dpp is coming: is your brand ready? - a global fashion perspective

Aug 26

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This article is for editorial and informational purposes only and does not constitute legal or regulatory advice. Digital Product Passport requirements are still evolving, particularly for textiles, and brands should consult the relevant EU legislation and qualified advisers for their specific situation.

‍In our first PULP article on the Digital Product Passport (DPP) from 10.03.2025, we examined the wider transformation behind the concept: why the European Union is moving toward structured digital product information, we looked at the broader idea behind the system: what a DPP could mean for transparency in fashion, how product information may change, and what this development could mean for brands and consumers. This second article takes a more practical perspective. It looks at the regulatory framework behind the DPP, at what fashion companies can reasonably begin doing now while the textile-specific requirements are still being developed, at how companies inside and outside the EU may be affected, and at what these changes may eventually mean for consumers inside and outside the European Union. It considers also what the regulatory framework already established, what is still unresolved for fashion in 2026.‍ ‍

Chronology is important. The legal framework is already two years old. Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation (ESPR), entered into force on 18 July 2024 and established the framework through which Digital Product Passports can become mandatory for specific product groups. The Regulation contains a dedicated chapter on the DPP and establishes essential requirements concerning product identifiers, data carriers, interoperability, access rights, data quality, and the future EU registry. Yet, this does not mean that ordinary fashion products have required a Digital Product Passport since 2024. Under the ESPR, concrete DPP obligations are introduced through delegated acts for particular product groups. Textile apparel is a priority group, but its product-specific delegated act has not yet been adopted. The European Commission currently plans adoption in Q4 2027 and states that the implementation timetable may change as the legislative and technical work progresses. Fashion is therefore in an intermediate phase. The direction of regulation is established, but the exact textile requirements are not. It would be premature to claim that brands can already follow a definitive textile DPP compliance checklist, because the final information requirements, the level at which passports will be assigned, and other sector-specific details will depend on the forthcoming delegated act, obviously. At the same time, the absence of final textile rules does not mean that brands have nothing useful to do. Much of the preparation concerns basic product information management, and that work is valuable independently of the precise form the final requirements take.

DPP - A structured digital information record linked to a physical product (@ Edie Lou Freisinger)

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What Is a Digital Product Passport?

A Digital Product Passport is a structured digital information record linked to a physical product through a unique identifier. It is a digital product record that will accompany products covered by the relevant European Union rules. It is an EU system for linking a physical product to a standardized digital record containing legally defined product information. It is part of the European Union’s broader move toward product traceability, circularity, and more structured access to information across a product’s life cycle. The ESPR establishes the general DPP architecture but does not impose the same passport on every product immediately. Product-specific requirements are introduced progressively through delegated acts under the Regulation. This means that the Regulation does not impose one identical passport on every product immediately. Instead, the European Commission first identifies priority product groups and then develops separate, legally binding requirements for each of them. Textiles and apparel are one of these priority groups. Its purpose is to keep relevant product information connected to the item in a structured form that can be accessed electronically. Depending on the final rules for a product group, the passport may contain information relevant to identification, materials, composition, maintenance, repair, reuse, recycling, environmental characteristics, or the economic operators responsible for the product.

So, for textiles, the Commission is currently preparing a specific legal act that will determine how the DPP must work in practice. This future act will define which textile products are covered, what information the passport must contain, whether the passport applies at model, batch, or individual-item level, which users may access which information, how the passport must be linked to the product, and from what date the requirements become applicable. Once that act is adopted, companies will receive a transition period before the rules begin to apply. When the textile requirements eventually become applicable, the relevant economic operator placing the product on the EU market will be responsible for ensuring that the required DPP exists and that the information it contains is accurate and up to date. So, the company legally responsible for putting that garment onto the EU market has to make sure the passport exists and that the required information in it is correct. That could be the manufacturer, importer, or another economic operator depending on how the product enters the EU market and how the final textile rules assign responsibility. The passport will be connected to the physical product through a standardized unique identifier and a machine-readable data carrier, such as a QR code where this is specified by the textile rules. The company may manage the underlying product data through its own systems or work with external service providers, but responsibility for meeting the legal requirements remains with the relevant economic operator.

