How Can You Prepare Your Fashion Brand for the Digital Product Passport (DPP)?

Last updated: November 17, 2025

The EU is moving closer to making Digital Product Passports a reality for textiles. In its 2025–2030 Work Plan, the Commission placed apparel at the top of the priority list, with a delegated act scheduled for 2027. Once adopted, brands will have at least 18 months before the new rules begin to apply.

What is the Aim of the Digital Product Passport (DPP)?

The EU's Digital Product Passport aims to advance transparency and sustainability by providing relevant information to downstream industry stakeholders, enabling circularity to make fashion value chains sustainable. It promotes sustainable manufacturing, extended product lifetimes and improved end-of-life handling of products in the EU. A DPP also enables authorities to check a brand's regulatory compliance, and at the same time helps consumers to make well-informed, sustainable choices.

But what exactly are the requirements, and when will they be enforced? Time for an overview of what we already know to help you prepare for DPP regulations.

What is the DPP and what Technology is Needed?

A Digital Product Passport is essentially a digital profile of each product. It brings together key information about traceability, sustainability, and circularity in one structured place. The passport is connected to a unique identifier that can be accessed through a data carrier, like a QR code printed on the label or packaging.

By scanning it, stakeholders across the value chain, from suppliers to recyclers and even end consumers, can access the data they need to understand where the product came from, how it was made, and how it can be cared for, reused, or recycled.

Who Does the DPP Impact?

Manufacturers, importers, distributors, material suppliers, service and repair professionals, refurbishers, recyclers, online marketplaces and dealers, public authorities, and consumers all interact with passported data according to access rights defined in product-specific rules.

The Road Toward a European Digital Product Passport

European Green Deal (2019): Launched in December 2019, the European Green Deal set the EU’s long-term vision for reaching climate neutrality by 2050. It established a pathway for a fair and competitive economy that grows while reducing environmental impact and driving a circular society.

Ecodesign for Sustainable Products Regulation (ESPR): The ESPR, proposed in March 2022 and officially adopted in June 2024, is now the cornerstone of Europe’s sustainable product policy. In force since July 2024, it provides the legal framework for making products in the EU more durable, repairable, recyclable, and resource-efficient. It also sets the stage for Digital Product Passports by requiring delegated acts for specific product groups.

EU Digital Product Passport (DPP): Under the ESPR, the Digital Product Passport is becoming a key tool to accelerate circularity. It is designed to centralize essential product information, covering traceability, sustainability, and end-of-life handling, and make it accessible throughout the value chain. By linking data to a scannable code (for example, a QR code on a garment label), the DPP supports transparency, helps brands comply with new rules, and empowers consumers, repairers, and recyclers to make informed decisions.

The EU Timeline for the DPP

The digital collection of data is a lengthy process that brands need to start now to ensure compliance by the time it takes effect. The fashion industry is one of the first sectors targeted by the European Union.

• April 2024: The European Parliament holds a plenary vote on the final text of the Ecodesign for Sustainable Products Regulation (ESPR), formalizing the framework that enables the Digital Product Passport (DPP) and related sustainability measures.

• July 2024: The ESPR officially enters into force. The Ecodesign Forum (the expert group that supports implementation) is set up, with preparatory work through late 2024 and its first meeting held in February 2025. Brands should begin organizing data and transparency practices in line with future requirements.

• Q3 2024: The Ecodesign Forum is formally put in place and readies its work programme, feeding into stakeholder discussions on upcoming delegated acts and DPP design.

• Late 2024/2025: The Forum convenes and advances technical discussions that underpin delegated acts (including those relevant to the DPP) and other ESPR initiatives.

• Q2 2025: The first ESPR & Energy Labelling Working Plan (2025–2030) was adopted on 16 April 2025. It sets priority sectors and indicative timelines: textiles/apparel are prioritized with an indicative adoption in 2027, while footwear is covered by a dedicated study under the plan.

• Mid-2025: The ESPR’s ban on destroying unsold goods takes effect on 19 July 2026 for apparel, accessories and footwear. Micro and small businesses are exempt; medium-sized companies are covered from 19 July 2030.

