What a garment passport will have to contain

Where the list comes from

In May 2026 the Joint Research Centre published a study on the content of the Digital Product Passport for textile apparel. It is the first document to describe a garment passport field by field rather than in principle.

Its status is worth stating precisely, because most summaries of it do not. The report carries the disclaimer that it is an external study prepared for the Joint Research Centre and that its contents do not necessarily reflect the position of the European Commission. It is an input to an impact assessment. Nothing in it binds anyone.

It is also the best available preview, and the timing is what makes it worth reading now. A public consultation on it closed on 26 June 2026. The binding list will be set by the delegated act, expected in 2027 and applying around 2029 — see the timetable.

The number that is repeated, and the number in the document

Almost every article on this subject, and several vendors’ playbooks, state that the study defines 49 data points. The figure does not appear in the study. Its summary tables enumerate 41 fields.

The point is not the arithmetic. A number that nobody checked has been repeated until it reads as a fact, in a subject where brands are being asked to make decisions about budget and staffing. The document is public and downloadable, and a claim about it can be verified in the time it takes to open it.

Four categories

The fields fall into four groups. The first two identify things, the third describes the product, the fourth proves what the third says.

• Product identification and classification — the article number, the model and batch identifiers, the customs classification, and the product category the article belongs to.
• Identification of the operators — who manufactured it, who imported it, in which facility, with names, addresses and identifiers. Facility identity sits here, not in the product description.
• Product information — fibre composition, a robustness score, a recyclability score, recycled content and the kind of recycling it came from, substances of concern with their concentration, the environmental footprint, care instructions and warranty.
• Conformity documentation — either a certificate, or a declaration accompanied by the parameters used to calculate what was declared.

What a brand already holds, and what has to be asked for

Roughly half of it exists already, in documents that circulate through the supply chain every season. Fibre composition is on the bill of materials. Countries and facilities are on delivery notes and orders. Certificates — GOTS, GRS, OEKO-TEX — are issued to suppliers and sent as attachments. The batch identifier exists in production and logistics systems, because goods are already shipped in lots.

The other half is not in anyone’s files. A recyclability score is a calculation nobody has run. An environmental footprint is a study nobody commissioned. The concentration of a substance of concern is a laboratory value the brand has never asked for, held by a mill three levels upstream. These are the fields that decide how long preparation takes, and why the textile chain is the difficult case.

The distinction matters for sequencing. The data that already exists needs structuring; the data that does not exist needs commissioning, and commissioning takes seasons rather than weeks.

Who sees which part

A passport is not one document shown to everyone. The study proposes three levels of access, and the placement of individual fields is more interesting than the principle.

Substances of concern are public, by name and by concentration — but where the substance sits in the garment is restricted to parties with a legitimate interest. The class of environmental performance is public, while the absolute footprint value and the parameters used to calculate it are not. An operator’s name and address are public, while its contact details are for authorities only. Every conformity certificate is for authorities only.

The pattern is consistent: what a consumer needs in order to compare is public, what an auditor needs in order to re-check is not, and what a competitor could use commercially stays out of both.

Two ways to prove it

The study describes two routes, and the choice has consequences for cost and process rather than for the passport’s appearance.

In the first, the declaration is backed by third-party certification and only the certificate goes into the passport. In the second, the declaration stands on its own and is accompanied by the calculation parameters and the technical file, kept at restricted access so that a market surveillance authority can recalculate the result.

The second route publishes nothing more to a consumer and requires considerably more to be assembled and retained. The study itself notes the risk that it buries authorities in data they have no capacity to check.

Which garments, and which are excluded

The proposed scope is apparel made of at least 80 % textile fibres by weight, in ten categories: t-shirts, shirts and blouses, sweaters and mid-layers, jackets and coats, trousers and shorts, dresses, skirts and jumpsuits, leggings, tights and socks, underwear, swimwear, and textile accessories. Workwear and sportswear are included.

Smart textiles and e-textiles are excluded, as are personal protective equipment, medical devices and toys, each of which is regulated elsewhere. So are intermediate products — fibres, yarn and fabric — which means the obligation attaches to the finished garment and not to what it was made from. Footwear does not appear in the list.

One clarification the study makes explicitly: attaching an RFID or NFC tag to a garment does not turn it into an e-textile and does not move it out of scope.

One rule that changes what a passport is for

Voluntary entries are limited to non-environmental information — logistics codes, payment terms, and similar. A brand may not add its own sustainability indicators, scores or claims to the passport.

The study gives the reason plainly: a strict exclusion of voluntary environmental content prevents greenwashing. It is worth reading against the way the passport is often described in the market, as a storytelling channel to the consumer. As specified, it is the opposite of one.

What can be prepared before the act

The fields will change. Where each field would come from will not.

What survives any redraft is the map: which suppliers sit behind each material, which of them holds which document, in what form that document arrives, and which values nobody currently produces. A brand that has that map can satisfy a list it has not yet seen. A brand that starts on the day of publication is asking suppliers for a history of seasons they have already closed.

Common questions