Foundations · 04 of 07
4 min read
The trade-off for a brand
A product passport is not a cost-free investment. The time spent filling in data is a real cost, and publishing a figure means accepting responsibility for that figure.
The real cost
The expensive part is not the subscription. It is the hours spent gathering supplier and composition data. For a brand with five SKUs, we aim for one working day. For a brand with a hundred, it is staged work, collection by collection.
Risks worth naming
Published data can be wrong, and the brand is the party answerable for it: under ESPR Article 27, the economic operator placing a product on the EU market answers for every passport data point, and a supplier declaration is not a defence. Wrong fibre or recycled-content figures are the kind of error that draws corrective measures. The liability also runs forward: a certificate expires, a supplier changes, and a page nobody updates becomes a published error. So every figure carries its disclaimer and its factor version, and unanchored wording is blocked before it goes out.
The claims rules reward plain words
From 27 September 2026, EU rules ban generic environmental wording with nothing checkable behind it. That is less frightening than it sounds for a brand that documents: a passport built from checkable facts is already inside the rules' register. To be plain about the division of labour: no platform can make a product compliant, ours included. Preparation puts the data in order; the brand, as the party making the claim, is the one that stands behind it.
If your buyer sells into France
France runs its own environmental cost score, the coût environnemental. Two parts reach Indonesian brands through their buyers: from 1 October 2026 a third party may calculate and publish a score for a brand that has not declared its own, using defaults that tend to land worse than declared data; and showing another aggregate environmental score to a French audience can oblige the brand to display the official score alongside it. If a buyer sells into France, this belongs in the planning conversation now.
The value you can count
Three things land fastest: answering a buyer questionnaire in hours instead of weeks, a hangtag that explains the premium without a salesperson, and internal records that are finally in order for the first time.
The essentials
- The main cost is data entry time, not the subscription.
- The brand is answerable for what its passport says. A supplier declaration offers no cover.
- No platform makes a product compliant. Preparation makes your statement checkable.
- From October 2026, silence towards France hands your score to whoever calculates it first.
- Fastest value: buyer questionnaires, price justification, and internal records in order.
Primary sources
- ESPR Article 27: economic operator responsibilities
- Directive (EU) 2024/825: EU rules on environmental claims, from 27 September 2026
- Décret n° 2025-957 and the Ecobalyse method: the French scheme
Time-bound claims in this module are re-verified at every JRC milestone. Last checked 19 Aug 2026.
Where we stand
Mula is not affiliated with the European Commission, the JRC, or any certification body. We describe rules in our own words and cite the clause. Using Mula is not registration of anything, and nothing here is a statement about your product's legal standing.
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