If you also sell clothing or textiles outside the Netherlands, the first reassurance is that the digital product passport is a European obligation: the basic rules apply in the same way throughout the EU. However, there are points where countries can differ, and those points are precisely what you discuss with your software provider before you choose or expand a system.
This concerns mainly three things: the language in which information is presented to the consumer, which supervisory authority in which country is competent, and whether, in addition to the passport, there are still national requirements that stand apart from it. None of those points changes the core of the passport itself, but they do determine how your software provider must set up the system if your articles are placed on the market in multiple countries.
What remains the same, because the EU regulates it
The regulation that underpins the digital product passport is a European regulation. This means that the core is the same everywhere: which data belong in the passport, that a QR code is used as a data carrier, and that the passport must remain accessible for ten years. A Member State cannot adapt or tighten this core on its own initiative. So in principle, it does not matter for the technology and structure of the passport whether an article is sold in the Netherlands, Germany or France.
The delegated act that will set out the data requirements for textiles and clothing still needs to be published; the work programme of the European Commission states 2027, with clothing of eighty percent or more textile fibres as the first category. As long as that act is not in place, it is not yet definitively established how detailed the data must be. What has already been published you can read via the official text; the knowledge bank sorted by subject sets out per theme where that can be found.
Where countries can differ
Even within a single European regulation, there remains room for national implementation. For example, the language in which consumer information is presented can differ per country where the product is sold — that does not affect the passport as such, but it does affect the way it is presented to the end customer. The supervisory authority that in practice oversees compliance is also a national matter: each Member State appoints its own market surveillance authority. And some countries already have their own longstanding labelling requirements that continue to exist alongside the passport, for example regarding textile names or specific warnings.
None of these differences is spectacular, but they are precisely the reason why a software system designed only for the Dutch market is not automatically suitable as soon as you also sell elsewhere.
What you ask your software provider
If you also sell in other EU countries, it is worthwhile to raise a number of concrete questions. Can the system display the same underlying data in multiple languages, depending on the country of destination, without you having to enter the data twice? Is it recorded which data are mandatory regardless of the sales country, and which additions are country-specific? And how is a change in regulation — for example an adjustment by a Member State to its own labelling requirements — implemented in existing passports, without you having to keep track of that yourself per article?
Data management is also a topic that deserves attention in this conversation: where the data are hosted and how they are secured is relevant for any company, but becomes more important as soon as multiple countries and thus multiple parties need access. how we handle privacy and data shows which choices play a role in that.
What this means for your contract
The answers to these questions belong not only in conversations at home, but also in the agreements you establish with your software supplier. Think about who is responsible for updating country-specific blocks if regulations change there, and how quickly that happens. A supplier who handles this proactively will save you work as soon as you add a new country to your sales market.
If you want to map out for yourself how your current situation relates to what can differ per country, then the free quick-scan with a few short questions provides an initial indication. For questions that are slightly more specific than this article, there is an overview of frequently asked questions.
What is not yet finalised
The date on which the obligation for textiles and clothing actually takes effect is not yet fixed. The Commission's work plan mentions 2027 for the delegated act, with clothing of eighty percent or more textile fibres as the first category; the actual entry into force of the obligation follows after that. As soon as this is published, it will be updated here. For translating this into your own situation, and especially where it comes to selling in multiple countries simultaneously, a lawyer or the competent supervisory authority remains the appropriate point of contact.
If you first want to get an impression of what is relevant for your company, then do the free quick-scan or browse through the topics in the knowledge base — both can be consulted without any obligations.