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 to develop best-practice methodology and assist to meet the emerging regulations and customer transparency expectations.

GCN is built on the UNTP framework for global data interoperability and the platform is designed to move quickly to adapt as circular economy regulations increase globally.

The data below is what we actually collect through the DPP lifecycle, and the specific regulatory frameworks it can contribute evidence toward, grouped by what they actually govern. Click here to see the full list of Sources we draw from.

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 field by field against what ESPR and the regulations feeding into it actually require, so building a compliant passport is a guided process. This is built ahead of the textiles delegated act being finalised — there's no formal ESPR service-provider registration to hold yet, because that process doesn't exist for textiles until the Registry goes live.

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. GCN provides the structured data and hosting that registration will point to.

Circular Performance Profile — building your evidence history now

The Circular Performance Profile data we collect today — durability, repairability, disassembly, recycled content, and related circularity attributes — builds 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, not yet adopted). GCN builds to these proposals directly, adjusting as they move through the EU's own process toward final policy — the same forward-positioning approach we take across every regulation on this page.

  - Recycled content is recorded per fibre with evidence, and compared against the JRC's currently proposed thresholds (denim: 20% recycled cotton; knitted or woven: 5–15% polyester, 5–10% nylon/wool) — labelled as proposed figures, not a mandated requirement.

  - Organic content is recorded as a structured percentage per fibre, evidence-linkable, distinct from organic certification (which confirms a standard was followed, not a quantity).

  - Carbon and environmental footprint draws on our existing Product Environmental Footprint (PEF) assessment — all 16 EF3.1 impact categories — distinguishing primary supply-chain data from secondary or estimated data, matching the JRC's own proposed reporting distinction. This remains voluntary; there is no mandated threshold.

  - A recyclability indicator is computed using the JRC's own proposed formula — mono-material composition, absence of coatings/prints/sequins/dyes, elastane content, and availability of a compatible recycling technique. The JRC describes this on a 0–10 scale, though the components as currently proposed cap the achievable score at 7 — we show the figure exactly as it computes, not adjusted to imply a higher ceiling. This is the EU's proposed methodology, not a GCN-invented score, and will be updated if the delegated act finalises a different approach.

  - None of this reflects an adopted legal requirement today. GCN does not verify the underlying data a brand enters — we record what's declared, with evidence where a brand chooses to provide it, and label every figure here as based on preparatory EU research, not settled law.

ESPR — Unsold Consumer Products: Destruction Ban & Annual Disclosure
Regulation (EU) 2024/1781 bans large companies from destroying unsold apparel, clothing accessories, and footwear — in force since 19 July 2026, extending to medium-sized companies from 2030. Alongside the ban, large companies must publicly disclose each year how much unsold stock they discard: quantity, weight, product category, the reason for discarding it, and what actually happened to it (resale, donation, recycling, remanufacturing, or — only under a permitted exception — destruction).

GCN lets a DPP Issuer log each discard event as it happens, see running totals build toward the year's figures, and finalize the annual disclosure once the filing period closes. Once finalized, that record is locked — it cannot be edited afterward, matching the reality that this becomes a real filing, not a draft. A finalized disclosure can be exported as a CSV of the locked category totals, ready to publish or submit as your actual annual filing.

This feature is visible to organisations recorded as "Large" under the EU's own size definition — 250+ employees, or turnover over €50 million and balance sheet over €43 million, the same definition the regulation itself uses. GCN does not verify a brand's declared size or audit its discard figures; we record what the Issuer enters, and lock it once they choose to finalize.

Fibre Composition & Labelling

Textile Labelling — Regulation (EU) No 1007/2011
This regulation sets the legally defined list of textile fibre names (Annex I) that a garment's composition label is allowed to use — "cotton," "elastane," "viscose," and so on are legal terms with specific definitions, not arbitrary marketing names. It also requires the label to state each fibre's percentage by weight, listed heaviest first (Article 9(1)), allows minor components to be grouped under "other fibres" instead of listed individually (Article 9(2)), and separately allows small, purely decorative fibres under roughly 7% of the garment's weight to be left out of the declared composition altogether (Article 10(1)). Where a product is sold to consumers in an EU member state, the label must be in that state's official language (Article 16(3)).

