If you are talking to a software supplier about the textile passport this year, the most important change is that there will be more technical clarity about what the passport will look like in practice. Work is underway on European standards for the data carrier, the unique product identification number and the register in which passports are registered. That work was already there last year, but the contours are becoming sharper this year, and that changes what questions you can ask a supplier.
For those to whom it matters: everyone who is already choosing a supplier or having an existing system adapted. The more concrete the technical standards become, the better you can assess whether a proposed solution aligns with them, rather than with the supplier's own interpretation.
Why the technology is still in flux
The regulation itself describes the objective: a passport that via a data carrier, usually a QR code, provides access to product information, remains available throughout the product's lifetime and aligns with a central EU register. How that is precisely arranged technically is not laid down in the regulation itself but is worked out in supplementary technical standards and in the delegated act for textiles, which according to the Commission's work programme is expected in 2027. Until then, standardisation organisations are working on the building blocks: what an identification number looks like, how a data carrier must be readable, how systems must be able to exchange data with each other.
That is the reason why a conversation with a software supplier this year proceeds differently than two years ago. There is more to refer to, and less room to say that "we will see when the time comes".
What you can ask about this year
A meaningful question to ask a supplier is not whether the system is "AI-proof" or "future-proof", but concretely which standards it follows and how it moves along once those standards are finally established. Ask, for example, how the supplier generates the unique product identification number and whether that aligns with the direction that standardisation organisations are currently following. Also ask how data is stored: in a format that is adaptable, or in a fixed structure that requires a new implementation with every change.
A second point is the register. The delegated act is expected to determine how passports are registered with a central EU register. Suppliers who are already anticipating this can usually explain better how their system is structured than suppliers who only say that "that will be added later". the knowledge base where these technical concepts are explained per subject indicates per component what is and is not yet established, with the reference in the official text included.
What is not yet finalised
It is important to distinguish between what is guidance and what is a firm rule. The technical standards being worked on are not all yet finalised, and the delegated act for textiles has not yet been published. A supplier who now already guarantees that his system "fully complies with the final version" claims more than can be substantiated at this time. A supplier who explains which choices he follows and why, and who indicates how he implements changes as soon as the final rules are known, provides a more realistic picture.
This is also the reason why many companies choose not to build the passport themselves, but to have it compiled by a party that structurally follows developments. This way you don't have to read every standardisation update yourself to know if your system still aligns. On the page that shows where our information comes from shows how we track sources and update them as soon as something changes.
How to prepare for this conversation
Do not enter the conversation with the question whether a supplier "uses AI" or "is compliant", but with concrete questions about identification numbers, data carriers and the register. Record what has been agreed, and arrange how changes will be communicated once the delegated act is in place. For a first overview of what is already established and what is not yet established for your type of product, you can see in a few questions where you stand now.
Do you not yet have a clear picture of what changes for your business, and what you should watch out for when connecting to a software supplier? Take the free quick-scan or read through the topics in the knowledge base. For your own business situation, it remains wise to also consult a lawyer, or ask the competent supervisory authority how they view a specific situation.