Digital Product Passport: What is It and What Does It Imply for Fashion?

Within a rapidly evolving framework of sustainability and circular economy initiatives, the Digital Product Passport (DPP) is a fundamental tool for which preparation is essential. The DPP aims to gather comprehensive data on a product and its supply chain, fostering transparency and information sharing throughout entire value chains.

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With the introduction of the Ecodesign for Sustainable Products Regulation (ESPR), the European Union is moving sustainability from marketing territory into regulatory obligation. At the heart of this transformation lies a new instrument that CSR and IT departments must now prepare for: the Digital Product Passport (DPP). This is not a trend. It is not a voluntary label. It is a legal requirement that will progressively reshape how fashion brands design products, manage data, and communicate sustainability.

Let’s break down what it is and what you need to know.

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What Is the Digital Product Passport?

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The Digital Product Passport is a mandatory digital identity for products placed on the EU market. It is introduced under the ESPR, a framework regulation designed to make products more durable, repairable, recyclable, and transparent.

Textiles and apparel have been identified as a priority sector. The first delegated act for textiles is expected by 2027, with progressive enforcement between 2027 and 2030.

In practical terms, the DPP will require each product to carry structured, standardized data covering its entire lifecycle. This information will be accessible via a digital carrier (such as a QR code, NFC tag, or RFID chip) attached to the product, its packaging, or documentation.

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The passport will include information such as material composition, recycled content, durability performance, environmental footprint, substances of concern, and recycling instructions. It must be accessible at the point of sale, both online and in-store, and remain available throughout the product’s life, including resale and end-of-life stages.

This is a profound shift. Sustainability will no longer rely on claims. It will rely on data infrastructure.

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Understanding the ESPR: Why It Changes Everything

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The ESPR is a framework law. It establishes objectives and principles, while the specific technical requirements will be defined through Delegated Acts for each product category.

The European Commission published its first Work Plan (2025–2030) in April 2025. Textiles and clothing are among the first sectors targeted, while footwear has been excluded from the initial list.

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The Delegated Acts will determine:

• Which products are affected
• The eco-design requirements by category
• The exact format and data structure of the Digital Product Passport
• The required granularity (product level, batch level, or unit level)

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Importantly, a Delegated Act cannot apply earlier than 18 months after entering into force. However, this does not mean brands should wait. Once published, the timeline to comply will be short — and the internal transformation required is significant.

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The Eco-Design Requirements Fashion Brands Should Anticipate

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The Joint Research Centre (JRC) is currently focusing on several core performance indicators for textiles.

Durability is one of the central criteria. Products may receive a numerical durability score reflecting physical resistance and lifespan. Recyclability could also be expressed as a score, potentially without minimum thresholds at first. Recycled content requirements may introduce minimum percentages. Brands will also need to disclose the presence of substances of concern (SoC) and communicate both environmental and carbon footprints in comparison to benchmarks defined under the PEFCR framework.

In addition, the ESPR includes a ban on the destruction of unsold goods.

These are not optional sustainability ambitions. They are emerging market access conditions.

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The 4 Regulatory Milestones of the DPP

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The Joint Research Centre (JRC) is developing the Digital Product Passport (DPP) through a structured roadmap covering scope definition, technical feasibility, eco-design criteria assessment, and final policy scenarios. This work supports the implementation of the Ecodesign for Sustainable Products Regulation (ESPR), adopted in 2024. Textiles are identified as a priority sector in the European Commission’s 2025–2030 ESPR Working Plan. The first delegated act for textiles is expected by 2027, with progressive enforcement thereafter. The JRC’s milestones ensure that both performance requirements and DPP data architecture are scientifically and technically grounded before adoption.

• In early 2024, the first milestone defined the scope and use cases, including textiles and consumer behavior analysis.
• By the end of 2024, technological feasibility and system architecture were evaluated, examining how DPPs could align with eco-design requirements.
• In 2025, eco-design options were assessed from environmental and economic perspectives, including durability scoring and recyclability models.
• By Q2 2026, final policy scenarios and DPP content specifications are expected.

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In other words, the architecture of the DPP is being built now, not in 2027.

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Who Is Concerned?

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All economic operators placing products on the EU market are affected. That includes manufacturers, brands, importers, distributors, retailers, component suppliers, and digital platform providers.

For fashion brands, this means the DPP is not solely a CSR responsibility.

Manufacturers must ensure compliance before market placement. Importers and distributors must verify compliance. Retailers must ensure that product information is visible to consumers. Suppliers must provide traceable and reliable data. DPP platform operators must guarantee hosting, accessibility, interoperability, and data integrity for at least ten years.

This is a cross-functional transformation project.

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Why CSR and IT Must Align Now

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The Digital Product Passport is fundamentally a data governance challenge.

CSR teams are responsible for defining sustainability metrics, validating methodologies, calculating environmental footprints, and ensuring regulatory alignment.

IT teams are responsible for structuring, storing, connecting, and securing data across systems: PLM, ERP, LCA tools, supplier portals, traceability platforms.

The DPP requires:

• Interoperable systems
• Secure and durable data hosting (10+ years)
• Open access for stakeholders
• Cybersecurity and integrity safeguards
• Seamless data flow across the value chain

Without strong IT architecture, sustainability data cannot become regulatory-compliant DPP data.

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Sanctions and Risks of Non-Compliance

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Member States will enforce the ESPR with administrative fines that must be effective, proportionate, and dissuasive. Non-compliant products can be withdrawn from the market. Fraud, data tampering, or intentional omission may lead to increased penalties.

Beyond financial sanctions, the reputational risk is significant. Non-compliance could also result in exclusion from public procurement procedures.

For brands operating in the EU, this is both a compliance issue and a business continuity issue.

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From Greenwashing to Verified Transparency

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The Digital Product Passport resolves the greenwashing vs. greenhushing dilemma.

Under the DPP, sustainability claims will be structured, standardized, and verifiable. Transparency becomes embedded in the product itself. Communication shifts from storytelling to regulated disclosure.

Consumers gain access to reliable data. Regulators gain oversight capability. Brands gain a framework for credible communication.

Trust becomes measurable.

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Why Acting Now Creates Competitive Advantage

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Although enforcement for textiles is expected between 2027 and 2030, preparation requires years of internal restructuring.

Brands that start now can:

• Improve data quality and traceability
• Optimize product design based on durability and recyclability
• Anticipate recycled content thresholds
• Align supply chains before regulatory pressure intensifies
• Turn compliance into differentiation

Those who wait risk rushed implementation, higher costs, and operational disruption.

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How Fairly Made Supports Your Digital Product Passport Readiness

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Preparing for the Digital Product Passport starts long before the Delegated Acts are published. It requires one essential foundation: reliable, structured, and centralized product data across the value chain.

Fairly Made supports fashion brands by organizing and consolidating traceability data at product level, enabling clear visibility over supply chains, material composition, and production stages. This structured data foundation allows brands to calculate environmental impacts in alignment with European methodologies and anticipate upcoming requirements, including durability, recyclability, recycled content, and footprint disclosure obligations.

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Beyond data collection, Fairly Made actively contributes to European discussions on environmental labeling and DPP implementation. Our digital passport solution is designed to serve as a robust operational base, allowing brands to transition smoothly toward full DPP compliance once Delegated Acts formally define the technical specifications.

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By centralizing traceability and impact measurement today, brands reduce future compliance risk and implementation costs. The platform transforms fragmented sustainability efforts into standardized, audit-ready, and regulation-aligned product information.

In short, Fairly Made enables fashion brands to move from sustainability ambition to structured and future-proof data infrastructure.

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