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What documents do you need to have ready for an inspection of your textile passport?

A supervisor does not only look at the passport itself, but also at the documents on which the data in it are based. This article lists which documents often come up in this regard.

What documents do you need to have ready for an inspection of your textile passport?

When a supervisor asks about the textile passport, the QR code and the page that opens behind it are usually the starting point, not the endpoint. The regulation requires that the data in the passport are traceable, and that means there must be a document, declaration or report somewhere on which that data are based. Those supporting documents are the part that receives the most attention during an inspection.

In practice, this concerns a limited number of categories: documentation on fibre composition, proof of origin and production location, declarations about recycled material if that is mentioned, and the documents from your existing product safety file that also appear in the passport. Which documents are needed depends on what is stated in your passport and the role you have in the chain; ultimately, this is decided by the competent supervisor or a lawyer, not by this article.

The passport itself is not the proof

A common assumption is that the passport, once completed and linked to the QR code, is the proof. That is not how the regulation is set up. The passport shows data; the supporting evidence for that data is a separate file that you, or the party that provided the data, must be able to show when asked. That distinction is precisely the detail that is most often overlooked during supervision and enforcement: all attention is focused on the passport and it is forgotten that the source of it must also be preserved and traceable.

This is more pressing in textiles than in many other product groups, because the composition and origin of clothing run through several links in the chain before they reach you. A percentage of cotton or a claim about recycled material is rarely measured by yourself; it comes from a supplier, a test laboratory or a certifying body. The question that comes first on the table during an inspection is therefore not "is this figure correct", but "where does this figure come from and can you prove it".

Which documents often come up

In most files that companies build for their textile passport, the same types of documents appear. Think of laboratory reports or certificates on fibre composition, delivery declarations from the manufacturer about material origin, certificates that support a percentage of recycled material if that percentage is communicated, technical documentation and declarations of conformity that are already kept for product safety, and correspondence or contracts that show which party provided which data. The latter is often just as important as the substantive documents themselves: with multiple links in the chain, a supervisor will also want to be able to determine who was responsible for which data.

Which of these documents you yourself must have and which may remain with your supplier as long as they are obtainable differs per situation and per role you have in the chain. read through the topics per situation provides an initial direction, but does not replace legal advice about your own position.

Why this weighs more heavily than it seems

Many entrepreneurs underestimate this part because the passport itself, once it is in place, seems to require little maintenance. However, the supporting file is the part that disappears fastest over time: a supplier changes, a test report is not requested again from a new batch, or the declaration that once came by email can no longer be found. Supervision and enforcement focus precisely on that traceability over time, not only at the moment of entry.

That is also why this part is often discussed separately from the rest of the passport process: it is not about what appears on the QR code, but about what must be demonstrable behind it, years later, possibly by someone other than the person who entered it at the time.

Who keeps what

In a chain with multiple parties, it is usual that not one company keeps all supporting documents itself. The manufacturer usually keeps the test reports and certificates on material and composition; the importer or the brand that has the passport compiled usually keeps the declarations and contracts showing which data were provided and by whom. Recording who keeps which document and for how long is something that is usually agreed in purchasing contracts with suppliers, not something that arises by itself.

Whether your current agreements with suppliers already cover this is something you can best discuss with your own lawyer or with the competent supervisory authority. You can get an initial impression of where you stand with your own products with a brief scan that shows you where you stand in a few questions.

What you can do now

Without having to wait for the final regulations, you can now already map out which documents you have in-house for your current collection and which you should request from suppliers. This prevents you from having to search for documents during a possible inspection that should actually have been with you already. How texpas.eu collects and traces such data is described on the page about how the information is compiled.

If you are unsure whether certain documentation is mandatory or sufficient in your situation, that is a question for a lawyer or for the supervisory authority competent in your case; this article describes the main points, not your specific file.

Do you want to first get an idea of what applies to your own products, without immediately creating an account? Do the free quick-scan or read the topics that are closest to your situation via the frequently asked questions about the textile passport.

This article is general information and not legal advice.