DPP Regulatory Design Meets Fashion Reality: How You Can Navigate Data, Deadlines and Delegated Acts

TL;DR: The EU Digital Product Passport (DPP), mandated under the ESPR, will require fashion brands to share verified, traceable product data through a scannable digital record. It will have to cover materials, sourcing, durability, repairability, and environmental impact.

Textiles must comply by 2027, all products by 2030. Success demands cross-team collaboration (ESG, procurement, IT, compliance), interoperable systems (ERP, PLM, traceability), and secure, structured supplier data.

Early adopters can cut costs, build trust with consumers, design for circular business models, and set the standard for transparency in fashion.

The EU’s Digital Product Passport (DPP), mandated by the ESPR, will redefine how fashion brands manage product data, compliance, and collaboration. As the Delegated Acts are released, which create requirements specific to each product group, the regulatory environment can seem complex, and even overwhelming.

This article breaks down what the ESPR means in practice — we turn complex legislation into actionable steps for procurement, sustainability, compliance, and IT teams. Keep reading to learn how you can stay agile, creative, and turn compliance into a long-term competitive advantage. For more information on the DPP, see our article on how to prepare.

Inside the Digital Product Passport Revolution

DPPs are the EU’s way of making product data structured, comparable, and accessible. Fashion is an early test case, but DPPs will soon be extended to all products sold in the EU. DPPs will define the fashion industry of tomorrow. You'll now need data readiness as much as creativity to keep your brand on the market.

The European Green Deal Sets the Stage for a New Kind of Fashion Governance

The EU Green Deal set an ambitious target: climate neutrality by 2050. Under this legislation, the European Commission issued the Ecodesign for Sustainable Products Regulation (ESPR), which mandates DPPs for all products. Textiles, a highly polluting sector due to poor end-of-life management, have been prioritized with earlier deadlines. DPPs will be required for textiles in 2027, and all products in 2030. Now, to sell in the EU, brands must prove sustainability, not just claim it.

How the EU Digital Product Passport Will Reshape Product Transparency and Trust

The DPP is like metadata for garments. With a quick scan of a QR code, consumers can see information about the product, what it's made of, where the materials come from, recycled content, REACH compliance, repairability, water and carbon footprints, and end-of-life recommendations. This creates consumer-facing transparency and trust, combats greenwashing, and supports circular programs.

Decoding DPP Regulatory Design in Fashion

The ESPR sets performance requirements on durability, recyclability, and REACH substances. The DPP provides for digital access to that information for the consumer. Over the next two years, the Delegated Acts will define which specific fields are required for textiles.

DPP: Roles and Responsibilities

From ESPR to DPP Regulation: Here's What Every Brand Should Know Before It’s Mandatory

To get ahead of the DPP regulation, we recommend the following timeline. If you wait too long, you'll risk sales disruption and emergency (expensive) IT projects.

DPP Preparation Timeline:

• 2025: assess internal readiness, map product and supplier data, internal audits

• 2025-2026: fill gaps from readiness assessment, start tracing

• 2026-2027: run pilots

• 2027-2030: scale DPPs through portfolio

What the Requirements of the DPP Really Mean for Your Company

DPP requirements turn product data into a regulated asset. You'll need to provide multi-tier, traceable, validated lifecycle information for every item on the EU market. Implementation requires alignment between ESG, sourcing, compliance, and IT. This means integrating ERP, PLM, and traceability systems, as your data will be scrutinized by both auditors and consumers.

Turning Legal Language into Practical Actions Across the Supply Chain

So, you're ready to get started? Here's a checklist to help you translate legalize into tangible actions for your company:

• Map suppliers beyond Tier 1

• Define who owns the data

• Standardize formats (material composition, certificates, REACH)

• Send out supplier questionnaires

• Monitor Delegated Acts closely

• Run small-scale pilot DPPs on high-volume / high-impact products

• Document compliance progress for investors and partners

• Schedule quarterly internal reviews to stay aligned with EU updates.

Building a DPP System That Works for Fashion

A future-proof DPP system needs centralized, interoperable data that connects ERP, PLM, LCA, and traceability tools, with tiered access and encryption. Automation should replace manual supplier data capture, and traceability checkpoints should be embedded early in the creation process to keep your operations running smoothly. When choosing a platform, prioritize scalability. In that way, you can make digital transparency a marker of quality, not a drag on creativity.

For example, when collecting data from suppliers, have them upload certifications (e.g., GRS, OEKO-TEX) and facility details through a structured portal. The data will then be validated, standardized, and synced to the product record for compliance and DPP use.

How to Use Data on Product and Material Sourcing the Right Way

Effective DPP procurement begins with consolidating supplier data across tiers, verifying claims through audits and certifications, and using impact metrics like carbon, water, and recycled content as a foundation for product design. This data should include certifications like GOTS and GRS, supplier location data, electricity mix for each facility, and materials breakdown. Repair guidance, resale insights, and retailer data embedded in the consumer-facing QR code will drive engagement and trust. You can use this product tracking as proof of brand integrity and to improve after-sales service. You can protect sensitive supplier data with controlled access while still improving your CSRD and ESG reporting.

