# The 22 fields we track for a textile passport

Source: https://activatedigital.ai/knowledge/fields
Last verified: 28 August 2026
Summary: Twenty two attributes, and not one of them is a statutory textile passport requirement today, because the [delegated act](https://activatedigital.ai/knowledge/regulation/what-a-delegated-act-decides) 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.

## In 60 seconds

Not one of the twenty two attributes on this page is a statutory textile passport requirement, because the delegated act that would set a textile field list has not been adopted. The twenty two are this business's own tracking set, and the heading says what we carry rather than what anyone is obliged to carry.

- Already governed now: the closed vocabulary of fibre names, the REACH Candidate List notification duty above the threshold and producer registration in some markets.
- Regulation (EU) 2024/1781 builds the passport, identifier and data carrier. The Commission's working plan gives textiles an indicative adoption year, not a schedule.
- Footwear sits outside the textile route but inside the Article 25(1) ban on destroying unsold goods, which has applied since **19 July 2026**.
- Article 25(1) does not apply to micro and small enterprises and applies to medium-sized enterprises from **19 July 2030**.
- Water impact, production facilities, substances of concern, recyclability route and SCIP reference are marked structurally blocked.
When the act arrives, some of the twenty two will be wrong. Saying so costs nothing and it changes how the tables below should be read.

## 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.

Twenty two is this business's own tracking set and not a statutory count, since nothing in force names a textile passport field list. If an act lands with a different list, the heading changes with it.

### What is still anticipation

The [Ecodesign for Sustainable Products Regulation](https://activatedigital.ai/knowledge/digital-product-passport) creates the passport, the [unique product identifier](https://activatedigital.ai/knowledge/fields/the-three-identifiers) and the [data carrier](https://activatedigital.ai/knowledge/passport/choosing-a-carrier-that-still-works). 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.

### Where footwear sits

Footwear falls on both sides of this line, which is why a business selling trainers usually cannot get a straight answer. It is outside the textile scope of the working plan, which indicates a separate study for footwear rather than a product act, so footwear is not on the textile route to a passport act at all. It is inside the scope of the prohibition on destroying unsold goods, which is Article 25(1) of the ecodesign framework regulation itself rather than a delegated act. That prohibition has applied since [19 July 2026](https://activatedigital.ai/knowledge/data) and its scope, set out in Annex VII, names apparel, clothing accessories and footwear. The delegated act that sits alongside it, Commission Delegated Regulation (EU) 2026/296, sets out derogations from the prohibition rather than the prohibition itself. Article 25(1) does not apply to micro and small enterprises and applies to medium-sized enterprises from 19 July 2030. Those size rules belong to Article 25. They are not a general SME exemption from DPP or other ESPR requirements.

The consequence depends on the size of the business, and for a large one it is the opposite of what most trainers sellers expect. Article 25(1) doesn't reach medium-sized enterprises until 2030, six years after the framework entered into force, and a large seller is reached now. So a large trainers business is already subject to a duty under this framework while sitting outside the scope of the one it is usually asked about, and a small one is subject to neither.

### 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, including the indicative year for textiles and the study indicated for footwear, the [status page](https://activatedigital.ai/knowledge/status/textile-passport) is the only page here that asserts a date.

## Difficulty and size sensitivity

Two columns in the first table are about how hard an attribute is. What evidence it takes is a separate question.

### Difficulty and size sensitivity are separate, deliberately

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 evidence an attribute needs

Neither difficulty nor size sensitivity tells anybody what evidence an attribute needs. The section after the attribute table takes that question on its own.

Both tables carry the same twenty two rows, in the same order, with the same numbering.

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 attribute set, and how hard each one is

These are the 22 textile DPP readiness fields ActivateDigital tracks, so you do not have to start by filling in 22 boxes. It is a readiness list, not a final statutory textile DPP schema; difficulty and size sensitivity describe different evidence questions.

