When the Commission adopted its 2025 to 2030 working plan for the Ecodesign for Sustainable Products Regulation in April 2025, it named the product groups to be dealt with first. Textiles came top, apparel specifically. Roughly 78 billion euros of EU market, and the group the Commission judged most in need of the treatment.
I have written separately about why the date everyone asks for is the wrong thing to focus on, and I will not repeat that here. What interests me is the other question, the one nobody in the trade seems keen to answer. Why textiles first, and what does the answer say about us?
We were chosen because we know the least
It is not flattering. Apparel is high volume, low durability and almost entirely opaque. Ask a mainstream brand which farm the cotton in a given shirt came from and in most cases nobody in the building knows. The information stops at the first-tier supplier. Everything behind that is a fog the industry has learned to describe with adjectives instead of records. That is precisely the condition a product passport exists to end, which is why we are at the front of the queue rather than the back.
What a passport will ask for is what a materials person asks anyway
The exact data set for textiles will be set by a delegated act that has not been written, so anyone quoting you a field list today is guessing. But the regulation names the parameters it is able to require, and they are not surprising: fibre composition, presence of substances of concern, durability, reparability, recycled content, and the countries where the main processing steps took place.
Read that list as a designer rather than as a compliance officer and it is simply a specification sheet. Composition is what I need in order to predict pilling. Substances of concern is what I need before putting a garment against a child's skin. Durability is the difference between a two-year blazer and a four-year one. Where the processing steps happened is how you find out whether a dyehouse holds a wastewater permit. None of this is regulatory overhead invented in Brussels. It is information the trade quietly stopped collecting once production moved far enough away that nobody had to look at it.
It is a supply chain project, not a software one
The mistake I keep watching people make is treating this as an IT purchase. There are vendors selling passport platforms, and the platform is the easy part. A QR code that resolves to a page is a weekend of work. Filling that page truthfully takes seasons, because it requires a spinner willing to tell you which bale lot went into which yarn, a dyehouse willing to share its recipe class and discharge data, and a factory willing to tie a production run to a specific batch of cloth. Every one of those is a relationship, and several of them are conversations suppliers have spent twenty years successfully avoiding.
Which is why the readiness gap will not close on a deadline. A school that switches supplier in 2028 does not thereby acquire a supply chain that knows its own history. It acquires a supplier who started the work in 2026, or one who did not.
What we did, and what I will not claim
We built ours for a domestic reason rather than a regulatory one, and it starts at the fibre. Each garment carries a permanent identity tied to the lot it was made in, and the lot carries the fibre origin, the certificates with their expiry dates, and the test reports. Where we cannot verify something we say so, rather than leaving a silence that reads as reassurance.
None of that makes us compliant with a rule that does not exist yet. I want to be careful about saying so, because the vendors will not be. What it means is narrower and I think more useful. When the textile rules do arrive, the work will be an export rather than an excavation.