Designing for Circularity Starts at the Data Level

If recyclers, resellers, and repair services don’t get the right data, circularity doesn’t work. If you use this data to help you plan, you'll make better material choices, reduce waste, and make CSRD/EUDR reporting easier.

How Digital Product Passports Enable Smarter Recycling and End-of-Life Decisions

DPPs store verified material composition and disassembly data, giving recyclers direct access to accurate information. This facilitates automated sorting, fiber recovery, repair, and reuse. By improving traceability of recyclable inputs, DPPs reduce landfill waste and support circular business models built on standardized, interoperable product data.

From Compliance to Competitive Edge

You can adopt DPP early and turn regulatory compliance into a competitive advantage. Verified product data strengthens retailer and investor trust, reduces audit and certification costs, and makes your brand stand out. When you share compliance data through a digital tag, it powers authentic storytelling, demonstrates accountability, and builds long-term loyalty by turning transparency and social responsibility into part of the customer experience.

Bridging the Gap Between Manufacturers and Consumers

Digital tags make supply chains visible, providing proof of ethical materials, regional compliance, and production storylines rooted in facts. From fiber to assembly, consumers can instantly trace where and how a product was made. This transparency reinforces supplier accountability, deepens emotional and ethical trust, and aligns brand narratives with verifiable information rather than unsubstantiated marketing claims.

The Role of Technology Platforms in DPP Compliance

Technology platforms are central to DPP compliance, required for structured data exchange, supplier onboarding, audit trails, and interoperability with EU systems. Choosing the right partner is essential to align with Delegated Acts, reduce fragmentation, and keep data verified. A trusted compliance partner can simplify onboarding and updates and manage ongoing verification. Choosing a scalable, collaborative compliance partner turns regulatory complexity into operational simplicity and strengthens collaboration.

Fashion’s New Era of Accountability

DPPs usher in a new era of accountability by making proof-based sustainability mandatory at product level. Brands must demonstrate verifiable origin, durability, safety, and recyclability against EU benchmarks. You can't just claim environmental responsibility, you have to show it. Non-compliant products risk market exclusion. This shift from greenwashed marketing to measurable, enforceable data across fashion value chains is permanent.

When Data Protection Meets Product Transparency

The DPP requires secure transparency. Sensitive supplier data must be shared with encrypted, tier-based access to protect intellectual property while meeting regulatory requirements. Compliance means balancing openness with confidentiality — providing verifiable product data without exposing trade secrets or compromising supplier trust.

Balancing Openness With the Responsibility to Safeguard Sensitive Information

Does maintaining this balance seem daunting? Here is a checklist to help you protect supplier data while complying with regulations:

• IP protection

• Tiered access levels

• Encrypted, anonymized data

• Limit publishing to EU requirements only

• Build trust by combining openness with responsible data governance.

What Comes After the DPP Becomes Mandatory

After 2030, the DPP will be required for all ESPR product categories with increasing alignment with the CSRD, EUDR, and the Green Claims Directive. Delegated Acts will continue evolving, so you'll need to continuously monitor the regulatory landscape and update your systems accordingly. Adopting DPP early will help you adapt more quickly and put you in a position to influence future EU data and transparency standards.

You can prepare for the next phase of the European circular economy by aligning traceability systems with CSRD and ESG reporting, creating cross-team governance, and training teams to manage DPP data long-term. Get started now to prepare your teams and become a leader on circularity.

The Future Is Transparent, Not Trend-Driven

DPP signals a major change in the fashion industry. Transparency, not trends, is the new luxury. Verifiable product data will become part of your brand identity, bringing sustainability and creativity together. The DPP is making sustainability into a standard by which all brands will be measured. It shifts the industry from greenwashed claims to verified environmental responsibility, supporting long-term value, traceable storytelling, and a more resilient, accountable modern fashion.

In Summary

The DPP marks a permanent shift in the fashion industry, from voluntary sustainability claims to verified, auditable proof. By 2027 for textiles, you'll need structured data on origin, materials, durability, and environmental impact. Compliance requires aligned teams, interoperable systems, and reliable supplier data. While challenges include data silos, supplier readiness, and confidentiality, secure standards and phased rollouts make them manageable. Start early to make reporting easier, improve supplier collaboration, strengthen credibility, and turn transparency into a competitive advantage. DPP is a compliance task, as well as your ticket to trust, resilience, and long-term value.

Q&A

What is the DPP regulation?

The EU’s Digital Product Passport, mandated by the Ecodesign for Sustainable Products Regulation (ESPR), is a digital record with verified product data, required for all goods sold in the EU by 2030.

What is DPP compliance?

Complying with the DPP means meeting EU obligations to create, maintain, and share accurate DPP data for every product sold on the EU market, interoperable with EU registries.

What is an example of a DPP?

In the fashion industry, an example is a pair of jeans with a QR code that links to verified details, including cotton origin, recycled content, factory and dyeing location, carbon and water impact, and recycling instructions.