GCN's fibre composition generator resolves whatever a facility enters against the Annex I list — including its full set of recognised fibres and the common trade/brand-name synonyms that map to them (e.g. "tencel" to lyocell, "rPET" to polyester) — then renders the result in the correct descending-weight order with percentages, with an Issuer-controlled option to group minor fibres and to exclude qualifying decorative fibres from the mandatory count. This resolved composition is what appears on the Product ID page, the public resolver, and CSV exports — not the raw text a facility originally typed in.

Label text is available in English and German today, with additional official languages added as we verify each translation against the regulation's own multilingual text. GCN does not verify a fibre content claim's accuracy — we apply the regulation's own naming, ordering, and labelling rules to what a facility declares.

Chemicals, Substances & Hazard Data

These four regulations are all administered by ECHA and all concern chemicals in textiles, but each is triggered differently and requires a different action — grouped here so the distinction is clear.

Chemical disclosure — REACH Article 33
The Substance of Concern (SoC) disclosure data we collect — including SVHC attestation at the 0.1% w/w threshold — can contribute to your organization meeting REACH (EC 1907/2006) Article 33 disclosure obligations: the duty to tell your customers and consumers, on request, if an article you supply contains a Candidate List substance above that threshold. This is separate from — and comes before — the SCIP notification duty below, which is a direct submission to ECHA rather than a communication to your own customers.
See how this is managed in the GCN Platform through the Downstream Network

SCIP notification — Waste Framework Directive, Article 9(1)(i)
Once an SVHC above 0.1% w/w has been declared under Article 33 above, a separate duty follows: notifying ECHA's SCIP database directly, so the substance's presence is captured for waste operators and recyclers at end of life. GCN's Chemical Disclosure includes a guided SCIP Notification Prep workflow — it pulls the article identifier, walks through exactly what ECHA requires per substance (CAS/EC number, concentration band, location in the product), classifies the article correctly (as an article or a complex object), and captures the required safe-use instructions, with a shortcut to copy a previous SCIP-ready product for a near-identical colourway. GCN does not submit to ECHA on your behalf — the workflow prepares everything, you submit through ECHA's own SCIP Submission Portal, then log the confirmation number to close the loop.

CLP Regulation — Chemical Input Hazard Classification.
The CLP Regulation (EC 1272/2008) requires anyone placing hazardous chemical substances or mixtures on the market — and downstream users of them — to classify, label, and package those chemicals correctly, using a signal word, GHS pictograms, and hazard statements set out on the chemical's Safety Data Sheet. This sits alongside, not instead of, the REACH and SCIP duties above — CLP concerns the chemicals used during production (dyes, finishes, treatments), while REACH/SCIP concern SVHC presence in the finished article itself.

Facilities can record their standing chemical input inventory in GCN — each declared chemical's signal word, pictograms, and hazard statements, as provided on its SDS, with the option to attach the SDS itself as evidence. Because this is a fact about the facility's ongoing chemical use rather than any single product, it's recorded once at facility level and applies across every DPP that facility is linked to.

This data is visible to regulators reviewing a DPP's linked facilities. It does not appear on the public Product ID — hazard classification of a manufacturing input has no bearing on the finished product a consumer sees, so we don't surface it there. GCN does not classify, test, or verify chemical hazard information — we record what a facility declares from the supplier's SDS. This does not replace a facility's own legal SDS record-keeping and hazard-communication obligations under CLP.

POPs Regulation — Named-Substance Compliance (Persistent Organic Pollutants)
Regulation (EU) 2019/1021 prohibits placing products on the EU market above set concentration limits for specific named substances — including PFOA, PFHxS, HBCDD, SCCPs, and Dechlorane Plus. This is different from the disclosure-based duties above: it isn't a disclosure requirement, it's a market-placement ban. A product above the limit for any of these substances cannot legally be sold in the EU at all.

GCN lets a DPP Issuer record, substance by substance, whether it's not present, below the legal threshold, above threshold, or not yet tested — with the option to attach test evidence for each. If any substance is recorded above threshold, it's flagged clearly and prominently wherever the DPP is reviewed, including a dedicated market-placement warning on the regulator view — this isn't a quiet field state.

GCN does not test, verify, or independently confirm chemical concentrations — we record what the Issuer declares, with whatever evidence they choose to attach. Recording an above-threshold result doesn't block the DPP from being saved; the platform makes the fact impossible to miss, it doesn't act as a compliance gate.