In 2026, fashion is still in a preparatory phase, but the DPP for textile is no longer merely a theoretical policy proposal. The ESPR itself identifies textiles - particularly garments and footwear - among the product groups to be prorated for future ecodesign requirements. The Commission’s 2025 - 2030 ESPR Working Plan subsequently confirmed textiles as a priority sector. The European Commission is now developing the textile-specific delegated act and currently indicates Q4 2027 as the planned date for its adoption, while noting the timetable may still evolve as the legislative and technical work progresses. The current EU framework does not provide a general exemption from future DPP requirements simply because a company is small or independent. Once textile- specific rules become applicable, the obligations are expected to follow the products placed on the EU market and the role of the relevant economic operator rather than company size alone. For fashion brands of all sizes, the present period is a reasonable time to prepare, even though the final textile obligations are not yet in force. Brands can use the time to assess whether their product information is organized consistently and start mapping the product information they currently hold. They can already organize product records, identify traceability gaps, improve supplier documentation, preserve evidence, and establish consistent internal data practices. They can check whether those records are stored consistently and whether they can be linked back to the correct product, material, or production run. These steps do not guarantee future compliance, but they reduce the amount of work that will be necessary one the final textile requirements are published. The final mandatory dataset for textile DPPs has not yet been adopted. The ESPR already defines the categories from which product-specific passport data can be selected, while the forthcoming textile rules will determine exactly which of these data - and which additional textile-specific information - fashion products will have to provide. You can find a short preparation checklist at the end of this article. It is not an official EU checklist and should not be read as a finalized set of mandatory textile DPP fields. Rather, it summarizes the categories of product and supply-chain information that are already clearly relevant to the DPP framework and are therefore likely to form part of, or support, the future textile requirements.

The information in the passport must be accurate, complete, and up to date (@ Edie Lou Freisinger)

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From Product Knowledge to Structured Product Data

Most fashion companies already possess large amounts of information about the products they make. Designers select materials and trims, technical teams create tech pack specifications, production departments communicate with manufacturers, purchasing departments manage suppliers, and logistics systems record the movement of finished goods. The information was usually created for different operational purposes and is not necessarily organized as one coherent product record. A fiber composition may be recorded in a technical specification, while supplier certificates are stored separately, manufacturing information appears in purchase orders or ERP records, and care instructions sit in dedicated artwork or labelling files. The information is therefore not necessarily disorganized; it is often organized according to different operational functions. The difficulty is that these separate records do not automatically form one coherent product history. A company may know a great deal about a garment while still needing to bring information from several files and systems together in order to reconstruct it fully. Each record can be accurate and well managed in its own context, while the overall product history remains fragmented.

The ESPR changes the significance of this fragmentation because a DPP is not merely a digital marketing page. Where a product-specific delegated act requires one, the information in the passport must be accurate, complete, and up to date. The Regulation also establishes essential technical principles: a passport must be linked to a persistent unique product identifier, its date must be structured and interoperable, and access must be managed according to rights defined for the relevant product group. The delegated act will determine whether information relates to a model, a batch, or an individual item and which data different actors may access. This means that preparation begins before deciding how the future DPP will be technically implemented. Brands first need to understand what product information they already hold, where it is stored, how reliable it is and whether it can be connected consistently to the relevant product.

Much of the core information may already be contained in the tech pack, including fabric and trim specifications, fiber composition, BOM, style number, supplier references, care-label information, construction details, and revision history. But the tech pack is usually only one part of the product record. It may not contain every supplier certificate, transaction document, manufacturing record, batch-specific change, testing result, or deeper upstream traceability information. Some of those records may sit elsewhere. The next question is whether the supporting information held elsewhere can be linked clearly to that same product record. The objective is therefore not to recreate information that already exists, but to determine whether the different records surrounding a garment can be connected consistently enough to form a complete and traceable product history. In small founder-led brands, product knowledge is often concentrated within a very short decision chain. The same people may select the textile, communicate directly with the mill or manufacturer, approve trims, revise the tech pack, and oversee production. This can produce a high degree of practical traceability, particularly when the supply chain is short. The weakness is not necessarily a lack of knowledge, but the absence of a formal data structure connecting that knowledge to documentary evidence. Information may exist across tech packs, purchase orders, certificates, supplier correspondence, invoices, test reports, and production revisions without being systematically linked through common product, material, and supplier identifiers. As the company grows, this becomes a question of data continuity: whether another employee, and auditor, or a future digital system can reconstruct the same product history from the records alone. A larger company may face the opposite problem: sophisticated databases and extensive documentation already exist, but information is distributed across large product ranges, multiple business units, supplier platforms, and legacy systems that were introduced at different stages of the company’s development.