• Late 2025: Regulations on key elements of the DPP will be passed. These regulations will include the establishment of the DPP registry, rules for service providers, product identifiers, data carriers, and digital credentials.

• Q4 2025–Q1 2026: Preparatory work for priority sectors, including textiles, continues through 2025–2026. The first apparel-specific delegated act is targeted for 2027, laying the groundwork for DPP compliance.

• 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.

• Full implementation by 2030: The DPP will be fully implemented by 2030. Brands need to begin the digital collection of product and supply chain data now in order to ensure compliance when the DPP takes full effect.

Digital Product Passport Requirements

The EU is finalizing the DPP’s product-group data lists and definitions. These will be set in delegated acts (such as the upcoming textiles act) and supported by ongoing standardization efforts.

The DPP is likely to include:

• Product’s technical performance (e.g. durability, reliability)

• Materials and their origins (e.g. recycled content, presence of substances of concern)

• Repair activities (e.g. possibility of maintenance and refurbishment, reparability)

• Recycling capabilities (e.g. possibility of recovery of materials)

• Lifecycle environmental impacts (e.g. environmental impacts, including carbon and environmental footprint)

By using Retraced, you're already taking the first step towards meeting the DPP requirements. As new aspects and requirements are released, our Product Team will promptly integrate them into the platform. We'll ensure that by the time the DPP is implemented, you and your data will be ready to showcase on our Digital Product Passport feature.

What information will likely be in an apparel DPP?

Delegated acts will define the final fields, but expect coverage across durability and repair, material composition and origins (including recycled content and substances of concern), end-of-life handling and recycling, and lifecycle performance.

New Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear provide a harmonized method to measure environmental impacts, and will underpin data models for claims and comparisons.

What Will Companies Have to Do to Prepare for the DPP?

Make sure that:

• A product passport exists, and it is in compliance with essential requirements established in articles 9 and 10 of the ESPR – exceptions are possible.

• The product passport is complete, meaning it includes all the mandatory information listed in the corresponding product groupspecific Delegated Act.

• The information included in the passport is authentic, reliable and verified in accordance with requirements established in the corresponding product group-specific Delegated Act.

• A back-up copy of the DPP is stored by a (certified) third-party product passport service provider.

• A copy of the data carrier or unique product identifier are made available to dealers and online marketplaces selling the corresponding product.

Ten practical steps to start now

1. Map your identifiers and labels: Decide if you will identify products by item, batch or model. Plan how that ID appears on the product. Use a 2D barcode such as a QR or Data Matrix that can live alongside today’s retail barcodes (EAN and UPC) during the transition to 2D.

2. Organize product and materials data: Create a clear bill of materials for each style. Record fibre and trim composition, evidence of recycled content, supplier references and any information on restricted substances you may need at product or component level.

3. Get footprint ready: Align your data with the EU’s Product Environmental Footprint rules for Apparel and Footwear (PEFCR). That helps you calculate carbon and other impact metrics consistently across styles and seasons.

4. Document repair, care and durability: Write practical repair instructions, list which spare parts are available and for how long, and provide care guidance that can appear in the Digital Product Passport.

5. Set a policy for unsold goods: From 19 July 2026, the EU bans destroying unsold apparel, accessories and footwear. Micro and small businesses are exempt. Medium-sized companies are covered from 19 July 2030. Put controls in place now and plan your yearly disclosure process.

6. Prepare for the EU DPP registry: Design how you will register passports once the EU registry goes live. Make sure your process can store and share the unique identifier that customs will check when needed.

7. Choose an architecture that scales: Use a simple web-based setup to create and serve passports so stores, partners and customers can access them easily. Follow current public guidance and keep room for more advanced options later if required.

8. Tighten governance and access: Assign owners for each data set, keep audit trails and define who can create or update passport records. Check that privacy and security are covered.

9. Run a small pilot: Start with a capsule of representative styles. Test the full flow: create IDs, generate passports, activate codes in retail and use the data after sale.

10. Train teams and suppliers: Align design, development, sourcing, compliance and ecommerce on the same process. Share the workflow, the deadlines and what “good data” looks like for a passported product.