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The 22 fields we track for a textile passport

Twenty two attributes, and not one of them is a statutory textile passport requirement today, because the delegated act that would set those has not been adopted. The set is still worth having. The evidence problems underneath it are real now, and most of them will not change when the act lands.

Sources as at
26 August 2026
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What is governed, what we track and what is still anticipation

Three different things get called textile passport requirements and only the first of them is law.

Already governed, and applying now

Some of what a passport would carry is already regulated, independently of any passport. Fibre composition has a closed legal vocabulary of fibre names and a duty to make composition available before purchase. Articles containing a substance on the REACH Candidate List above the threshold carry a notification duty. Producer registration for textiles is live in some markets already. None of that waits on a delegated act and none of it is new.

What ActivateDigital tracks

Twenty two fields, chosen from the framework, from the instruments that already apply to textiles and from what a passport has to hold to be useful to somebody who is not the brand. That is the table below. It is what we carry, not what anyone is obliged to carry.

What is still anticipation

The Ecodesign for Sustainable Products Regulation creates the passport, the unique product identifier and the data carrier. It is in force and it builds the machinery. It does not say what a pair of trousers has to carry, and the delegated act that would has not been adopted. The Commission's working plan names textiles as a first priority with an indicative adoption year, which is an indication in a work plan rather than a schedule. The year itself is on the status page with everything that qualifies it.

So when the act arrives, some of the twenty two will be wrong. Saying so costs nothing and it changes how the table should be read.

Why the set is useful before then

Because the hard part was never the list. Composition, weight and origin are difficult to evidence today, for reasons that have nothing to do with which act names them. A brand that fixes those has done work that survives the delegated act whatever it says. A brand that waits for the list will start from nothing on the day it lands.

For what is settled, what is adopted and what is merely signalled, the status page is the only page here that asserts a date.

Two axes rather than one

Every field below carries a difficulty and a size sensitivity, and they are deliberately separate.

Difficulty is about the field. Water impact is hard because the input nobody holds is the geography where the fibre was grown, and a company with a billion euros of revenue is in exactly the same position as a company with two hundred thousand. Size sensitivity is the part of the difficulty that is caused by being small, and there are four mechanisms behind it: supplier leverage, a fixed cost spread over fewer units, not having a product information system, and not employing a specialist.

Collapsing those two into one severity score turns a problem the whole industry has into one that looks like it belongs to small companies. Three of the five hardest fields here carry no size sensitivity at all.

What the size sensitivity column is and is not

It is our inference from implementation work and from published research, not a measurement of small companies. Nothing here says whether any particular business can comply. It classifies fields.

Two cells are held back. Each of them would read as a commercial claim about a specific regulatory instrument, so they wait for review rather than publishing on the strength of one worked example.

The 22 fields

The resolution column is our own measurement on a 34 variant test catalogue. It is a test catalogue and not a customer, and it says what the engine reached without asking the merchant anything.

The attribute set, with intrinsic difficulty and size sensitivity held apart. Resolution figures are from a 34 variant test catalogue.
Field What it asks for Class Difficulty Size sensitivity Resolved
1. Product identifierA unique identifier, in practice a GS1 GTIN, carried into a Digital Link address and permanent once it is printed.Catalogue hygieneLowMedium24
2. Model, style and variantThe product as distinct from the variant, which decides how many passports exist.Catalogue hygieneLowLow34
3. Economic operator identityWho is placing the product on the market, corroborated where a public register allows it.Registration and adminLowMedium34
4. Operator contact and addressA contact route for the responsible operator.Registration and adminNoneLow34
5. Commodity codeA Combined Nomenclature classification, which is republished every year.Catalogue hygieneMediumMedium20
6. Fibre compositionPercentages of fibre mass against the legal vocabulary of fibre names, never forced to 100.Supplier dependentMediumMedium31
7. Recycled contentA mass fraction of recycled input over the fibre mass of the whole product.Supplier dependentHighHigh4
8. Country of originA declared non-preferential origin, recorded rather than adjudicated.Supplier dependentMediumMedium20
9. Product weightNet product mass, being the mass of the goods without any packaging.Catalogue hygieneLowLow31
10. Conformity declarationsDeclarations of conformity where an instrument requires one, which for ordinary apparel is usually nothing.Registration and adminMediumLow0
11. Carbon footprintA modelled figure from a governed calculator, recorded and republished unaltered.Method and modelMediumMedium18
12. Water impactA scarcity weighted figure under ISO 14046. Not litres.Method and modelBlockedNone18
13. Durability coefficientA dimensionless multiplier from a French regulatory formula over business inputs. It contains no test result.Method and modelMediumHeld34
14. Microfibre sheddingA semi quantitative supplement under the French official methodology. Not milligrams per wash.Method and modelLowNone24
15. Production facilitiesA facility identifier the merchant names. Never one we searched for.Supplier dependentBlockedHigh0
16. Substances of concernA disclosure about substances of concern above 0.1 per cent by weight.Supplier dependentBlockedHigh0
17. Recyclability routeA route or a score, on a method that has no authority behind it yet.No governed basisBlockedNone17
18. SCIP referenceA reference to a SCIP notification, where the duty arises.No governed basisBlockedLow0
19. Repair routeWhere and how the product can be repaired.No governed basisUnknownHeld0
20. Care instructionsCare across five dimensions, read from the merchant's own words. No symbol is emitted.Supplier dependentMediumLow20
21. Safety certificatesA certificate number a scheme's own register recognises. Having none is lawful.Supplier dependentMediumHigh0
22. EPR registrationA producer registration per market where textile extended producer responsibility applies.Registration and adminHighHigh0

