In July 2024, the EU’s Ecodesign for Sustainable Production Regulation (ESPR) officially came into force, replacing the previous Ecodesign Directive. One of the key changes resulting from the ESPR is the introduction of Digital Product Passports (DPPs). These “digital identity records” will collect and share data about a product and its supply chain across the entire value chain, requiring considerable technological investment from both the European Commission and all in-scope businesses operating under its jurisdiction.
While many aspects of DPP policy are still being defined, and further adjustments are possible (as seen with recent Omnibus reforms for CRSD/CSDDD), preparatory work for priority sectors like textiles is already underway. Regulations on key elements of the DPP are expected to be passed by the end of 2025. By late 2027, fashion brands will need to have DPP-compliant systems in place to ensure full product traceability and transparency. That means that businesses will need a firm handle on their data well before then, along with a clear plan for how they will collect, record, and disseminate all the information required to maintain a centralised, accessible digital identity for their products.
Despite the nearing deadlines, there’s still much we don’t know about DPPs. Key technical specifications, including precise data formats, interoperability standards, and the IT infrastructure for the DPP system, are still under development. Questions remain around enforcement of regulation, data security, the role of third-party platforms, and expectations for how far traceability must extend across supply chain tiers.
What we do know, however, is that the DPP is on its way, and it will fundamentally reshape how fashion brands and retailers handle product data. Even without every detail finalised, it’s clear the future will require greater supply chain transparency, more structured data, and the ability to connect that data to a specific product at every stage of its lifecycle. In this evolving environment, preparation is key. You don’t need to have all the answers just yet, but it's important to start asking the right questions and take action now.
Current timelines
Though the ESPR was officially adopted in July 2024, the DPP will not be fully implemented until 2030. In the interim, a number of key activities must occur across government and businesses to ensure an effective rollout. As a priority sector, the fashion industry will need to respond at an accelerated pace to meet these requirements.
July 2024: ESPR entered into force, and the Ecodesign Forum was established to provide governance and oversight for sustainable product standards, including the DPP.
April 2025: The first ESPR Working Plan was published. This plan identified six key product groups, including textiles/apparel, and a set of horizontal legal requirements around repairability and recycled content for energy and electrical products.
Mid-2025: Legislation is expected to be passed that will enforce the ban on the destruction of unsold goods (with specific exemptions to be defined).
Late 2025: Regulations on key elements of the DPP will be passed, including the establishment of a registry, and rules for product identifiers, service providers, and data carriers.
Q4 2025 - Q1 2026: The first set of measures for prioritised sectors, including textiles, will be adopted.
Late 2027: The first product-level requirements under the DPP will apply. By this time, fashion brands must have DPP-compliant systems in place to ensure full product traceability and transparency.
2030: All in-scope sectors and organisations are expected to be DPP compliant and fully integrated into the Commission’s centrally managed system.
How to future-proof your organisation to meet DPP timelines
Based on our engagement with retailers on early legislation compliance, we've developed several recommendations to ensure your brand is data-ready for DPP compliance, even as legislation evolves.
1. Understanding scope and strategy
Begin by clarifying your goals. Are you aiming for basic compliance with DPP requirements, or do you want to use the DPP to lead on transparency and sustainability in fashion? Identify which of your product categories are most likely to be impacted first. Consider what sustainability frameworks you already align with and how they can support your data strategy.
2. Mapping your existing systems
Your product data likely resides in multiple places: Product Lifecycle Management (PLM) systems, Enterprise Resource Planning (ERP), supplier portals, spreadsheets, and possibly carbon accounting or traceability platforms. Review how these systems communicate. Can they generate structured, machine-readable data formats like JSON or XML? Do your SKUs provide a solid foundation for assigning a unique identifier to each product? You'll need that to link every DPP to the correct item.
