What a textile passport has to carry, and where each field comes from

The question every apparel brand asks first is what goes in the passport. The answer is set by the delegated act for the category, and until that act is adopted the precise field list is not final.

What is already clear is the shape of it, and the shape is more useful for planning than the list, because it tells you where the work is.

Four groups, and only one of them is yours

Group the requirements by where the data physically lives and the project plan writes itself.

Identity. What the product is, which model it belongs to, which batch or item it is, which economic operator placed it on the market. This lives in your own systems. You can produce it in days.

Composition and materials. Fibre content, share of recycled material, substances of concern. This lives with your mills and their suppliers.

Supply chain. Which suppliers, which production facilities. This lives with your Tier 1, who know their Tier 2, who may or may not know their Tier 3.

Lifecycle. Durability, repairability, care, disassembly, end of life. This is partly a design decision and partly a testing exercise, so it lives between your product team and your labs.

Three of the four groups are outside your four walls. That single fact explains why digital product passport (DPP) projects that start as IT projects stall, and why the ones that succeed start in sourcing.

Granularity is the hidden cost

The expensive question is not which fields. It is at what level.

A field declared per style is one number. The same field declared per production batch is a number per batch, tied to a specific supplier, a specific facility and a specific date, and it has to be captured at production time because it cannot be reconstructed afterward.

Batch level granularity turns the passport from a data entry exercise into a process change at the point of manufacture, and processes take longer to change than spreadsheets. If your category's act requires batch level identification for producer, facility or substance data, then the systems that have to change are your suppliers', not yours.

Why you cannot fill it in later

Every field in the composition and supply chain groups has the same property: it describes something that happened at a specific moment, and the evidence for it exists only if somebody captured it then.

A mill can tell you today what fibre it is using today. It cannot reliably tell you in 2029 what went into a specific batch in 2027 unless it recorded it at the time. The passport does not just require data. It requires that the data was collected when the product was made, which means the collection process has to be running before the obligation starts.

What to do with this

Take one product line and try to fill every group with evidence rather than assertions. The exercise takes a week and it produces the only estimate of your real readiness that is worth anything, because it surfaces which suppliers respond, which have the data, and which have never been asked.

Then look at the gaps and note which of them are sourcing decisions rather than data decisions. Those are the ones with the longest lead time, and they are the reason the work starts now.

The step-by-step version of this exercise is in the readiness checklist.

Sources

• Regulation (EU) 2024/1781 (ESPR): the content of a passport is set by the delegated act for each
• product group.
• ESPR Working Plan 2025-2030, COM(2025) 187 final: textiles and apparel delegated act
• indicatively Q3-Q4 2027.