If you are a sustainability officer at a fashion brand or textile manufacturer, the way product and supply-chain information is managed is changing significantly. What was once difficult to trace across multiple tiers of the value chain will increasingly need to be documented, structured, and accessible.
Under the Ecodesign for Sustainable Products Regulation (ESPR), which entered into force on 18 July 2024 in the European Union, the Digital Product Passport (DPP) is a regulatory requirement that will reshape how product data is collected, verified, and shared. For companies in fashion and textiles, this means building systems that can connect information across the full product lifecycle, from raw material sourcing to manufacturing, distribution, use, and end-of-life.
Textiles have been identified as a priority sector under the regulation because of their significant environmental footprint, rapid production cycles, and low recycling rates. The introduction of DPP will therefore have practical implications for how companies track materials, engage suppliers, manage compliance data, and communicate product information.
What is a Digital Product Passport?
Imagine there’s a QR code on your product. Your consumer scans it and instantly sees exactly where the materials were sourced, the factory’s carbon footprint, and a guide on how to repair the fabric after years of use. Sounds like science fiction, right? It’s not. That’s what the DPP is.
At its simplest, a DPP is a digital identity card for a physical product. It securely records a product’s entire life story, from raw material extraction to eventual disposal.
Addressing the Triple Crisis of Fashion
The textile industry is in a threefold crisis. As defined by the EPRS study, this includes ecological, economic, and social issues. Characterised by high wastage and complex, fragmented global supply chains, the industry is a major user of non-renewable resources and intense amounts of water.
The textile-specific DPP seeks to reduce the “fast fashion” model. It does this by offering clear information on material longevity and the social effects of production. By making sustainability data visible, the EU hopes to shift the market toward more durable and repairable products.
A 3-Phase Deployment
The EU is looking at a progressive rollout to ensure businesses can adapt. This is based on the June 2024 STOA (Panel for the Future of Science and Technology) study undertaken for the European Parliament involving over 80 stakeholders across the textile sector and proposing “step-by-step implementation scenarios”.
| Phase | Target Year | DPP Maturity Level | Minimum Expected Requirements (more yet to be finalised) |
| 1 | 2027 | Minimal & Simplified DPP | Circularity (recycled content and recyclability/ re-use)Product safety and innocuousness (chemical safety/ REACH compliance)Key environmental impacts (eg Greenhouse Gas/ carbon footprint, energy use, water use, water pollution, plastic microfibers)Supply chain traceability (at least the location of the following main processes but also the wet processes that have significant impact), information on the packaging of the finished product (recycled content, recyclability, possibility of re-use).Most probably weight & quantity, as well as composition materials of the main components |
| 2 | 2030 | Advanced DPP | Requirements will expand to include more information on:The finished product for transparency for the customers (eg colour, size, weight, composition).The supply chain with restrictive access to preserve confidentiality and business of the companies.Potentially data related to the product’s health impact, the value chain’s social impact and animal impact. Potentially more environmental impact data (likely to be aligned with the EU Product Environmental Footprint (PEF) Category Rule (CR) for Apparel). |
| 3 | 2033 | Full Circular DPP | Comprehensive circular record including repair history, resale information, and garment-specific sorting/recycling instructions. |
Important Note: This is an initial draft and not an exhaustive list based on current EU documents. Technical updates are to be provided by end of 2025 and end of 2026, draft DPP requirements by end of 2027 and final DPP requirements are to be announced by early-mid 2028.
Why 2027 is Your Target
The Delegated Acts for Textiles, which will set the exact rules for clothing under the ESPR, are the next regulatory milestone and are currently planned to be issued as draft by end of 2027, and as final by early-mid 2028. Once these acts are adopted, brands will have a compliance window to get their digital systems in order, with compliance expected to be delivered by mid-end 2029. That said, it will easily take Brands and its Tiers 1/2/3 suppliers up to 2 years to gear up to the DPP requirements, so starting that journey in 2026 or latest in 2027 is highly recommended.
Crucial Note: Even if your brand is based outside the EU (e.g., in the U.S. or Asia), if you sell in the European market, you will have to comply with these regulations to ensure fair competition.
What Data Do You Need to Collect?
As a sustainability officer, you should begin auditing your data now. As per the STOA report presented above, the key data you will require include:
| Data Category | What You Need to Collect | Why It Matters |
| Product identity and description | Name, unique product identifier, size, weight, colour, and temporality (season/year) | Forms the baseline for lifecycle assessment and comparability across products |
| Supply chain | Manufacturing stages and locations (Tiers 1-4) | |
| Composition & Innocuousness | Fibre composition, recycled content, and presence of hazardous substances (REACH/SoC) | Required for Phase 1 compliance to prove safety and material circulation. |
| Environmental Impact | Key environmental impacts (eg Greenhouse Gas/ carbon footprint, energy use, water use, water pollution, plastic microfibers) and ultimately all environmental impact data as per the EU PEF CR (Product Environment Footprint Category Rule) for Apparel & Footwear | Required for Phase 1 and Phase 2 |
| Circularity Instructions | Repair guidelines, maintenance advice, and recycling protocols | Supports extended product life and end-of-life responsibility requirements |
| Social Impact | Due diligence data on human rights and labor conditions | Aligns with the Corporate Sustainability Due Diligence Directive (CSDDD). |
| Documentation | Compliance certificates, audit reports, and transaction certificates | Provides verifiable evidence during regulatory reviews and brand audits |
Important Note: This is an initial draft and not an exhaustive list based on current EU documents. Technical updates are to be provided by end of 2025 and end of 2026, draft DPP requirements by end of 2027 and final DPP requirements are to be announced by early-mid 2028.