Two labels need a word. Blocked in the difficulty column means a structural block: the obstacle is somebody else's infrastructure rather than anything the brand can work harder at. Held in the size sensitivity column means the value is not published while it waits for review, and there are two of those.

Two of these rows have their own page so far. Fibre composition and the SCIP reference are linked above. The rest are rows rather than links, because a link to a page nobody has written is a promise, and the estate would rather be short than misleading.

What the five classes actually mean

The class says what kind of problem a field is, which is more useful than how hard it is, because it says who can do something about it.

Catalogue hygiene

The value is already in the business, or it is one weighing session away. The failure mode is a field holding the wrong kind of thing, and the most common instance is a merchant's internal stock code written into the barcode field. This is the cheapest useful work and it is the work that unlocks nothing else until it is done, because several computed fields need weight and composition before they can produce anything at all.

Supplier dependent

The fact exists and it belongs to a mill, a factory, an agent or a certification scheme. This is the largest class, seven of the twenty two, and it holds the three heaviest evidence burdens. Software can ask better, record the silence and generate a statutory request. It cannot create the fact, and this is the class where a vendor is most tempted to imply otherwise.

Method and model

Somebody else's method computes it. The calculators are public and free, so producing a number is cheaper than it looks. The difficulty is knowing what the number is not, and a modelled figure read as a measured one is the real risk here.

Registration and admin

A duty discharged with an authority rather than a data problem. Recurring rather than one-off. Software can tell you which registers to look at and record the answer. It cannot register you. This is the most under-discussed real cost in the set, because it is a duty that already exists rather than one that is coming.

No governed basis

There is nothing to comply with yet, or nothing to look up. Effort spent here buys nothing, and the correct behaviour is to wait and record why. Three fields sit here and each one is waiting on somebody other than the brand.

How much work this actually is

Twenty two attributes across 34 variants is 748 cells. On that test catalogue 363 of them resolve without asking the merchant anything, and 24 distinct questions cover the rest.

That ratio, rather than a percentage, is the honest shape of the work. One answer often covers many rows: which markets do you sell into is asked once and lands across a catalogue. Four questions are cold asks that nothing could have answered from data, being the factory, the fabric supplier, the repair address and the markets.

Seven of the twenty two attributes resolve for nobody at all on that catalogue, and each of the seven is waiting on evidence that does not publicly exist rather than on a better engine. Conformity declarations, production facilities, substances of concern, the SCIP reference, the repair route, safety certificates and EPR registration.

A note on the denominator, because it matters. Thirty four variants is not thirty four products. A composition is a property of a product rather than of a size, so five sizes of one shirt are one composition question and five passports.

How many passports a range actually needs

The most consequential unanswered question in this set is not which fields are required. It is what a passport is attached to.

If it attaches to a model, one style in a full size and colour run is one set of product facts and one passport. If it attaches to an item, the same style is hundreds. Nobody outside the delegated act can settle that, and it moves the cost of a passport programme by more than any field on the table.

The positions on record differ. EURATEX asked in March 2026 for information at model level unless operators voluntarily provide more granular data. The Small Business Standards study argues for flexible granularity across model, variation, batch and item, from a survey of 18 respondents. The delegated act has decided neither, and until it does, any figure for how many passports a range needs is a working assumption rather than an answer.

How to read a row that resolves for nobody

A zero in the resolution column is not a failure to look. Each of those fields has a recorded reason, and the reasons are different in kind.

For the SCIP reference the reason is structural. The database is positive only, holds no product identifier and legally suppresses the identity of the submitter, so a reference can be recorded and cannot be discovered. For production facilities the reason is access, not structure: the records exist and confirming one anonymously and free of charge is not possible. For substances of concern the reason is that the evidence does not exist until a supplier writes it down, and there is one statutory route to making it exist.

Those three sentences are three different absences, and the evidence page sets out the vocabulary that keeps them apart. It is worth reading before the table above, if the table above is going to be used to plan anything.

What a Shopify catalogue already answers Which of these rows come out of the store, which come from the merchant once and which need somebody upstream. The whole table, on one product A worked passport with the same twenty two rows, including the ones that stayed empty and why.

Sources