FASHION'S TRUST PROBLEM IS HIDDEN IN THE LABEL.
MONDAY BRIEFING | PRODUCT INTEGRITY | SUPPLY-CHAIN ACCOUNTABILITY | TRACEABILITY
Fashion invests heavily in building brands, developing products and communicating their value to consumers. But behind every garment is a fundamental question: can a fashion business prove that what it tells customers about a product is accurate?
A Financial Times report published on 15 October brought renewed attention to European Commission findings released in June 2026. Of the 132 clothing items tested across eight EU member states, 49 had inaccurate fibre-composition labels, approximately 37% of the sample.
These findings do not mean that 37% of all clothing sold in Europe is incorrectly labelled. The testing involved a specific sample, not a representative assessment of the entire fashion industry. Nevertheless, the results raise important questions about product integrity, supply-chain accountability and the reliability of information provided to consumers.
For an industry increasingly focused on transparency, traceability and sustainability, this is more than a technical compliance issue. It is a commercial challenge that reaches from product development and sourcing to brand reputation and customer confidence.
Because transparency isn't simply about what a brand says. It's about what that brand can prove.
1. THE LABEL IS A PROMISE
When a customer purchases a garment described as cotton, wool or a particular fibre blend, that information forms part of their understanding of the product. Material composition can influence expectations around comfort, care, performance, durability and value. Customers reasonably expect the information on a garment's label to reflect what they are buying.
The European Commission's testing identified discrepancies that included incorrect fibre percentages and instances where the actual composition differed from the declared materials. The findings are significant, but their limitations matter. A sample of 132 items cannot establish the prevalence of inaccurate labels across the wider market, and the results should not be interpreted as evidence that every brand or supplier faces the same problem.
What they do demonstrate is that discrepancies can occur, and that accurate product information cannot simply be taken for granted. For fashion businesses, this matters because brand trust is built on more than marketing, design and customer experience. It also depends on the integrity of the product itself. A business can invest substantially in creating a compelling brand proposition, but inaccurate product information risks undermining the confidence that investment is intended to build.
The commercial question is not whether every customer examines every label. It is whether a business has sufficient confidence in the information it provides.
Product integrity is part of brand integrity.
2. THE RISK STARTS LONG BEFORE THE GARMENT REACHES THE SHOP FLOOR
A clothing label is where the customer sees the information. But the accuracy of that information depends on processes that begin much earlier.
Fashion supply chains can involve fibre producers, fabric mills, dyeing and finishing facilities, garment manufacturers, sourcing partners and retailers. Materials and product information may pass through several organisations before the finished garment reaches the customer.
That creates a practical challenge: how does a fashion business establish that the information supplied to it accurately reflects the product being sold? Supplier declarations and technical documentation are important, but businesses also need appropriate controls to assess the reliability of that information. Depending on the product and associated risks, those controls might include supplier due diligence, documented material specifications, quality assurance, contractual requirements and proportionate testing.
This does not mean every fashion brand must independently laboratory-test every garment. Verification should be appropriate to the circumstances and the applicable legal obligations. But relying on information without understanding how it has been checked can create commercial and regulatory exposure.
The European Commission also identified wider consequences of inaccurate fibre-composition information, including risks to consumers, fair competition and textile recycling. For consumers, the issue is straightforward: they need reliable information to make informed purchasing decisions. For businesses, inaccurate declarations can create unfair competitive conditions, particularly where companies invest in meeting material specifications and substantiating their claims. For textile recycling, reliable fibre information can support sorting and processing decisions, although recycling systems may also use their own identification technologies.
Responsibility under the law depends on a business's role in the supply chain and the legislation that applies. Manufacturers, importers, distributors and retailers do not necessarily have identical obligations. Commercially, however, the consequences of inaccurate information can reach the brand whose name appears on the garment. Customers see the finished product. They do not necessarily know which organisation supplied the fabric, prepared the specification or produced the label. That is why product verification cannot be treated solely as an administrative exercise.
The real question is whether fashion businesses have the visibility, supplier relationships and controls needed to stand behind what they sell.
3. DIGITAL PRODUCT PASSPORTS ARE RAISING THE IMPORTANCE OF RELIABLE DATA
The European Union is developing Digital Product Passport requirements under its Ecodesign for Sustainable Products Regulation, with textiles identified among the priority product categories. The objective is to make specified product information more accessible in digital form, supporting transparency, sustainability and circularity.
For fashion businesses, this represents a potentially significant development in how product information is recorded, managed and shared. However, it is important to distinguish between existing legislation and future requirements. EU textile products are already subject to fibre-composition labelling rules under Regulation (EU) No 1007/2011. Digital Product Passports form part of a separate regulatory framework. The detailed textile-specific requirements are still being developed.
The European Commission's indicative timetable currently anticipates adoption of textile-specific measures in the fourth quarter of 2027. This is not a deadline by which every garment must carry a Digital Product Passport. The final obligations and implementation dates will depend on the measures adopted.
