The passport every garment will carry.
The Digital Product Passport is a digital record attached to a product. A code printed on the label leads to it. Inside are the data an authority, a recycler and a customer are entitled to read. The framework is already law. The rules for textiles are not written yet, and that gap is the time a brand has to get ready.
What it actually is
A passport is not a page about your brand. It is a set of data attached to a unique identifier for the product, and it is reached through a code printed on the garment. In practice that code is a QR. Whoever scans it sees the part of the data they are entitled to see, and that part is not the same for a customer, a repairer and a market-surveillance authority.
The regulation also sets two conditions that are easy to miss. The passport must stay available for at least the expected lifetime of the product. And it must stay available even if the company that created it stops trading.
Where responsibility sits
The obligation falls on the economic operator who places the product on the European market. For most fashion companies that is the brand itself. If the brand is based outside the Union, the obligation falls on the importer.
A service provider may hold the data and publish the passport on your behalf: the regulation provides for this explicitly. What it does not provide for is the responsibility moving with the data. If the passport is wrong, the authority knocks on your door.
The regulation also sets a limit on that provider. It may not sell, reuse or process passport data beyond what delivering the service requires, unless you specifically agree to it.
What is decided and what is still open
Much of what is written about the passport mixes two different things. Some points are settled by a regulation that is already in force. Others will only be settled when the textile delegated act is adopted. Keeping them apart saves time.
- Decided: the passport exists, and every product covered by it must carry a data carrier that leads to it.
- Decided: access is differentiated by role, so not every reader sees the same fields.
- Decided: the European registry is an index of identifiers and not an archive of passports. The data stays with you or with your provider.
- Open: the exact list of mandatory fields for a garment. It will arrive with the textile delegated act.
- Open: how many years a textile passport must stay online. The regulation sets a floor, not a number.
The page is not the hard part
Publishing a page that a QR code leads to is a solved problem. The difficulty is elsewhere. The fields that page has to carry are not in your systems.
They sit in your suppliers' documents, and in the documents of their suppliers. Your manufacturer knows who sold them the fabric. The weaver knows who sold them the yarn. Neither has ever had a reason to tell you, and neither is obliged to answer quickly.
This is why bringing a supply chain on board is measured in months rather than weeks. It is also why the date that matters to you is not the one on the delegated act. It is the day you start collecting.
The passport outlives the contract
One line of the regulation shapes every choice a brand makes here. The passport must stay available even after insolvency, liquidation or the end of trading.
One consequence follows directly. A passport is not a marketing page you switch off at the end of a season: it is a commitment with a duration, and the duration is at least the expected life of the garment. When you choose who publishes your passports, you are choosing who will still be serving them in ten years.
Three things you can do before the delegated act exists.
Take one garment and go all the way down
A single product, from the finished garment down to the fibre, tells you in a week how deep your supply chain goes and where it breaks. No regulatory document will give you that.
Structure the documents you already receive
Invoices, bills of materials, certificates and technical sheets already contain much of what is required. The work is not asking for them again. It is reading them, having a person confirm each value, and recording which document vouches for which field.
Decide the address before you print
The code on the label is printed once and stays on the garment for years. If the address is decided before the print run, the passport can be completed later without reprinting anything.