If you sell textile products in multiple EU countries, the core of the digital product passport is the same everywhere: the same data categories, the same link with the QR code, and the same structure according to the European regulation on ecodesign (ESPR). What can differ is how a country handles this in practice: which language is mandatory on the passport for that market, which national point supervises it, and how that supervision is implemented in practice. This difference is therefore not in the content of the passport, but in its implementation per Member State.
For textiles this subject is extra relevant, because textile products often reach the market via multiple channels and multiple countries at the same time: an importer in the Netherlands, a wholesaler in Germany, a retail chain in France. Each of those countries can place its own emphasis within the same European basic rules. This is no exception to the regulation, but a normal consequence of how EU regulations are implemented by Member States: the rules themselves are common, supervision and national embedding are not automatically so.
What remains the same throughout the entire EU
The regulation itself applies directly in all Member States, without a country being allowed to change the content. This means that the data that must appear in a textile product passport, and the way the QR code refers to it, are in principle the same everywhere. A passport that meets the requirements in the Netherlands therefore also meets the requirements in Spain or Poland in terms of content. That is precisely the intention of a digital product passport: one dataset that is readable and verifiable everywhere, instead of a different document per country.
The exact data requirements for textiles are not yet fully established at the time of writing; these are being further developed per product category in supplementary regulations. For the current status per product category, the official text on EUR-Lex is the reference point, and this reference belongs with each topic on this platform, even if the details are still being developed.
Where countries can differ
Three points come up most frequently in practice. First, language: a Member State can require that the information the consumer sees via the QR code is available in the language or languages of that country. This does not affect the underlying data, but does affect the way you present it to the end user. Second, the contact point: each country designates its own market surveillance authority, and this authority determines how checks are conducted and which desk you contact with questions. Third, enforcement practice: how strictly and with what priority a supervisory authority checks differs per country and over time, and we as a platform cannot make a prediction about this.
For companies that are unsure whether and how these differences affect their own situation, it is useful to first look at what is already structurally in place and what still needs to be filled in. This overview, worked out per situation, can be found in the knowledge base with explanation per subject. The question of how supervision in the Netherlands relates to other Member States can also be found there.
What this means for an importer selling in multiple countries
If your textile products are placed on the market in different EU countries, the practical question is not so much whether the passport must be different, but whether the presentation and administrative handling per country are sufficiently aligned. Consider the question of who qualifies as a market participant in each country, which local contact point receives any questions from a competent authority, and whether the language version behind the QR code matches the country of sale. These are not legal complications that require a lawyer, but practical matters that you should best arrange early in the process, together with your distributors or subsidiaries in those countries.
Whether your specific export structure fully complies with what the regulation requires cannot be answered in general terms; it depends on your role in the supply chain in each individual country. For that individual assessment, we refer you to a lawyer or to the competent authority in the country concerned.
How to approach this in practice
A practical first step is to determine which countries are relevant for your textile products, and per country to inventory whether there is a language or registration element in addition to the European basic requirements. If you want to quickly see where your situation currently stands, the product scan with a few short questions provides an initial indication, without you having to immediately work out all the details. It is also useful to know how the data for such a passport are compiled and hosted; you can read more about this in the explanation of how the data are created.
If you have a specific question about your own export countries, frequently asked questions about this are bundled at questions and answers about the product passport. If you want to explore more broadly which other topics are relevant to your company, feel free to start with the free quick-scan; that provides a short answer and an indication per topic, without requiring an account.