COMPLIANCE FAQs 

GCN is built to help brands and value chain actors collect, structure, and hold the data needed to prepare for upcoming and emerging regulations and reporting requirements alongside existing Standards.

GCN's platform structure supports the data points a business already needs or may be asked to provide for future Regulations, particularly in the EU. The data points exist in the GCN App as usable, attestable evidence to help brands and value chain actors develop best-practice methodology and meet emerging regulations and customer transparency expectations.

INTEROPERABILITY. GCN is built on the UNTP framework for global data interoperability, and the platform is designed to move quickly as circular economy regulations expand globally. GCN is also tracking the work of the newly established ISO/IEC JTC 5 — Digital Product Passport committee, which began international standardization work in 2026 to build a common, cross-sector DPP framework — expected in part to build on the same European DPP standards GCN's architecture already conforms to. As JTC 5's work matures, GCN intends to align with it directly.

GCN has mapped its textile DPP data model against applicable international textile standards (ISO), including ISO/TC 38 standards, with standards-linked evidence and conformity credentials captured within the GCN Data Framework. It also covers the first non-EU regulation — California's Responsible Textile Recovery Act (SB 707) — set out in its own section at the bottom of this page.

Below is a brief description of the Regulations and Standards the platform has been built to record data against.
To see full details on the specific regulatory frameworks, contact GCN to request the GCN Platform Compliance Report.

Digital Product Passport & Circular Performance

ESPR — Regulation (EU) 2024/1781

Ecodesign for Sustainable Products (ESPR) is the regulation that makes Digital Product Passports mandatory, with textiles named as a priority sector for the first sector-specific rules (expected around 2027). Under ESPR's data model, the European Commission's central DPP Registry doesn't hold your product data — it holds a unique identifier and a pointer to where that data actually lives. The real dataset is stored by the DPP Issuer or by an authorised DPP service provider acting on their behalf.

GCN acts as that hosting layer — a Data Service Provider hosting your Digital Product Passport data on EU-sovereign infrastructure (Frankfurt), structured against what ESPR and the regulations feeding into it require, so building a compliant passport is a guided process. GCN does not register a product with the Commission's Registry on a brand's behalf — that will be a separate step for the Issuer (or their nominated registrant) once it's operational for textiles.

Circular Performance Profile — building your evidence history now

GCN's Circular Performance Profile collects durability, repairability, disassembly, recycled content, and related circularity attributes, building a documented evidence history that can contribute to future reporting obligations under ESPR ecodesign requirements and the EU Waste Framework Directive, ahead of those requirements coming into force.

ESPR Textiles — Building to the EU's Own Preparatory Research (JRC Study)

The EU's Joint Research Centre published its preparatory study for ESPR's textiles ecodesign requirements in December 2025, ahead of the expected delegated act (still targeted for around 2027). GCN has built directly to these proposals — recycled and organic fibre content, environmental footprint assessment, and a computed recyclability indicator — adjusting as they move through the EU's own process toward final policy. None of this reflects an adopted legal requirement today; GCN does not verify the underlying data a brand enters, and every figure is labelled as based on preparatory EU research, not settled law.

So organisations can start capturing this data now in preparation for mandatory implementation, GCN's platform also collects data relevant to:

Textile Labelling (Regulation (EU) No 1007/2011); four ECHA-administered chemical regulations, each triggered differently — Chemical disclosure (REACH Article 33), CLP Regulation, SCIP notification (Waste Framework Directive, Article 9(1)(i)), and POPs Regulation (Persistent Organic Pollutants, including PFAS); Microplastics and Microfibre Shedding Test Evidence (under AATCC TM212, ISO 4484-1, or The Microfibre Consortium Test Method); and the Safe and Sustainable by Design (SSbD) Framework (Commission Recommendation (EU) 2026/510).

Additional regulations include Deforestation-free sourcing (EUDR — Regulation (EU) 2023/1115), Forced labour risk documentation (Regulation (EU) 2024/3015), the revised EU Waste Framework Directive (Directive (EU) 2025/1892), Empowering Consumers for the Green Transition (ECGT — Directive (EU) 2024/825), the Right to Repair Directive (EU 2024/1799), and the EU Business Wallet future credential reference (eIDAS 2.0).

Digital Product Passport — Technical System Standards (CEN/CENELEC EN 182xx)

Eight standards, developed by CEN/CENELEC's Joint Technical Committee 24. Six were published as full standards on 27 May 2026; the remaining two, covering access rights and data authentication, are still in final draft. None of this is a legal requirement for textiles yet — the ESPR delegated act for the sector hasn't been adopted — but the same technical standards are already live for battery passports (from February 2027), so we've built toward them ahead of the mandate.

