How EU Regulations Could Change Supplier Selection
Why data readiness, traceability and evidence may become part of sourcing competitiveness
Buyers used to choose suppliers on the basis of the following: quality, price, delivery time, capacity, certification, and compliance. These criteria will stay important when it comes to purchasing. But the regulation of products and supply chains in Europe is adding yet another criterion: the ability to produce reliable information concerning the product and the supply chain.
For brands operating in the EU market, their compliance with regulations is becoming more and more dependent on information not kept by themselves. The material composition of the products, suppliers, certificates, origin, and information backing up claims about the product usually start at the level of manufacturers and their suppliers. And the availability of the information may make or break the ability of the brand to meet its requirements.
And it might affect the process of choosing suppliers. A manufacturer who keeps the records in order and reacts quickly to all information requests makes things easier for the buyer. When all information is spread between spreadsheets, emails, and different departments, the most technically competent supplier can become hard to evaluate.
Product information is becoming more important
The ESPR creates an enabling framework to introduce sustainability and transparency requirements for goods offered on the EU market. Textile garments belong to the list of priority product categories within the 2025-2030 ESPR Working Plan.
The Digital Product Passport is one of the tools to be introduced within the ESPR framework. A digital passport will provide products with a digital footprint containing data according to product-specific regulations. Since the definitive requirements for textile products have not been adopted yet, it would be too early to provide a definitive list of required data fields for all types of garments. However, the trend is clear - more product information will need to be available in a structured format.
The EU Digital Product Passport Registry was launched in July 2026 together with the testing platform and guidelines for economic operators. This does not mean that a passport is required for each textile product at the moment. However, it means that the technical platform is growing while sector-specific requirements are being prepared.
It gives brands a practical motive to look into the way of gathering product information during the sourcing process. Suppliers that already know where their material, production, and evidence records are held will be better placed to adapt when the textile rules are finalised.
Forced labour rules increase the need for supply chain visibility
The EU Forced Labour Regulation will apply from 14 December 2027. It prohibits products made with forced labour from being placed on, made available on, or exported from the EU market, regardless of where the products were manufactured.
The regulation does not create a standard supplier questionnaire or a new reporting system for every company. Businesses are responsible for ensuring that products entering or leaving the EU market are free from forced labour, and they may be asked for relevant supply chain information during an investigation.
This makes traceability commercially relevant. A buyer may need to understand where key materials came from, which upstream businesses were involved, and what information supports the supplier's account. A factory with well-maintained supplier records can answer these questions more efficiently than one that has to reconstruct its supply chain after a request arrives.
The value of traceability is therefore practical. It helps a buyer assess risk, document decisions and respond when further information is needed.
Due diligence connects sourcing with risk information
CSDDD will affect the broader sourcing environment as well. With the amendments introduced by the EU for 2026, the scope of the regulation is limited to very large businesses. As of July 2029, it will cover EU companies with over 5,000 employees and worldwide net turnover of more than EUR 1.5 billion and non-EU companies that fall under the EU turnover threshold.
It will require in-scope companies to identify and manage adverse human rights and environmental impacts related to their operations, subsidiaries and chains of activity. It does not mean, however, that all European fashion brands fall under the jurisdiction of the Directive. Nevertheless, its effects might be experienced across supply chains, especially when large companies require trustworthy information about risks.
Amended requirements aim at reducing unnecessary pressure on small business partners. It means that requests for information should have to do with risk assessment but cannot be an endless stream of questionnaires. Accurate record-keeping from the suppliers' side can ensure a better approach to this matter.
The cost of poor information is easy to overlook
The quotation from the supplier does not include any cost of gathering missing information internally. This cost becomes evident at a much later stage when the brands have to identify suppliers, relate certificates to materials, and validate the claims or documents as product data.
This process may include sourcing, compliance, sustainability, product development, and data experts. Any delays in one department of the factory can delay the work of multiple people on the buyer's end. In addition, repeated queries also increase the burden on the supplier where the ownership of the information itself is ambiguous.
As regulatory requirements evolve, buyers may become aware of this unseen cost of doing business. The minimum unit cost looks unappealing where even the basic information of the product is regularly delayed, incomplete or unverifiable.
The quality of the information will, therefore, become an aspect of the supplier relationship. This will coexist with production performance and not replace it.
What brands may begin to assess
Brands do not have to put a new compliance program in place each time there is a new regulation. Many of the skills required for meeting the requirements can already be covered in existing sourcing and supplier development programs.
Important points to consider include:
- Material and product data available;
- Upstream suppliers visibility;
- Relation between certificates and the products or materials they are issued for;
- Product, material and supplier name uniformity;
- Ownership of the data in the factory;
- Reaction time to a request for evidence;
- Format of information provided.
Assessment of compliance readiness can start by looking at one particular product. Brands and suppliers will trace the information for that particular product, see how the pieces of data are stored, and discover any inconsistencies and problems along the way. That will provide more insight than a general question of whether the factory is "DPP ready."
Readiness begins with organisation
Manufacturers can assume that preparation involves an upfront investment in the new software. Technology might be of help, but it cannot address ambiguities of responsibilities and the unreliability of the source data.
The first thing to do is to analyze the flow of information through the plant. Information regarding product specifications can be stored in merchandising; supplier records - by sourcing; certificates - in compliance; and supporting documents - in production or quality. If these records use conflicting names or cannot be related to a particular product, implementation of an additional tool won't change anything.
To start working, the plant needs to analyze:
- the sources of material and supplier information;
- the departments that keep and update records;
- the linkage between certificates and products/materials;
- the dependencies of information on upstream suppliers;
- the processes of evidence verification and updating;
- the time to respond to a buyer's request.
All these actions lay the groundwork for further implementation of the digital solution. They also enhance the existing communication with the buyer.
Data readiness can strengthen the supplier relationship
Factories have been working on improving quality systems, lead time, production planning, and compliance for years. It is possible to manage product information with the same rigor as operations.
Accurate data saves effort on duplicate queries and helps in product development, validation, and reporting. Moreover, it allows commercial teams to speak confidently about requirements to the buyer. And the advantage is not just in the future Digital Product Passports but in everyday sourcing tasks.
This is even more relevant in the competitive apparel industry, where there could be many factories having comparable production capabilities. The factory that is easy to evaluate and easy to collaborate with has an advantage without altering the product.
Preparation can start before the textile rules are final
The specifics of certain areas that are under development under ESPR include the product-specific criteria for textiles. Neither brands nor suppliers should take early expectations as their final commitments.
They can prepare for future actions by enhancing existing information that they have. Brands can determine which records of products and suppliers are hard to access. Factories can link data from material sourcing to testing, certification, production, and commercial documents. Both parties can also determine ownership of information and methods for evidence exchange.
All these actions will be relevant no matter what technical form the textile Digital Product Passport will have in the end.
Supplier selection is broadening
EU regulation will not replace the established fundamentals of apparel sourcing. Suppliers will still be expected to deliver the right quality, price, capacity and lead time.
What is changing is the amount of reliable information needed around the product. As brands prepare for product requirements, forced labour controls and due diligence obligations, they may favour suppliers that can provide that information without lengthy manual searches.
For manufacturers, this creates a clear area for improvement. Strong records, defined responsibilities and credible evidence can reduce risk for the buyer and strengthen the commercial relationship. Data readiness is becoming part of what it means to be a dependable supplier.
Regulatory context in this article reflects the status of relevant EU rules and implementation plans as of August 2026. Product-specific ESPR requirements for textiles, including final Digital Product Passport data requirements, remain subject to future delegated acts.