Fashion businesses should therefore avoid treating proposed requirements as though they are already in force. Nevertheless, the direction of travel makes product-data quality an increasingly important consideration. Businesses need to understand where their material information originates, how it is verified, how it is stored and whether it remains consistent as products move through development, sourcing, manufacturing and distribution.
Technology will undoubtedly play a role. But introducing a new digital system does not automatically make the underlying information accurate.
A Digital Product Passport can only be as reliable as the information behind it.
The challenge is not simply collecting more data. It is ensuring that the information businesses already hold can be trusted.
4. PRODUCT DATA IS BECOMING A STRATEGIC ASSET
For many fashion businesses, product information sits across several departments. Design and development teams manage specifications. Sourcing teams work with suppliers. Compliance teams assess legal requirements. Ecommerce teams prepare product descriptions. Sustainability teams gather information to support environmental reporting. Each function has its own responsibilities, but the information needs to remain consistent.
Where data is incomplete, fragmented or difficult to verify, businesses can face additional costs, delays and uncertainty. Where information is accurate and accessible, it can support better decisions across product development, supplier management, quality assurance and regulatory compliance.
The opportunity is to move beyond treating product data as a collection of documents and begin managing it as an important commercial resource. That does not require every business to invest immediately in an entirely new technology platform. It starts with understanding the information already available, identifying where gaps exist and establishing appropriate processes to improve its reliability.
For senior fashion leaders, the questions are practical. Can the business identify the source of its material-composition information? Does it understand how suppliers substantiate their declarations? Are discrepancies identified and addressed? Can different teams access consistent information about the same product? These questions matter today, regardless of how future Digital Product Passport requirements develop. They also provide a useful starting point for businesses considering how to prepare for greater expectations around traceability and product transparency.
The competitive opportunity is not simply to hold more information. It is to make better decisions using information the business can trust.
5. THE REAL OPPORTUNITY: MAKE PRODUCT INFORMATION A COMMERCIAL ASSET
For fashion businesses, the opportunity goes beyond meeting regulatory requirements or preparing for Digital Product Passports. Reliable product information can become an important commercial asset, supporting better decisions across the business.
Consider the role that material information plays in product development, sourcing, pricing, quality assurance and customer communication. Each function relies on accurate information, yet that information is often managed across different teams, suppliers and systems.
When product data is incomplete or inconsistent, the consequences can include additional verification costs, delays, incorrect product descriptions and uncertainty around supplier performance.
But when businesses have reliable, accessible information, they are better equipped to identify problems earlier, manage supplier relationships and make informed commercial decisions.
There is also a competitive dimension. Brands that can substantiate their material specifications and product claims may be better positioned to demonstrate quality, support their pricing propositions and build customer confidence. That does not mean customers will automatically pay more for a product simply because its information is verified. The commercial value depends on how effectively that information supports the product proposition and the wider customer experience.
The opportunity is also operational. Better visibility of product information can help businesses identify inconsistencies before they become costly problems, while improving coordination between design, sourcing, compliance and retail teams.
For senior leaders, this raises an important strategic question: is product information being managed simply to satisfy operational requirements, or is the business using it to improve commercial performance?
The answer will vary between organisations. But as scrutiny of product claims increases, the ability to access and substantiate reliable information may become an increasingly valuable capability.
The commercial advantage isn't simply having more product data. It's being able to trust that information and use it to make better decisions.
THE TFTT INSIDER VIEW: CAN FASHION PROVE WHAT IT SELLS?
The European Commission's findings should not be interpreted as evidence of a universal failure across fashion. But they highlight an issue that every business should be prepared to examine: the potential gap between the information recorded about a product and the materials actually used to make it.
The renewed attention given to these findings last week makes this a timely moment to consider how the industry manages that risk.
For fashion leaders, the implications extend well beyond labelling compliance. This is about consumer confidence, supplier accountability, product quality, commercial decision-making and the ability to substantiate claims. And with Digital Product Passport requirements being developed in Europe, the importance of reliable product information is likely to increase. The opportunity is not simply to respond to regulation. It is to use this moment to strengthen how businesses manage their products, suppliers and information.
That requires collaboration across sourcing, product development, operations, technology, compliance and senior leadership. Three questions should sit at the centre of that discussion:
Do we know what's in the products we're selling?
Can we demonstrate that the information is accurate?
Are we using that information to make better commercial decisions?
These questions will not have identical answers across every business, product category or supply chain. But they provide a practical starting point.
Fashion has become exceptionally sophisticated at telling stories about its products. Increasingly, it must also be able to substantiate those stories.
Because the question isn't whether fashion can collect more product data. It's whether businesses can trust the data they already have, and turn that understanding into commercial advantage.
TFTT | Inside Fashion. Not Observing It.
