or elsewhere in the EU. Without a clearly identifiable responsible party, no one would need to demonstrate exactly that the data in the passport is correct. The regulation solves this by placing one role at the centre: the supplier is the one who ensures that the passport exists, that it is correct, and that it remains accessible throughout the entire lifetime of the product.
This does not mean that other links in the chain are left out of the picture. A manufacturer that produces textiles but does not sell under its own name, an importer that purchases for another brand, and a distributor that only resells: they all play a role, and the regulation describes those roles separately. But the supplier is the one with whom the core of the obligation lies. You can read more about how those roles relate to one another in the knowledge base worked out per situation.
Supplier versus manufacturer, importer and distributor
The difference lies mainly in the question of under whose name and responsibility the product reaches the market. A manufacturer that produces exclusively on behalf of another brand and does not itself appear as a selling party is usually not the supplier in the sense of the regulation. An importer that sources products from outside the EU and subsequently places them on the market under its own brand name may be. A private label company that has a collection made and sells it under its own label falls in most cases under this role as well.
This classification sounds simpler than it sometimes is in practice. In mixed constructions, for example where a brand partly manufactures itself and partly purchases from third parties, or where a group operates multiple labels from one legal entity, it is not always immediately clear who fulfils which role. The official text provides the definitions; the application to a concrete business structure is something that a lawyer or the competent supervisory authority can advise on.
What a supplier must be able to demonstrate in practice
The obligations that attach to the role of supplier revolve mainly around traceability: where the product comes from, what materials it is made of, and what information a consumer or supervisory authority must be able to access via the QR code. For clothing companies that work with multiple suppliers and production locations, this is a practical question: who supplies the data, who checks it, and who is accountable if something is missing.
This is precisely the point where the conversation with a software supplier or service provider becomes relevant. Not every party that claims to be "passport-ready" automatically takes into account the question of who qualifies as the supplier in your specific chain. If you want an indication of where your business roughly stands, the product scan with a few questions provides an initial indication before you have those conversations.
What is not yet finalised
The delegated act that specifies the precise requirements for the digital product passport for textiles is expected in 2027 according to the European Commission's work plan, with clothing consisting of eighty percent or more textile fibres as the first category. Only after publication of that act will the date from which suppliers must actually start working be established. As long as that date has not been published, 2029 is an indication and not a confirmed figure.
The precise definition of who qualifies as a supplier in borderline cases can also be further clarified through later implementing measures or guidelines. If you want to establish structure at this moment, it is advisable to map out your own supply and sales chain: which products do you sell under your own name, which under the name of another, and where is the boundary. How we keep that information for you and where the data comes from is explained on the page about how the information is compiled.
First find out where you stand
Whether your company falls under the definition of supplier depends on the precise role you fulfil in your chain, and that differs per brand, per collection and sometimes even per product. For your own situation, a conversation with a lawyer or the competent supervisory authority is the appropriate course of action; for a first orientation you can do the free quick-scan or read the frequently asked questions. If you are uncertain about exactly where you stand in this chain, then the frequently asked questions are a good starting point before you take further steps.