The 22-field textile readiness guide: what the record covers, not 22 tasks for the merchant.

| Field | What it asks for | Difficulty | Size sensitivity |
|---|---|---|---|
| 1. Product identifier | A unique identifier, in practice a [GS1 GTIN](https://activatedigital.ai/knowledge/fields/gs1-application-identifiers-dpp), carried into a [Digital Link address](https://activatedigital.ai/knowledge/fields/gs1-digital-link) and permanent once it is printed. | Low | Medium |
| 2. Model, style and variant | The product as distinct from the variant, which decides how many passports exist. | Low | Low |
| 3. Economic operator identity | Who is placing the product on the market, corroborated where a public register allows it. | Low | Medium |
| 4. Operator contact and address | A contact route for the responsible operator. | None | Low |
| 5. Commodity code | A Combined Nomenclature classification, which is republished every year. | Medium | Medium |
| 6. Fibre composition | Percentages of fibre mass against the legal vocabulary of fibre names, never forced to 100. | Medium | Medium |
| 7. Recycled content | A mass fraction of recycled input over the fibre mass of the whole product. | High | High |
| 8. Country of origin | A declared non-preferential origin, recorded rather than adjudicated. | Medium | Medium |
| 9. Product weight | Net product mass, being the mass of the goods without any packaging. | Low | Low |
| 10. Conformity declarations | Declarations of conformity where an instrument requires one, which for ordinary apparel is usually nothing. | Medium | Low |
| 11. Carbon footprint | A modelled figure from a governed calculator, recorded and republished unaltered. | Medium | Medium |
| 12. Water impact | A scarcity weighted figure under ISO 14046. Not litres. | Blocked | None |
| 13. Durability coefficient | A dimensionless multiplier from a French regulatory formula over business inputs. It contains no test result. | Medium | Held |
| 14. Microfibre shedding | A semi quantitative supplement under the French official methodology. Not milligrams per wash. | Low | None |
| 15. Production facilities | A facility identifier the merchant names. Never one we searched for. | Blocked | High |
| 16. Substances of concern | A disclosure about substances of concern above 0.1 per cent by weight. | Blocked | High |
| 17. Recyclability route | A route or a score, on a method that has no authority behind it yet. | Blocked | None |
| 18. SCIP reference | A reference to a SCIP notification, where the duty arises. | Blocked | Low |
| 19. Repair route | Where and how the product can be repaired. | Unknown | Held |
| 20. Care instructions | Care across five dimensions, read from the merchant's own words. No symbol is emitted. | Medium | Low |
| 21. Safety certificates | A certificate number a scheme's own register recognises. Having none is lawful. | Medium | High |
| 22. EPR registration | A producer registration per market where textile extended producer responsibility applies. | High | High |

**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.

Seventeen of the twenty two rows have no page of their own, and the table names them rather than linking nowhere, because a link to a page nobody has written is a promise. The five that do have a page are listed after the next table, once and nowhere else on this page.

## What evidence each attribute actually needs

Three attributes this list treats alike behave in three incompatible ways, and a difficulty score puts all three in roughly the same place. Origin is conferred at making up, so records covering the spinning and the weaving describe steps the rule says do not decide it. Composition is fixed at the mill and stays legible in the finished garment, which is checkable against the result of analysis by a method the regulation prescribes. Recycled content originates several steps upstream of anybody a brand has a contract with, no laboratory test at scale separates recycled from virgin origin in a finished product, and an unbroken record is the only mechanism that exists.

That last proposition reaches us through a summary of the preparatory study rather than from the study's own file, and the page says so rather than restating it as ours. The row is not softened for it. There is no shorter route to that attribute and nobody has one to sell.

The same twenty two attributes, with a status for each.

| Field | Status |
|---|---|
| 1. Product identifier | Anticipated |
| 2. Model, style and variant | Our model |
| 3. Economic operator identity | Study proposal |
| 4. Operator contact and address | Our model |
| 5. Commodity code | Binding today |
| 6. Fibre composition | Binding today |
| 7. Recycled content | Our model |
| 8. Country of origin | Binding today |
| 9. Product weight | Our model |
| 10. Conformity declarations | Our model |
| 11. Carbon footprint | Our model |
| 12. Water impact | Our model |
| 13. Durability coefficient | Our model |
| 14. Microfibre shedding | Our model |
| 15. Production facilities | Study proposal |
| 16. Substances of concern | Our model |
| 17. Recyclability route | Our model |
| 18. SCIP reference | Our model |
| 19. Repair route | Our model |
| 20. Care instructions | Our model |
| 21. Safety certificates | Our model |
| 22. EPR registration | Our model |

### What the four statuses mean

The status is about the attribute as a published field, not about whether anybody has a duty somewhere else. Several rows marked as ours sit on top of duties that are perfectly real, and the row's own words say so.