Mandatory Information
Additional / Voluntary Information
Table 1: Expected DPP Data Taxonomy (Based on EU EPRS & CIRPASS Preparatory Studies)
Categories of Information
Phase 1 (~2027)
Compliance
Phase 2 (~2030)
Performance
Phase 3 (~2033)
Circularity
Supply Chain: Production
Reference (Batch/ID)
✔
✔
✔
Type of Processes (Tier 1-2)
✔
✔
✔
Weight Quantity
✔
✔
✔
Traceable Asset (Tier 3-4)
✔
✔
Company (Tier)
✔
✔
Composition Material
✔
✔
✔
Identification Type
✔
✔
Location (Country/Facility)
✔
✔
✔
Date
✔
✔
Supply Chain: Transports
Company
✔
Means
✔
✔
✔
Distance
✔
✔
✔
Date
✔
Finished Product
Reference
✔
✔
✔
Colour
✔
✔
Costs
Circularity Strategy
✔
✔
✔
Quantity
✔
✔
Identification Type/Authentication
✔
✔
Composition (% Fibre & Recycled Content)
✔
✔
✔
Packaging Specs
✔
✔
✔
Company (Brand)
✔
✔
Performance / Durability Score
✔
✔
Description
✔
✔
Size
✔
✔
Date
✔
✔
Finished Products: Evaluations
Quantity Tests
✔
✔
Environmental Impact
✔
✔
✔
Audits
✔
✔
Animal Impact
✔
✔
Company (Evaluation)
✔
✔
Social Impact
✔
✔
✔
Certification
✔
✔
✔
Date
✔
✔
Distribution
Company (Distributors)
✔
Location
✔
✔
Purchase Dates
✔
In Shop / On-line
✔
Second hand
✔
✔
Usage
Usage Type
✔
Consumer Identification
Usage: Repair Cleaning and Modification
Company (Aftersales)
✔
Type of Service
✔
✔
Location
✔
Date
✔
✔
End of Life: Collecting/Sorting
Reference
✔
✔
Type of Processes
✔
Location
✔
✔
Identification Type
✔
✔
Output
✔
Date
✔
✔
Input
✔
Company (Collecting)
✔
End of Life: Recycling
Type of Processes
✔
Recycling Strategy
✔
Company (Recycling)
✔
Location
✔
✔
Composition
✔
✔
Date
✔
✔
What are the Challenges?
The biggest challenge is that you cannot create a DPP alone. It requires radical collaboration with your entire supply network. For example, gathering data from “Tier 2 & 3” suppliers will be difficult. These are the fabric mills, weaving and knitting facilities, dye houses, and yarn spinners. Often located in developing economies, these suppliers may lack the digital infrastructure required to provide machine-readable certifications or verified data.
Additionally, many manufacturers worry that disclosing detailed material compositions or supplier lists could compromise trade secrets. To solve this, the EU proposes differentiated access rights:
• Public Access: Visible to consumers (e.g., eco-scores, repair instructions).
• Restricted Access: Shared with supply chain partners and authorities (e.g., detailed batch-level performance and compliance audits).
How to Prepare in Advance for DPP
Don’t wait for 2028! It takes time to understand the requirements, start to embed such new activities across your product life-cycle processes, and develop an efficient data infrastructure and collection process.
Early adopters will also have the ability to pilot, learn and identify how to generate new value and gain a competitive edge – for example through enhanced engagement with consumers, whilst avoiding compliance scramble.
1. Map Your Supply Chain: Identify every partner involved in data creation, from raw materials (or at least Tiers 3 – yearn spinners) to distribution.
2. Audit Your Data: Determine where your data currently lives (spreadsheets, ERPs, or supplier databases), its quality, and identify what is missing – specifically regarding innocuousness, environmental impact and recycled content.
3. Run a Pilot: Start with a “capsule collection” to test the flow, from creating IDs to generating the passport.
4. Align with Standards: Ensure your environmental footprint data aligns with PEF methodology.
5. Assign Governance: Create a cross-functional team to lead DPP compliance readiness. Review and improve ownership of product data across your design, sourcing, and compliance functions.
The Role of Sustainability Softwares
The sheer volume of data required for every SKU can be overwhelming. The EU STOA study emphasizes the need for interoperability (APIs) to connect existing systems like PLMs and ERPs with the DPP. This is where specialised software like GreenStitch will help you transform the workflow.
Instead of relying on manual spreadsheets, GreenStitch creates Digital Product Passports (DPP) using verified lifecycle and supply-chain data. It connects with existing ERP and PLM systems to pull information directly from Bills of Materials and supplier declarations. This helps ensure each passport meets the incoming delegated acts requirements. This helps you move beyond rough estimates. You get clearer, science-based insights into your product’s impact.
