texpas.eu

What is changing this year in the supervision of the textile passport?

No supervisory authority has been designated for the textile passport yet, but there is progress at EU level. This article outlines what is and is not yet established this year regarding enforcement.

Short answer: no supervision yet, but preparation underway

For those looking for what is changing this year in the supervision of the textile passport: no authority has yet been designated to specifically check whether clothing companies maintain a digital product passport. The obligation itself still needs to be established in a delegated act, which is currently expected in 2027. Supervision of something that is not yet mandatory does not exist. What is changing is the preparation for it: the European Commission is further developing the broader framework and Member States are setting up the structures within which market surveillance will then run.

This is particularly relevant for those already thinking about internal responsibility: who within the company keeps track of this, and which authority will you need to contact if questions arise. That question cannot yet be answered with certainty, but the groundwork for it is being laid this year.

What the framework regulation already provides for

The textile passport stems from the Ecodesign for Sustainable Products Regulation, the ESPR. That framework regulation is already in force and describes in general terms how market surveillance of products within the EU works: Member States organise checks on compliance with ecodesign requirements, and manufacturers and importers must be able to present documentation when requested. This is the structure within which textiles will eventually be placed, once the textile-specific requirements have been established.

What this means in practice and how the regulation is structured can be read in more detail in the knowledge base with the regulation explained by topic. This also explains how the general ESPR rules relate to the textile-specific implementation that is still to come.

What is not yet finalised

Two things are currently still open. First: which Dutch supervisory authority will be specifically responsible for checking the textile passport. This will only become known once the delegated act and associated implementing agreements have been published. Second: how strictly and in what manner that check will be shaped in practice. We deliberately make no prediction about that — that is up to the supervisory authority itself and to the text of the regulation once it exists.

What you therefore do not need to expect this year is a concrete designation of a supervisory authority or an enforcement framework specifically for textiles. What you can follow is the progress of the EU work programme, which indicates the order in which product groups will be addressed.

What is actually happening this year

The most important development this year is at EU level: the Commission is working towards the delegated act for textiles, with clothing of which eighty percent or more consists of textile fibres as the first category. In addition, as with any new regulation, preparatory discussions are taking place between Member States on how market surveillance is to be organised in practice. Such work is usually not visible to individual companies, but it does determine the structure in which you will eventually operate.

How we precisely follow this information and where the data on this page comes from can be read on the page how we monitor the official sources. As soon as the delegated act has been published, including any designation of a supervisory authority, this will be supplemented here.

What this means for your company

Even without a designated supervisory authority, it is worthwhile to already know roughly where you stand: which products will fall under the first category and which data you will need from suppliers once the obligation becomes concrete. This prevents you having to start from scratch when the delegated act is published.

For your own situation, with specific questions about liability or responsibility within your organisation, a lawyer or the future supervisor is the right contact. We describe the regulation and the current status, but do not provide legal advice on individual cases.

Would you like to see in advance how your company is likely to stand, without any obligations? Do the free product scan and get an indication in a few questions, or browse through the frequently asked questions about the textile passport for quick, short answers.

This article is general information and not legal advice.