- Binding today **Three rows.** An instrument in force already requires the fact to be given for textiles, independently of any passport: composition, the commodity code and customs origin.
- Study proposal **Two rows.** Named among the identification concepts of the preparatory study informing the textile decision. That study is pre-decisional by design, we hold it at second hand and it is never cited here as law.
- Anticipated **One row.** The framework itself creates it and no act has set it for textiles. That row is the product identifier, because the framework creates the passport, the identifier and the carrier and then stops.
- Our model **Sixteen rows.** In the set because we track it. Nothing we have read makes it a textile field.
Sixteen out of twenty two carrying nothing but our own judgement is an uncomfortable ratio to publish and it is the accurate one. If most of the list is a working set rather than a legal one, the useful question about any row is what evidence it would take to defend it, which is a question the delegated act does not change.

Where each attribute's evidence has to come from is set out, attribute by attribute, on [how far back each attribute's evidence has to reach](https://activatedigital.ai/knowledge/guides/how-far-back).

## Who can act on each field

A more useful question than how hard a field is: who can do something about it. Some values are already in the business, often one weighing session away, and many belong to a mill, a factory or a certification scheme, where software can ask better but can't create the fact. A few, like the recyclability route, have nothing to comply with yet, so the right move is to wait and record why. Modelled figures come from public, free calculators, and the French durability coefficient moves when a business input such as a warranty term changes. Certificates expire and scopes are withdrawn while the goods stay the same.

## Twenty-two fields does not mean twenty-two questions

ActivateDigital builds the textile passport from the product data and evidence you already hold. The field list is not a blank form for you to research and complete.

It works from your existing record first, then asks for the private product facts, company details or supplier evidence still needed. In the current test flow, initial product-specific questions averaged about five per product, with company identity separate. Counts are before answers and follow-ups can arise.

See how to [turn existing product data into a textile passport](https://activatedigital.ai/knowledge/guides/the-data-you-already-have).

Shared facts can serve matching products or variants where their scope agrees. Genuine material differences stay separate. Supplier-held information may already be in your files or obtainable through a targeted request, even when it is not public.

ActivateDigital can [build the governed record these attributes describe](https://activatedigital.ai/textile-digital-product-passport-software) from the catalogue data and documents you already hold.

## 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 either 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](https://activatedigital.ai/knowledge/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](https://activatedigital.ai/knowledge/evidence) sets out the vocabulary that keeps them apart. Read it before using either table above to plan anything.

## Related

- [What Textile Product Data Can a Tech Pack Establish for DPP Readiness?](https://activatedigital.ai/knowledge/digital-product-passport/textiles/tech-pack-dpp-readiness) — source-specific tech-pack mapping
- [DPP Data Requirements: Mandatory, Conditional and Voluntary Information](https://activatedigital.ai/knowledge/passport/mandatory-conditional-voluntary-data) — The legal-status layer above a field model

## Keep exploring

The question this one usually raises next.

- [What to do nextEvidence & suppliersWhere to stop askingThe same triage worked through in prose, with the chain drawn, the point where visibility usually breaks and the one attribute where depth cannot be avoided.→](https://activatedigital.ai/knowledge/guides/how-far-back)
Also worth reading

- [CompareEvidence & suppliersHow we know, and what a blank meansWhy an absence found by us is written differently from an absence asserted, and how a source held at second hand is marked.→](https://activatedigital.ai/knowledge/evidence)
- [Related questionRules & scopeEvery date this estate holdsWhat is adopted, what is in application and what is merely indicated, including the textile year and the footwear boundary.→](https://activatedigital.ai/knowledge/status/textile-passport)
- [Evidence behind thisSmall businessWhich Product Facts Can a Small Business Verify Itself?Need to work out which fields you can actually establish yourself?→](https://activatedigital.ai/knowledge/evidence/small-business-product-fact-observability)