EN 18216 — Data Exchange Protocols, EN 18219 — Unique Identifiers, EN 18220 — Data Carriers, EN 18221 — Data Storage, Archiving & Persistence, EN 18222 — APIs for Lifecycle Management & Searchability, EN 18223 — System Interoperability, EN 18239 — Access Rights, Security & Confidentiality (final draft), EN 18246 — Data Authentication, Reliability & Integrity (final draft).

RFID hardware compliance: RoHS Directive (2011/65/EU); RFID producer responsibility and end-of-life under the WEEE Directive (2012/19/EU).

Built for scale: bespoke reporting support for large brands

The GCN platform is built to accommodate businesses of all sizes — affordable for MSMEs, while also supporting larger brands required to meet additional corporate due diligence and reporting, including the Corporate Sustainability Due Diligence Directive (CSDDD — Directive (EU) 2024/1760) and the Corporate Sustainability Reporting Directive (CSRD — Directive (EU) 2022/2464). For brands reporting under CSRD, we offer a bespoke engagement to structure our data specifically to your ESRS reporting requirements.

International Textile Standards (ISO/TC 38)

GCN has built to ISO/TC 38 — the international technical committee responsible for textile standards: fibre identification, composition testing, care labelling, colour fastness, and, increasingly, environmental and traceability vocabulary. None of these are laws in themselves; they're the reference methods regulators, certifiers, and test labs point to when a legal requirement needs a specific, repeatable way to measure or label something. Request additional information on how GCN's data model lines up with the specific ISO/TC 38 standards, including:

• ISO 1833 series — Quantitative Chemical Analysis

• ISO 3758:2023 — Care Labelling Code Using Symbols

• ISO 105 series — Tests for Colour Fastness

• ISO/TC 38/SC 20 — Fabric Descriptions

• ISO 4484 series — Microplastics from Textile Sources

• ISO/TC 38 — Traceability & Responsible Sourcing of Animal Fibres

• ISO 5157 — Textiles: Environmental Aspects — Vocabulary

GCN does not test, certify, or independently verify conformance to any ISO/TC 38 standard — these are reference methods and vocabulary that inform how we structure our own fields and what evidence we let you attach, not a certification GCN itself holds.

International Textile Standards ISO 59040 Product Circularity Data Sheets (PCDS)

ISO 59040:2025 describes a Product Circularity Data Sheet, a voluntary business-to-business template of circularity statements covering composition, circular production, repair and reuse, and end-of-use. It is separate from the DPP requirements under ESPR. GCN does not issue PCDS documents. Many PCDS statements ask for data a brand already records in its GCN DPP, such as fibre composition, recycled content, repair and recycling claims, take-back partners, and certification evidence. So GCN lets a brand export that data for a product as a CSV file, labelled "prepared from GCN data, based on the ISO 59040 structure". Each row shows its source and whether it was prefilled from GCN or still needs the brand's input, and anything GCN doesn't hold is left blank. The brand then completes and issues its own PCDS in the tool of its choice. Brands can also link an externally created PCDS to the DPP as a related document. All values are declared by the brand and GCN does not verify them. The export is available only to the brand's own organisation, and what the public DPP shows is unchanged.

US State Extended Producer Responsibility (California SB 707)

GCN's platform is built to collect appropriate data to meet the upcoming Californian Responsible Textile Recovery Act (SB 707) — an Extended Producer Responsibility (EPR) law for apparel and textile articles, a broader category than "textiles" alone, explicitly including footwear, handbags, fabric window coverings, and napkins. CalRecycle's implementing regulations — which will define the exact data producers must report and how eco-modulated fees are calculated — aren't expected before 1 July 2028 at the earliest, with full programme rollout by 2030.

Unlike the EU's ESPR, SB 707 does not currently mandate a Digital Product Passport.

Built to move when the regulations land. GCN does not calculate or submit eco-modulated fees, and does not report to CalRecycle. Once CalRecycle's implementing regulations define the actual reporting fields and thresholds, we'll adjust our data model to match — the same approach we've taken with every EU regulation still in preparatory or draft form elsewhere on this page.

Contact GCN to request further information on the specific regulatory frameworks in the GCN Platform Compliance Report.

Click here to see the additional list of Sources we draw from.