What a listing has to carry, and what it does not

The short answer

A refused listing has two candidate causes. Either an item of the short set that product safety law fixes for a distance offer is missing, or the platform has applied a rule of its own. The first is knowable from the law and is identical on every channel. The second is knowable only from that platform's published policy, which is a commercial decision and not a legal duty.

Nothing read for this page supports the idea that a marketplace refuses a listing for want of passport data. The gates that are running today test something else entirely.

The pattern is worth carrying off this page. Marketplaces gate on who you are and on whether the product is safe. They do not gate on what the product is made of. The sustainability data the category talks about most is gated by nothing we read, which is the opposite of the impression the category gives.

What the listing rules actually fix

Product safety law fixes what has to be clearly and visibly indicated on an offer made at a distance. Four things. Who made the product, with a postal address and an electronic contact. Where the manufacturer is established outside the Union, the person inside it who answers for the product. Enough information to identify the product, which includes an image of it, its type and whatever identifier it already carries. Any warning or safety information that belongs with it.

The last of those four is where the widest misreading sits. An identifier here means one the product already has, of the kind a model number or a batch number supplies. It is not an instruction to mint a new one, and it says nothing about how the identifier is encoded or whether anything on the garment can be scanned.

The duty to make information available in electronic form is a separate provision and it is permissive. An operator may additionally provide the information digitally. Additionally is doing the work in that sentence: a digital version supplements the information the offer already carries and never replaces it.

The obligations here are written by class of actor. Traders offering a product hold the information and supply it. Providers of online marketplaces are obliged to design and organise their interface so that a trader can give that information and so that a buyer sees it. That distinction explains something sellers find baffling from inside an account: a platform builds a mandatory field because law obliges it to make the field exist, then enforces the field because an empty one leaves the platform exposed. The field is the platform's. The information behind it is yours.

What the listing rules do not require

This list is longer than the one above, and stating it is most of the value of this page. None of the following is part of the listing duty as we have understood the articles.

• No unique identifier per item. The duty reaches identification of the product, satisfied by identifiers the product already carries.
• No data carrier. Nothing has to be printed on the goods, and nothing has to be scannable.
• No machine-readable record. The information is shown to a person reading an offer.
• No composition, durability or repairability data. Those are governed by other instruments where they are governed at all, never by the listing rules.
• No recycled content and no supply chain disclosure. Sustainability data is gated by nothing in this instrument.
• No product passport. No product act has been adopted for textiles, so nothing in the passport chapter is a condition of listing a garment.

Sustainability data being gated nowhere is worth sitting with. The gates that exist today are about safety and identity. The data that everybody is being asked about is neither, and a seller who reads a delisting as a sustainability failure will spend a quarter fixing the wrong thing.

What platforms actually gate on, and how well we know it

The table below is split into two tiers because the evidence behind it is of two qualities, and the split is itself the lesson. In the first tier a platform's own policy carries a described mechanic and a described consequence. In the second, the material reached this estate through an integrator's documentation or through a sibling research stream. It was not re-verified and it rests on a single reading. An audit of the originating research caught it over-stating its own count. The corrected split is four in the first tier and two in the second.

No platform is named in the rows. The rows describe the mechanic, because a mechanic survives a policy edit and a platform name does not.

What a document demand looks like when it arrives

This section is lived experience rather than policy. It comes from seller community records, it is not written down in any instrument, and no platform publishes it as a rule. It is also the stage of this workflow where money visibly and repeatedly moves, which is why it belongs on the page rather than in a footnote.

The pattern is retroactive. A demand for evidence about a product arrives months or years after the offer went up, on goods that have been selling untroubled the whole time. Nothing changed about the product. What changed was the platform's own risk position, and the clock starts when the message lands.

• An exact model-number match. The document has to name the model number on the listing. A report covering the range, the fabric or the sister style is refused, and so is a report whose model number differs by a suffix.
• A standard report may not be enough. For some categories the ordinary laboratory report a supplier already holds is treated as insufficient, and a specific test is named instead.
• A suspended laboratory means a refused report. Where the issuing laboratory's accreditation has been suspended, its report is refused, whatever the report itself says and whenever it was issued.
• A stated service level. The review runs to a published turnaround, which is the seller's window and not a negotiation.

Two of those four cost money outright: a fresh test to the named method, and a fresh test because the first laboratory lost its accreditation after the fact. The other two cost time at the worst moment. The defence is dull and it works, which is to hold the document set filed by the model number printed on the product rather than by supplier or by season. What each of those documents actually establishes, as against what a platform will accept, is a separate question with its own page.