On PFAS ("forever chemicals") specifically: two of the best-known PFAS compounds, PFOA and PFHxS, are already tracked above with the same substance-by-substance rigor as the rest of the POPs list — not present, below threshold, above threshold, or not yet tested, with evidence attachable per substance. The wider PFAS family (thousands of related compounds) isn't yet named individually in EU law the way these two are, so today it falls under the more general REACH Article 33 SVHC disclosure rather than this named, substance-specific tracking. That's expected to change — ECHA's proposed universal PFAS restriction under REACH, with consumer textiles named in the fastest restriction tier, would bring the wider PFAS family into a comparable named, per-substance regime.

The harder part of "the PFAS problem" is rarely just knowing a substance's legal status — it's tracing which facility or treatment step in a multi-tier supply chain introduced it in the first place. GCN's chemical disclosure data is captured per facility, per treatment step, not only once at the finished-product level, so wherever a PFAS-relevant substance is declared, it's tied to the specific facility and process that reported it — not left as an undifferentiated "may contain" statement about the finished product as a whole. GCN does not test for, detect, or verify PFAS presence itself; this is a self-attestation and traceability tool, not a laboratory — but it addresses the other half of the problem: knowing where in the chain to look, and holding that evidence in a structured, retrievable form once it exists.

This declared data also travels downstream: specific PFAS congeners under the POPs Regulation, and a general PFAS declaration under Restricted Chemicals, are both visible to a Sorter at the point of scanning as part of the batch-level chemical disclosure check described in the Circularity & Waste section below — so a flagged item is caught before it re-enters circulation, not just recorded and forgotten. GCN does not yet track the full PFAS family as a distinct, named category there either — today it's whatever's been declared against these specific, named substances.

Microplastics — Intentionally Added (REACH).
Separately from chemical hazard classification, REACH also restricts intentionally added synthetic polymer microparticles — microplastics deliberately included in a product, such as in some glitter, coatings, or finishing treatments. This is distinct from the unintentional microfibre shedding covered below, which happens during a garment's normal use and washing rather than being added on purpose. The EU Strategy for Sustainable and Circular Textiles separately identifies unintentional shedding as an area for future action under upcoming ESPR ecodesign measures.

Safe and Sustainable by Design (SSbD) Framework — Commission Recommendation (EU) 2026/510.
The SSbD self-attestation we capture in the Dyes & Finishing section — confirming whether the dyes or finishing chemicals used in a product were developed or assessed under the EU's Safe and Sustainable by Design framework — lets your organization show alignment with this voluntary Commission framework, which explicitly named textiles as one of the value chains tested in its development. It isn't currently mandatory, so this is offered for brands who want to demonstrate alignment ahead of any future requirement.

Sourcing, Origin & Human Rights

Deforestation-free sourcing (EUDR) — Regulation (EU) 2023/1115.
For leather, natural rubber, and wood-pulp-derived materials, the origin, certification, and due-diligence evidence we capture — including recognised schemes like FSC, PEFC, CanopyStyle, Leather Working Group, GPSNR, and — where applicable — a FLEGT licence (available only for timber sourced through Indonesia's licensing system, currently the only country with an operational one) — can contribute to your due-diligence documentation under the EU Deforestation Regulation. Following a December 2025 revision, application is postponed to 30 December 2026 for large and medium operators, and 30 June 2027 for micro and small operators.

Forced labour risk documentation — Regulation (EU) 2024/3015

The facility-level self-attestation on forced labour indicators we collect for Mill, Finishing, and Product Manufacturer facilities, together with a free-text sourcing risk assessment field, can contribute to your obligations under the Forced Labour Regulation. Both fields can be entered by you as the Brand, or — once you've approved that facility's own account — entered directly by the facility itself. This is documentation support, not an automated country-risk rating or a substitute for the Regulation's investigation and enforcement process.

A facility can request to link its own account to its record on GCN, but nothing changes until you approve that request — there's no automatic matching and no self-approval, and you keep a full history of every facility that's ever claimed a record under your account, including which organisation and when. Once you've approved a facility, it can enter its own forced labour and sourcing risk declarations directly, in its own words, rather than you relaying what you've been told.