One practical response is the use of a Product Lifecycle Management system, or PLM. In fashion, PLM software is designed to centralize many of the records generated during product development, including specifications, bills of materials, sizing, supplier information, technical documentation, and revisions. Established platforms such as Centric PLM by Centric Software are widely used in the fashion industry and can provide a highly integrated product-data environment for companies managing large assortments, complex supplier networks, and frequent product revisions. For a growing or established brand, this type of system can reduce duplication, improve version control, and make product histories easier to maintain across departments. For a start-up, however, enterprise-level PLM can be economically unrealistic. A very small label may work with only a limited number of styles, materials, and suppliers and, therefore, the company can already build a reliable internal structure with ordinary tools. For each style, the brand can create one master product record - as the central index for the garment. It would contain the basic information that identifies the product: style code, version, fiber composition, main material, trim information, supplier, manufacturer, care instructions, and links to the documents that support those facts using consistent naming and filing conventions. While the tech pack is primarily a production document used to communicate how a garment is constructed, the DPP is a structured digital record associated with the finished product. Some information may overlap, such as product identifiers, and care information, but the DPP can also draw on supplier records, certifications, manufacturing documentation, traceability data, and information relevant to repair, reuse, or recycling. Cloud-based document storage can support this structure without requiring significant software investment. All documents can be stored in clearly defined folders linked to the corresponding product or material code. The important issue is consistency. Responsibility for maintaining the definitive product record can be assigned clearly, even if this responsibility initially sits with the founder or production manager. These practices require relatively little financial investment but create a much stronger basis for future traceability and DPP implementation.

The goal at this stage is to establish disciplined product-data practices that can later migrate into a PLM or another structured platform when the business reaches sufficient scale. As a company grows, the difficulty is keeping one reliable product record synchronized across more people, suppliers, and production cycles. While at that level, an enterprise platform such as Centric PLM may still remain financially unrealistic, there is a middle ground. Lighter cloud-based PLM systems can introduce a shared product-data structure, version control, and collaborative access without the cost and implementation burden of a large enterprise solution. Examples include Techpacker and Rechain at the lower-cost end, PLMBR for more developed collaborative workflows, and Delogue for companies requiring more formal product and supplier management. Pricing and functionality vary considerably between providers.

PLM software is designed to centralize many of the records generated during product development (@ Edie Lou Freisinger)

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Beyond the EU

The DPP is an EU regulatory instrument, but its practical reach does not stop at the EU’s geographical borders. What matters is not primarily where a fashion company is headquartered, but whether a product is placed on the EU market. Once the textile-specific requirements become applicable, a Swiss, British American, Japanese or other non-EU brand selling covered garments into the European Union will have to consider the same market requirements as an EU-based company for those products The Commission describes the ESPR rules in precisely these market terms: once product-specific requirements are in place, they apply to products being sold on the EU market. For non-EU companies, however, the compliance structure can be more complicated because an additional actor may sit between the brand and the European market. Under EU product law, an importer is an EU-established person or company that places a product from a third country on the Union market, and importers carry their own compliance responsibilities. The ESPR also anticipates information concerning the importer and the EU-established responsible economic operator as possible elements of the DPP framework. The exact allocation of responsibilities for textiles will depend on the final textile rules and on the way a particular company distributes its products, so a Swiss brand selling directly into the EU may face a different operational structure from one working through an EU distributor or importer. The important point is that a “non-EU brand” does not mean “outside the system”. If the garment enters the EU market, someone in the chain must fulfil the relevant EU obligations. Where the brand is based matters less than how the product enters the EU market and which company is legally responsible at that point.

This creates an important distinction between legal scope and business impact. The European Union is not making the DPP a global law, obviously. A product sold exclusively in Switzerland, the United States or Japan does not become subject to the ESPR. Yet for internationally operating fashion companies, maintaining completely separate information systems for EU and non-EU products may prove inefficient. A company that already has to structure product information to satisfy European requirements may therefore decide to use the same underlying data architecture across several markets. In this way, EU regulation can influence international business practices without legally governing every product sold worldwide. For example, a Swiss brand must organize certain product information in a structured way in order to sell in the EU. Technically, it could maintain that structured system only for EU-bound products. But that would create two parallel ways of managing the same garments: one for Europe and one for Switzerland. Instead, the company may choose to use the same internal product-data structure for all markets, even where the DPP itself is not legally required.

