Why the split exists
The split exists because a fully public passport was never going to be agreed: the data recyclers need to process an item safely also maps a brand's supplier relationships, test regimes and cost structure. ESPR therefore separates a public tier anyone can scan from a restricted tier reserved for authorities and credentialed operators.
The split is not a technical afterthought. It is the condition under which producers agreed to publish anything at all, and most of the implementation effort in a real passport system goes into enforcing it correctly: the wrong field in the wrong tier is either a competitive leak or a compliance failure. The restricted side answers to parties with a defined role, market surveillance authorities, customs, and operators who process the item at end of life.
The public tier
The public tier answers the questions a person holding the garment is entitled to ask. What is this made of. How do I care for it. Where was it made. What share of it is recycled. Does it contain substances that matter for reuse or recycling. The delegated act for textiles, expected in 2027, will fix the exact list, but the working data models in the CIRPASS-2 pilot all place composition, care, origin, recycled content and substances of concern on the open side of the line.
Public means public for the life of the item. A sorter who scans a carrier eight years after sale reads the same tier as the consumer did on day one, which is precisely what makes the public tier the workhorse of circularity: it is the only part of the passport whose readers were never vetted, registered or credentialed.
The restricted tier
Behind the split sit the fields with an audience of institutions rather than individuals: the supplier chain behind the item, the test evidence behind its claims, treatment and repair history, and the compliance documentation that authorities check against. Who can access each field is a matter of role. Market surveillance authorities and customs read what they need to enforce the rules; operators involved in reuse, repair and recycling read what they need to process the item; the general public does not read any of it.
| Tier | Typical fields | Who can access them |
|---|---|---|
| Public | Composition, care, origin, recycled content, substances of concern relevant to handling. | Anyone who scans the carrier: consumers, resellers, sorters, collectors. |
| Restricted | Supplier chain, test and certification evidence, treatment history, compliance files. | Authorities, customs and credentialed operators with a role defined by the rules. |
How access rights are enforced
Access rights are enforced at resolution time: one carrier and one identifier resolve differently for different requesters. GS1 Digital Link turns the identifier on the item into a web address, an anonymous scan of it resolves to the public tier, and an authenticated request from a party with a recognised role resolves to the restricted fields behind it.
The access rights management layer, one of the areas CEN and CENELEC are standardising in JTC 24, is what makes the same QR code serve a consumer a care page and serve a customs officer a compliance record.
That design has a consequence worth stating plainly: the tiers live in the data model, not in the printing. There is one carrier, one identifier and one record, with access decided at resolution time. A system that prints one code for consumers and hides another for authorities has not implemented the passport, it has implemented two labels.
The sorter's position
Sorting and recycling operators sit awkwardly across the line. The rules recognise them as legitimate readers of restricted data for the items they process, and the data they most need day to day, composition, substances, recyclability, is mostly public anyway. The friction is elsewhere: the stock on their lines predates the passport regime, so for most items there is no tier to read because there is no record at all. The access question only has meaning once a record exists, and for legacy stock somebody at the sorting line has to originate it.
What the split means for evidence
The split means every public claim needs restricted evidence behind it. A field like recycled content is only as strong as the test reports and supplier documents that substantiate it, so a well built record keeps the claim on the open side linked to the provenance that carries it on the controlled side.
That link is the discipline the tier structure quietly imposes: a trace from each value back to the document it was read from, a confidence on every field, one source of truth serving both tiers. A record built that way never has to guess later which reader is asking.
Common questions
Who can access the restricted data in a textile DPP?
Parties with a role defined by the rules: market surveillance authorities, customs, and operators involved in reuse, repair and recycling, each seeing what their role justifies. The general public reads only the public tier. The delegated act for textiles will fix the precise mapping of fields to roles.
Is recycled content public or restricted?
The claim itself is expected in the public tier, readable by anyone who scans the item. The evidence that substantiates it, test reports, certificates and supplier documentation, sits in the restricted tier. The pairing is deliberate: the public reads the claim, authorities can audit its basis.
How are DPP access rights enforced technically?
Through resolution rather than printing: one carrier and one identifier resolve differently for different requesters. GS1 Digital Link provides the addressable identifier, and the access rights management standards being developed in JTC 24 govern which role sees which fields.