If your company has been placing clothing or textiles on the market for some time, you almost certainly already have a file related to product safety. Think of a technical file, a declaration of conformity, test reports from a laboratory, or safety data sheets for chemical substances used. Part of those documents indeed contains data that also goes into the textile passport, such as fibre composition, origin of materials or the dyes used.
The key detail here is that a product safety file and a textile passport have been drawn up for different purposes. The first was made to demonstrate that a product is safe under normal use. The second was made to make the origin, composition and circularity of an article traceable. The same source data can appear in both, but often at a different level of detail, for a different unit, or linked to a different product line than the specific article number that the passport asks for.
Which documents are often already available
For most companies that have been selling textiles for some years, there is a technical file built around the General Product Safety Regulation. It typically contains a declaration of conformity, test reports from a laboratory or notified body, and sometimes a safety data sheet for chemical finishing. Furthermore, manufacturers often already supply certificates on fibre composition or country of origin, for example for customs or labelling purposes. All these documents are a good starting point to see which data already exist somewhere in your organisation or with your supplier.
Where it does not quite fit
The connection often breaks down at the level of detail. A test report on fire safety provides a pass or fail result, but no exact percentage of fibre composition. A supplier's certificate of origin sometimes only mentions the country, while the passport may ask for the specific production location. And a safety file is often drawn up per product line or collection, while the passport must be correct per article or even per batch. These are not errors in the existing documents; they are simply made for something else. Anyone who maps out this difference early on prevents it from later becoming apparent that an apparently complete file has gaps.
What to do with that difference
It is useful to check for each piece of data that the regulation asks for whether an existing document contains that data, and at the correct level of detail. If something is missing, it is often easier to obtain from the supplier than to reconstruct later. If you have multiple suppliers, you will also notice that one company already supplies this kind of data in a structured way and another does not yet. An overview of what a provider must precisely record in this context is described in the knowledge base with explanations by topic. This also explains how the term provider relates to brand, importer and manufacturer.
Who ultimately assesses whether it is correct
Whether an existing document actually qualifies as supporting evidence for the passport is ultimately for the competent supervisory authority to assess, not for a software supplier or service provider. For your own situation, it is advisable to discuss this with a lawyer or the supervisory authority, especially when files from several countries are combined. However, it is useful to know in advance what the source of the regulation itself is and how it is structured; this can be found via an explanation of where the information comes from.
Anyone wanting to see which documents for their own assortment are likely already available and which are still missing can find out most quickly by asking their own suppliers, or first get an indication of their own situation in a few questions. For companies unsure whether a specific document already meets requirements, an overview of frequently asked questions is available on the frequently asked questions page. The free quick-scan provides an initial direction in a few minutes, without requiring an account.