Coverage also extends downstream. Sorters, resellers, repairers, rental companies, and other downstream operators using GCN can self-attest too — a direct "no indicators of forced labour at my own operation" declaration, alongside any recognised worker-welfare standards they hold (amfori BSCI, SA8000, SMETA, WRAP, Fair Wear, ETI Base Code, and others). This works differently to facility-level attestation above: a downstream operator's declaration is linked to the specific item via its RFID tag and reaches your compliance record automatically the moment that operator's system records the item, with no approval step on your side — you don't need to separately request evidence from every downstream partner who handles your product after it leaves your own facilities, but you also don't choose who that first attesting party is, the way you do when you approve a facility's claim. As with every self-attestation on this platform, GCN does not verify these claims; the value is that they're offered directly by the party in a position to know, structured and retrievable, rather than left as something you'd otherwise have no practical way to collect.

Corporate Due Diligence & Reporting — Built for Scale - see full details below

Circularity & Waste
Revised EU Waste Framework Directive — Directive (EU) 2025/1892.
The EPR registration status we record for textile and footwear producers can contribute to your obligations under the revised EU Waste Framework Directive, ahead of Member States' mandatory textile EPR schemes. GCN does not calculate eco-modulated fees — that sits with your Producer Responsibility Organisation (PRO).

Separately, Article 11a of the same Directive requires Member States to ensure separate collection of used and waste textiles, in force since October 2025. The bulk RFID scanning built into GCN's Sorter role — reading every item in a batch in one pass — checks each item's already-declared chemical disclosure data at the point of scanning and flags the batch if any item carries a restricted or advisory chemical rating, generating evidence of a genuine separate-collection stream at your sorting or collection facilities. This works the same way whether the batch is moving within the EU or on to a destination outside it — there's no country- or region-specific gating in how the scan works. See how this works on the Downstream Network

Microfibre Shedding Test Evidence.
There is currently no EU-wide requirement to test or disclose microfibre shedding from textiles. We've built this field ahead of that likely direction — France's AGEC framework already requires it, and it's a reasonable expectation for future EU textile rules.

It also has a present-day use: under the Empowering Consumers for the Green Transition Directive (ECGT), a brand that makes any claim about a product's shedding performance (e.g. "low-shedding fabric") must be able to substantiate that claim if challenged. Where a brand records a real test result here — under AATCC TM212, ISO 4484-1, or The Microfibre Consortium Test Method — that evidence can support the substantiation requirement for that specific claim. This field is self-reported by the brand, with an optional test report attached as evidence. GCN does not run, verify, or score the test itself — we hold the record and the evidence a brand chooses to provide.

Consumer Information & Transparency

Empowering Consumers for the Green Transition (ECGT) — Directive (EU) 2024/825. The quantified, evidence-linked claims we structure across the platform — durability, repair, and environmental attribute data tied to credentials rather than unverified marketing language — are built to support substantiation under the ECGT Directive, in force from September 2026 with no company-size exemption. A first-viewed timestamp is also recorded on each product's public page, confirming the information was genuinely accessed at least once — with no visitor identity captured — so your organization has evidence the claim data was made available and viewed, not just published.

Right to Repair Directive (EU) 2024/1799.   The Right to Repair Directive's mandatory obligations currently apply to a defined list of product categories — household appliances and electronics — and don't yet extend to textiles or footwear. We've built the data structure anyway: a repair information access point, a spare parts availability period, and a repair score/index field ready to be populated once a textile-specific repairability methodology is defined. This isn't compliance with a Directive that doesn't yet reach apparel — it's readiness, built ahead of ESPR's expected extension of repairability requirements to this sector, so your organization can start capturing this data now rather than scrambling once it becomes mandatory.

Digital Identity & Interoperability

EU Business Wallet — Future Credential Reference (eIDAS 2.0). The EU's eIDAS 2.0 framework (Regulation (EU) 2024/1183) is building the EU Digital Identity Wallet, extended to organisations as the EU Business Wallet — letting a company cryptographically prove its identity and role in a transaction. Rollout is still underway, expected around 2027, and there's no live credential format yet to connect to.

GCN already has an optional field for a future Business Wallet credential reference, captured consistently everywhere a business enters its own identity on the platform — your own organisation record, each facility's own record (Mill, Trims, Product Manufacturer), and both parties separately in every sorting and downstream/end-of-life event, so each counterparty's reference is captured in its own right rather than assumed from the other side of the transaction. Today it's free text with no format validation, because there's nothing concrete yet to validate against — this is forward-positioning for when the standard is finalised, not a working integration with a real EUDI Wallet credential today.

