A Quick Dive into the EU Digital Product Passport (DPP)

Of all the endeavours undertaken by the European Union to facilitate 
sustainability and a circular economy, the Digital Product Passport (DPP) appears to be the most tangible solution to address supply chain and 
transparency issues. The DPP is part of the Ecodesign for Sustainable Products Regulation, which came into force on 18 July 2024, replacing the current Ecodesign Directive 2009/125/EC, and is specifically designed to meet consumer demands for transparency and resolve the current lack of reliable product data.

What is Digital Product Passport?

The Digital Product Passport (DPP) is a digital record of a comprehensive set of data and information on a product’s origin, materials, environmental impact, and disposal recommendations. This aligns with the objectives of the Greenwashing and Green Claims Directive on the verifiability of sustainability claims, which include promoting the durability, reusability, upgradability, and reparability of products.
As the Greenwashing and the Green Claims Directive practically imposes third-party verification for any sustainability claims, DPP will make data and information about a product available to every consumer, free of any additional charge, and for the duration of the product’s expected lifetime. Customers will access the Digital Product Passport through a data carrier, such as a QR code on a product tag, and unlike traditional labels, data and information on DPP can evolve and be updated throughout the product’s life, from production to end-of-life processing. For consumers, this data and information system will provide protection against greenwashing and misinformation. For brands and producers, this is a game-changer that will level the playing field on environmental performance. Brands and producers that fail to meet specific criteria are expected to be singled out at the earliest stages of competition.

Textiles are at the forefront of the regulations, alongside industrial batteries and consumer electronics. All textile and apparel products, either manufactured in or exported to the EU market, will be subject to the Digital Product Passport regulations. According to Asquith-group, ‘textiles’ should include t-shirts; shirts and blouses; sweaters and mid-layers, such as fleeces, cardigans, hoodies, and sweatshirts; jackets and coats, including blazers, parkas, outdoor vests, and suit jackets; trousers and shorts, including jeans, capri pants, outdoor leg-wear, and dress leg-wear; dresses, skirts, and jumpsuits; leggings, stockings, tights, and socks; underwear; swimwear; and textile accessories like headwear, scarves, ties, belts, gloves, and mittens. Certain textiles, such as smart textiles, electronic or e-textiles, personal protective equipment (PPE), medical devices, and textile fabrics, yarns, and fibres, will most probably be excluded from the DPP requirements.

Textiles at the forefront

Technical standards for the DPP are expected to be finalised by the end of December 2025. For textiles, the DPP will become mandatory by late 2027 or early 2028, which leaves brands and producers approximately two years to prepare and adapt. According to Charles Newman at Resource.co, the best practice would be for brands to launch a ‘minimal and simplified DPP’ by 2027, which shall include essential product information and basic environmental impact data. By 2030, this should evolve to include more comprehensive supply chain information and after-sales tracking. ‘Full circular DPP’ should be reached by 2033, with complete lifecycle data, closed-loop material flows, and detailed circularity performance indicators.

What information will be included in DPP?

It is speculated that the Digital Product Passport shall include around 16 categories of information. According to official sources as of 2024, the following data and information are expected to be included as standard:

Product Identification, which means unique product identifiers such as QR code.

The product’s technical performance, including detailed information on functional attributes such as breathability, water resistance, and stretch, details on any safety certifications or standards the product meets (e.g., flammability tests or chemical safety), and information on how long the textile product is expected to last under normal usage conditions.

Materials and their origins, including detailed information on fabrics and components. This is where vegan and sustainability certifications on material composition, origin, and farming practices will be listed. And since the competition between brands producing the same type of t-shirts or bags, will eventually narrow down to design and quality (this is where the later is going to be expressed by the number of certifications listed) – and the credibility of the institutions these certifications represent.

Repair activities, including instructions and guidelines for product care, repair, and maintenance, including washing, drying, and ironing recommendations. Since product durability has already been thrust into the spotlight as a major factor in the global fight to reduce consumer waste, brands and manufacturers are expected to provide special instructions on how to sustain or improve a product’s optimal durability, or at least how to avoid premature disposal.

Recycling capabilities, including instructions for recycling, or responsibly disposing of the product, for both end-consumers and recycling facilities. Following California’s SB707 act and the UK’s efforts to establish end-of-life disposal responsibility on manufacturers, it is reasonable to speculate that the EU will adopt and mandate specific end-of-life treatment policies or requirements. This will likely boost the popularity of everything vintage and repurposed, particularly resale platforms, recycling and ‘up-cycling’ programs.

Lifecycle environmental impacts, including a comprehensive assessment of a textile product’s environmental footprint throughout its entire lifecycle in accordance with ISO 140, ISO 14044 and ISO 14067. Therefore, brands are strongly recommended to implement Life Cycle Assessment (LCA) for their products as early as possible. LCA validates ‘green’ claims for a particular product, and provides the necessary data for it to comply with environmental regulations. LCA also identifies hotspots of environmental impact, guiding sustainable decisions, and supporting the shift towards a circular economy in the fashion industry. By quantifying environmental KPIs, companies can make more informed decisions about sourcing and managing suppliers that comply to ever stricter sustainability regulations.

The bottomline

Regulations aside, there’s an aura of expectation that DPP will prove to be the tool that will pick up where Direct-to-Consumer left off, and build engagement and eventually trust between consumers and brands. As an additional platform for providing all solid facts and information that would otherwise not fit into catchy commercial campaigns, brands might also utilise DPP to provide early access to limited collections, which could further a sense of exclusivity, as well as loyalty towards a brand. Furthermore, the Digital Product Passport (DPP) is an almost-perfect tool to tackle the counterfeit issue in the resale market. With the high complexity of information included in each DPP, they are expected to be particularly challenging to fake, serving as an ultimate tracking tool for a genuine product, cradle to grave.

For consumers, the DPP will serve as a reliable fact sheet about a product’s origin, materials, and the manufacturing process that produced it. Customers can track the entire lifecycle of a product, from raw material extraction to disposal, ensuring that ethical and sustainable standards are followed. They can also access information about care instructions, durability, and potential environmental impact, which will help them choose products that align with their values (and clothing care skills!). This is a huge shift from greenwashing campaigns to a set of verified, real-time, instant access data. And yes, even if this will eventually require consumers to get more educated, in the end, it is also these very consumers that will benefit from informed purchasing decisions.

Further reading:

https://www.asquith-group.com/eu-digital-product-passport-for-textiles-to-be-mandatory-in-2028/

https://www.carbonfact.com/blog/knowledge/lca-fashion-textile

https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en

https://resource.co/article/european-parliament-research-puts-forward-requirements-digital-product-passport-textiles#:~:text=A%20DPP%20for%20textiles%20is,impact%2C%20and%20social%20responsibility%20metrics.

https://data.europa.eu/en/news-events/news/eus-digital-product-passport-advancing-transparency-and-sustainability#:~:text=EU’s%20Digital%20Product%20Passport%3A%20Advancing%20transparency%20and%20sustainability,-How%20to%20leverage&text=Starting%20in%202024%2C%20the%20European,Digital%20Product%20Passport%20(DPP).