What a regulator measured, and what it did not publish

A market surveillance campaign on textile labelling recorded 49 of 132 garments as non compliant, on a sample drawn across several member states rather than across a market. That denominator is the point. A sample of 132 garments is a campaign rather than a census, and no rate for the sector can be built out of it.

The same campaign compared online offers against physical retail and recorded a difference between the two channels. This page describes that difference and does not quantify it, because the per-channel denominators are not in the reproduction that reached us, and a channel figure without its denominator is exactly the kind of number this estate refuses to republish. The campaign publication also does not state the tolerance thresholds it applied, so a reader cannot tell whether a garment missed by thirty points or by a fraction above a permitted difference, and the headline is therefore a count of recorded non compliance rather than a rate of wrongness. How the estate decides what an absence like that permits it to say is set out in how we know.

What survives is still useful to a seller. Label accuracy is measurably worse in the channel where nobody can touch the garment, which is the channel this page is about, and the attribute at issue is composition rather than anything a passport chapter governs.

The one passport provision that points this way

One provision in the ecodesign framework connects passports to this part of the world, and it runs the opposite way to the usual story. Where a passport is required, the economic operator placing the product on the market has to give dealers and providers of online marketplaces a digital copy of the data carrier or the unique product identifier, free of charge, on request.

Read that carefully. It is not a platform demanding passport data from a brand. It is a brand obliged to hand a copy of an identifier to a platform, once passports exist for the goods concerned. No product act has been adopted for textiles, so it does not bite on a clothing listing at present. What is in force, adopted or merely indicated is kept on the status tracker. A passport would not discharge a listing obligation either: the two instruments ask different things of different actors, and satisfying one leaves the other where it was.

Diagnosing a listing that is down

Work the short legal set first, because it is four items long, published and identical across platforms. Check the two that are easiest to leave half done: the electronic contact for the manufacturer, and the person inside the Union who answers for the product where the manufacturer sits outside it. Both tend to exist somewhere in a business without ever reaching the offer itself.

Beyond that, the work that pays is boring. The identity block and the product data assembled to clear a listing gate is largely the same data a passport would want, which is the honest connection between this page and the rest of the estate, and the reason the effort is not wasted if a product act eventually reaches textiles.

Sources

• General Product Safety Regulation (EU) 2023/988
  CELEX 32023R0988In forceReached through a secondary reproduction, primary text not read

  The product safety regulation, and the source for what a distance offer has to show. The official record was reached and the instrument identified there, but two independent programmes hit a truncation wall on every retrieval route, and the listing information articles were never read at the Official Journal. Their content reached this estate through a secondary reproduction and was checked for numbering against government guidance. This page therefore states the effect of those articles, quotes no wording from them and publishes no article number for them. It will carry the article numbers when a consolidated rendering has been read, and not before.

  View official source

• Marketplace and platform seller policy documentation
  Platform policy, not lawRelevant provisions reviewed

  Platform seller policy documentation, read at a mixed depth, which is why the table on this page is split into two tiers rather than presented as one list. Four platforms carry dated and mechanised gates with a described consequence. Two further platforms reached this estate through an integrator's documentation or through a sibling research stream and neither was re-verified, and those rows carry the weaker badge for that reason. An audit of the originating research caught it over-stating its own count, and the corrected split is what is published here. Nothing in this material supports any statement that a marketplace requires passport data. One large platform's own supplier manual says the opposite in the present tense, read across three versions and eighteen months, and the current version of that manual is unread.

• Ecodesign for Sustainable Products Regulation (EU) 2024/1781, consolidated text
  Arts. 2, 9, 10CELEX 02024R1781-20240628In forceRelevant provisions reviewed

  The ecodesign framework, here for the one passport provision that already points at dealers and marketplace providers. Articles 1 to 29 and the definitions were read at the consolidated text. Every route stopped inside Article 29, so the articles on distributors and dealers were not read and nothing here describes them.

  View official source

• Commission joint enforcement campaign on textile labelling, 2026
  Regulator publicationReached through a secondary reproduction, primary text not read

  A market surveillance campaign on textile labelling, here for one figure with its denominator and for two absences. The publication does not state the tolerance thresholds it applied, so its headline is not republished here as a rate of wrongness. Its channel comparison between online offers and physical retail is described on this page and not quantified, because the per-channel denominators are not in the reproduction that reached us. One sub figure in the same campaign rests on five garments and is not published by us in any form.