3. Evaluating data quality and availability
DPPs require rich, verifiable data: material composition, fibre origin, country of manufacture, CO₂ footprint, chemical treatments, care instructions, and end-of-life guidance. Ask yourself: Do we have this data today, and at what level of granularity? Is it per batch, per style, or per individual unit? Can it be trusted? How clean, complete, and up-to-date is the data across your product portfolio? You'll need to identify gaps, especially in areas like Tier 3 material sourcing or water impact data, and plan to address them.
4. Assessing data governance
Identify who internally owns and is responsible for product data - sourcing, design, compliance, or sustainability? A DPP may require data from various departments. For example, product care and repair data will likely involve both product and design teams, while manufacturing and import data will be held by procurement teams. Since this data needs to be unified into a single digital product (the DPP), it's important to have a clear understanding of who is responsible for managing and quality checking this data. This includes escalation protocols for instances where data is absent or incorrect. DPPs will often require exposing certain product attributes publicly (e.g., via QR codes), so privacy, IP protection, and data accuracy all need to be addressed. Consider whether you have agreements in place with suppliers that allow for upstream data sharing, and how you’ll manage confidentiality concerns here as well. Collectively, these changes will ensure teams are working towards a unified goal under clearly defined processes, while minimising potential impacts on core retailing activities.
5. Engaging your supply chain
Fashion supply chains can be fragmented and complex. To meet DPP requirements, you’ll likely need to trace beyond Tier 1 to the material, dyeing, or even fibre processing stages. Start by identifying where your current visibility ends. Are your suppliers digitally mature? Can they provide the necessary documentation and structured data formats? You may need to support them with onboarding tools or collaborate on a common data platform to ensure compliance throughout the chain. Ensure your suppliers are engaged in this conversation, as they will likely be involved in gathering data upstream to support internal traceability activities.
6. Bake in flexibility through incremental changes
As the Commission continues to refine regulation on key elements of the DPP, guidance and technical requirements for ensuring compliance are expected to change; similarly, the technological specifications of the DPP have not yet been defined. Recognising this ensures that any investment made into enhancing your data landscape does not constrain your organisation in a costly transformation that will be difficult to pivot from. Align teams on a new data management approach and begin with the implementation of simple changes such as a standardised data collection approach, while holding off on more costly, infrastructural changes.
7. Planning for lifecycle integration
The DPP doesn’t end at the point of sale; it follows your product into the circular economy. Do you have the infrastructure to update the passport after repair, resale, or return? Can your platforms track customer behaviour or manage reverse logistics? Think about how you’ll enable consumers, recyclers, or service providers to access and potentially edit data as your products move through use, repair, and end-of-life stages.
8. Drive momentum through industry-wide collaboration
The introduction of DPPs marks a system-wide change aimed at enhancing traceability and driving a transition towards more circular business models. By engaging in industry-wide forums, businesses can play an active role in developing innovative solutions that will ensure a smooth transition to DPPs. Some early opportunities include: influencing sector-specific DPP data requirements, defining a standardised language for interoperability, or partnering with a third party supplier to pilot new technology or approaches. Such engagement can both lower the collective cost of DPP compliance for your industry and give you the competitive advantage as you play an active role in shaping new products and solutions.
Conclusion
The introduction of Digital Product Passports under the EU’s Ecodesign for Sustainable Products Regulation marks a defining moment for the fashion industry. While the road to full compliance is still being paved, the direction is clear: a future where product transparency, sustainability, and traceability are non-negotiables.
For fashion brands, this is not just a compliance challenge, but also a strategic opportunity. Those who begin laying the groundwork now will likely be better positioned to meet regulatory deadlines and lead in a market that increasingly values accountability and circularity. By investing early in data systems, governance, and supplier engagement, brands can build resilience, foster innovation, and set themselves apart in a rapidly evolving landscape. The time to act is now.
Ready to unlock compliance value while keeping costs under control? Get in touch to find out how we can help you prepare, implement smartly, and future-proof your organisation for the demands of DPP.
