Opinion: Traceability May Not Be Required, But It’s Getting Hard to Work Without

Traceability does not sit in EU law as a formal requirement for textile companies. So why should you care? If you look at what regulations are asking companies to do, the direction becomes quite clear. Businesses need to provide reliable product information. They need to show they really know their supply chains. And they need to back this up with evidence when asked.

That creates a practical challenge: How do you generate and defend that level of information without being able to trace where products and materials come from? I’ve been following these developments closely. When you look at different regulations, you start to see the same themes come up.

ESPR and the Digital Product Passport

The Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP) give a strong indication of where things are heading.

The DPP will introduce structured product information. For textiles, we expect requirements around physical durability, recycled content, substances of concern, and environmental footprint. The details are still being defined, with delegated acts expected around 2027 and enforcement likely following about 18 months later.

One important distinction often gets overlooked. The DPP will show selected information to the public. But authorities will look at the documentation that supports these claims. This is where things become more demanding.

Recycled content is a good example. Claims are difficult to support without some level of upstream visibility or at least solid chain-of-custody documentation. Certification schemes may help, but there is still limited clarity on how far they will go.

Substances of concern create a similar situation. Product-level statements depend on inputs from suppliers and components. That pulls data requirements that may go further up the supply chain.

Environmental footprint can be calculated using secondary data. Still, the more specific and defensible the result needs to be, the more useful and rewarding primary data becomes.

Recyclability sits somewhere in between. It depends on design, but also on materials, blends, trims, and coatings that are not always visible without deeper insight into sourcing.

Durability is different. That remains largely a testing and product design topic, where traceability plays a smaller role.

Across most of these areas, the same pattern shows up. The closer companies get to product-specific claims, the more they rely on upstream information. Traceability supports that process. It connects product data with where things actually come from.

The Forced Labour Regulation Brings Another Layer of Pressure.

The EU Forced Labour Regulation focuses on products. Authorities assess whether a specific product is linked to forced labour. If they open an investigation, brands need to respond fast with detailed evidence tied to that product.

This can include supplier mapping, production sites, and documents that link raw materials to finished goods. These requests are time-bound. In many cases, companies will likely have between 30 and 60 days to respond. The stakes are high. If the evidence does not hold up, products can be removed from the EU market. In that situation, the ability to trace products back through the supply chain becomes critical.

Without it, companies need to piece information together manually. That takes time and introduces uncertainty. It also makes it harder to respond consistently across different products and collections. With it, the same information can be accessed at product level, linked to sourcing decisions, and supported by documentation.

What This Means Day to Day

Without traceability, product data often sits separately from sourcing information. Evidence has to be rebuilt when needed. Responses to authorities can be slow, especially when multiple suppliers or regions are involved. That means that risk increases, especially for materials like cotton.

With traceability in place, product data links back to upstream inputs and evidence can be retrieved at product level. Processes become more consistent across collections. Existing certifications and supplier relationships become easier to use because they connect to actual products.

Where This Leaves Brands

To be clear: Traceability does not stand as its own legal obligation in EU textile regulation today. Under ESPR, the focus stays on product information. Under the Forced Labour Regulation, the focus is on providing evidence when a product is investigated.

But both rely on a clear link between the product and its supply chain. Without that link, meeting these expectations in a consistent and timely way becomes difficult, especially for companies working across multiple sourcing regions and complex product setups.

Traceability serves a practical role here. It helps keep product data consistent and supports due diligence. It allows fashion brands and suppliers to respond when regulators ask questions.