GCN does not verify an organisation's identity through this field, and entering a reference here confirms nothing on its own. It exists so the data structure is ready once the EU Business Wallet becomes a real, checkable standard. Where a reference has been recorded, it's visible on the relevant organisation, facility, and lifecycle-event records across the Regulator view and compliance export — again, as a captured reference, not a verified credential.

Embedded Electronics (RFID Hardware)

RFID hardware compliance — RoHS Directive (2011/65/EU). The RoHS compliance status we record for RFID tag hardware — covering cadmium, lead, mercury, hexavalent chromium, PBBs, PBDEs, and the four regulated phthalates — can contribute evidence toward RoHS Directive obligations for the electronic components embedded in your products.

RFID producer responsibility and end-of-life — WEEE Directive (2012/19/EU). The WEEE producer registration status we capture, and the RFID tag end-of-life handling attestations recorded at point of disposal, can contribute to meeting your WEEE Directive producer-responsibility obligations for embedded electronics. Tag-level end-of-life outcomes go beyond a simple reused-or-recycled split: a tag can be recorded as reset for reuse in a new product, routed to a WEEE-compliant e-waste stream, or — separately — left in the garment and disposed of with general textile waste, or with no outcome recorded at all. That last category isn't a gap in the data; it's deliberately captured so that improper or unrecorded tag disposal is itself visible on the record, rather than silently absent.

Built for scale: bespoke reporting support for large brands

Some obligations apply specifically to large enterprises and require compiling evidence across an entire supply chain into a specific format — not a single data point on a product record. GCN's underlying traceability, facility, and Circular Performance Profile data is built to feed exactly this kind of work. Where a brand's obligations go beyond what a self-attestation field can capture, we offer a bespoke, purpose-built engagement to structure our data around your specific framework.

Corporate Sustainability Due Diligence Directive (CSDDD) — Directive (EU) 2024/1760
CSDDD requires large companies to actively identify, prevent, mitigate, and remediate human rights and environmental impacts across their own operations and value chain, and to adopt a climate transition plan. This is a due diligence and risk-management exercise your legal and compliance teams run, drawing on evidence from every tier of your supply chain — Member States must transpose it into national law by 26 July 2028, with the first companies required to comply from 26 July 2029. GCN's facility-level attestations, forced labour indicators, sourcing risk assessments, chemical disclosure data, and origin/certification evidence are built to be that evidence base. For brands operating at CSDDD scale, we offer a bespoke engagement to structure this data specifically to your due diligence framework.

Corporate Sustainability Reporting Directive (CSRD) — Directive (EU) 2022/2464
CSRD requires qualifying large undertakings — following the 2025 Omnibus I simplification, companies with net turnover above €450 million and 1,000+ average employees — to disclose standardised sustainability performance data under the European Sustainability Reporting Standards (ESRS), subject to external assurance. This is a reporting exercise your finance and sustainability teams run, compiling structured data from across your supply chain into the ESRS format; national transposition is due by 19 March 2027. 

GCN's traceability data — captured in the sequence of how products are made, used, and cycled — and our Circular Performance Profile are built to be that underlying data source. 

Note. For brands reporting under CSRD, we offer a bespoke engagement to structure our data specifically to your ESRS reporting requirements.

These sit apart from our standard self-attestation fields because they're obligations operating at a different scale and requiring a different kind of engagement — CSDDD is about demonstrating what you did, CSRD is about disclosing what happened, and both draw on the same underlying evidence GCN is built to capture.

Packaging (PPWR) — out of scope

Regulation (EU) 2025/40 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC — commonly called the PPWR — governs the box, bag, and hang tag your product ships and sells in, not the garment or footwear item itself. It sets its own separate Extended Producer Responsibility registration (from August 2026), packaging sizing rules, recyclability grading, recycled-content targets, and harmonized labelling requirements, run through country-specific packaging registers that are entirely separate from textile EPR schemes.

This sits outside GCN's current scope. Our data model is built around the product's Digital Product Passport — a per-product record — not aggregate, business-wide packaging-material reporting, which is a fundamentally different shape of obligation. Packaging compliance also already has its own dedicated, industry-agnostic tooling ecosystem, unrelated to fashion or DPP platforms. If your organization needs packaging compliance support, that's a separate specialist engagement, not something GCN is built to cover.