For Swiss brands in particular, this makes the DPP difficult to treat as a distant European development. Switzerland remains outside the European Union, but the EU is a major neighboring market, and any brand intending to sell covered products there will need to follow the applicable EU market requirements once the textile rules take effect. The same logic applies to other non-EU companies with European customers. Preparing product information now therefore has a value beyond regulatory compliance: it reduces the need to reconstruct an entirely new information system when European requirements become operational and allows a company to decide deliberately whether its future product-data structure will be EU-specific or form part of a broader international system. But what happens if the US, Japan, the UK, etc. later introduce their own product- passport requirements? In principle, if every jurisdiction created a completely incompatible passport with different identifiers, formats, and databases, international brands would face a serious compliance burden. They could end up in a bureaucratic hell: the same garment documented several times according to different data fields, identifiers, technical formats, and reporting rules. Without interoperability between systems, a mechanism designed to improve transparency could instead generate administrative cost and CCC (considerable compliance complexity).

When an economic system repeatedly fails to account for the consequences it produces, regulation becomes difficult to avoid (@ Edie Lou Freisinger)

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When Regulation Becomes Necessary

The obvious international risk is fragmentation. The European framework attempts to reduce this risk by building the DPP around open standards, interoperable formats, standardized identifiers. What the EU cannot solve by itself, however, is what the US, Japan, Switzerland, or other jurisdictions may decide to require in the future. The EU can design its system around open and international standards so that compatibility is technically possible, but it cannot guarantee that another non-EU country will adopt identical rules. So, there is a technical solution, but not yet a complete political one. The ideal international model would be: one underlying product-data system within the company, based on common standards, with different regulatory outputs generated from that same source. If international regulators coordinate, this could work quite well. But standardization inevitably removes freedom. In this case, it tells companies that certain information must be recorded in a comparable form rather than however each company prefers. That can feel extremely bureaucratic, particularly for small businesses, and badly designed standards can become expensive administrative machinery. There is therefore a legitimate reason to be cautious about how far standardization goes.

But there is an uncomfortable reason why regulation has become necessary. For decades, much of the fashion industry was organized around maximizing production, consumption, and profit while significant environmental and social costs remained outside the responsibility of the companies creating them. Pollution, resource depletion, waste, and opaque supply chains could be treated as external consequences rather than integral costs of doing business. Voluntary initiatives have certainly produced improvement, but they have not created a consistent level of accountability across the industry because of their voluntary nature. When an economic system repeatedly fails to account for the consequences it produces, regulation becomes difficult to avoid. The DPP can therefore be understood as part of a broader attempt to move responsibility back into the product system itself: if companies will not consistently provide traceability and credible information voluntarily, governments increasingly require them to do so. An industry that refuses to govern its own externalities eventually invites government to germ them for it.

For start-ups and small brands, the transition may also create an opportunity to contribute to a fairer competitive environment. If comparable product information becomes a common requirement, companies that invest seriously in responsible production may be better able to demonstrate that effort, while opacity becomes more difficult to use as a competitive advantage. This should not be confused with making the industry fair by regulation alone, obviously. A Digital Product Passport can improve traceability and accountability, but it cannot by itself determine whether a product or business model is environmentally or socially responsible. Its importance lies in making some of the information needed to judge those questions harder to hide.

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This bullet list is grounded in Annex III of the ESPR, it is a list of possible/legal DPP data elements - it is not the finalized mandatory textile DPP checklist.

Product-specific information required by the relevant ecodesign rules, including information on product performance, characteristics, substances of concern, durability, repairability, recyclability, or other requirements where applicable.
Unique product identifier for the model, batch, or individual item, depending on what the product-specific rules require.
GTIN or equivalent product identification number, where applicable.
Relevant customs or commodity code, such as a TARIC code.
Compliance documentation, for example declarations of conformity, technical documentation, or conformity certificates where required.
User information, such as instructions, warnings, or safety information where required by EU law.
Manufacturer information, including the manufacturer’s identification and required contact details.
Identifiers for other relevant economic operators in the value chain where required.
Unique facility identifiers for relevant production locations where required.
Importer information, including identification and, where applicable, the importer’s EORI number.
Information identifying the responsible EU-based economic operator, where such an operator is legally required.
Reference to the DPP service provider holding the required backup copy of the passport
Product description — product name, category, model or style, colourway, and relevant version.
Fibre composition — documented composition of the main material and, where possible, relevant components.
Material records — fabric and trim specifications, material codes, and supplier references.
Repair information — information that could support repair or replacement of components where relevant.
Production changes and version history — records of changes in fabric, trims, supplier, manufacturer, or specification between production runs.
Traceability gaps — a record of which stages of the supply chain are documented and where reliable information currently stops.
Responsible person or team — someone inside the company responsible for maintaining the definitive product record.