The Digital Product Passport, or DPP, is one of those phrases that has moved rather quickly from “something coming in the future” to “something we probably should understand.”
And yes, it involves data.
Quite a lot of it.
But the DPP is not simply another digital label to add to a product. Under the EU's Ecodesign for Sustainable Products Regulation (ESPR), it is intended to make relevant product information accessible throughout a product's lifecycle and improve transparency across the value chain.
For fashion brands, the important question is therefore not only:
“How will we create a DPP?”
It is also:
“Do we actually have the information we will need?”
That is where things become interesting.
What is a Digital Product Passport?
A Digital Product Passport is essentially a digital record connected to a physical product.
The information will be accessible through a data carrier on the product — for example, a QR code — and can provide information about the product's composition, origin, sustainability characteristics, use, repair, reuse and end-of-life, depending on the applicable requirements.
The DPP is part of the EU's broader move towards more transparent, circular and resource-efficient products. The ESPR framework also requires DPP information to be accurate, complete and up to date.
For fashion, this means that information which has historically been scattered across suppliers, spreadsheets, certificates, product developers and — occasionally — someone's inbox may increasingly need to become structured product data.
And that is probably the less glamorous, but much more important, part of the story.
Why should fashion brands start thinking about it now?
Textile apparel is one of the product groups prioritised under the ESPR for Digital Product Passport requirements. The European Commission currently indicates Q4 2027 for adoption of the textile-specific delegated act. The exact requirements for textiles are therefore still being developed.
Following adoption of an ESPR delegated act, economic operators will have a transition period of at least 18 months. This means that if the textile delegated act is adopted as currently planned in Q4 2027, mandatory application would not be expected before roughly mid-2029 — although the timeline can change as the legislative and technical work progresses.
So there is time.
But that does not mean brands need to sit around waiting for the final legislation.
In fact, waiting for the final spreadsheet of requirements before looking at your data may be a slightly uncomfortable strategy.
The more useful question is:
What information do we already have, and where are the gaps?
Because collecting product information is not necessarily the difficult part.
Finding out that three different suppliers use three different definitions of “recycled,” nobody knows which version of a material specification is current, and the factory has never recorded the information you suddenly need?
That is where the fun begins.
What about bags and accessories?
This is one area where it is worth resisting the temptation to give a simple answer.
The European Commission currently identifies textile apparel as the priority product group for the textile-specific ESPR delegated act. The final product scope and exact DPP requirements are still being developed.
Some bags and accessories may fall within existing textile-product definitions depending on their composition, but that does not automatically mean that every bag will be covered by the future textile DPP.
In other words, if you make handbags, backpacks or accessories, don't assume either that you are definitely exempt or that you definitely need a DPP today.
The future delegated act will determine which products are covered and what information they will need to provide.
For brands working with bags and alternative leather materials, this is particularly worth watching as the textile framework develops.
Is there an exemption for small businesses?
Another common question is:
“But we're a small brand. Surely this doesn't apply to us?”
At the moment, there is no general SME exemption from DPP requirements under the ESPR based simply on turnover, number of employees or production volume.
The DPP obligations will primarily apply to economic operators placing products within the relevant scope on the EU market. Depending on the circumstances, this can include manufacturers, producers and importers. Other operators in the supply chain may also have obligations to provide or make relevant information available.
The ESPR does recognise that implementation can be more challenging for SMEs and micro-enterprises. It therefore provides for support measures, guidance and tools to help smaller businesses comply.
So, for now:
Small does not mean exempt.
It means that preparation and support may be particularly important.
And there is currently no simple “below €X turnover”, “under X employees” or “below X units per year” threshold that generally removes a business from DPP obligations.
The important threshold is therefore not simply the size of the company, but whether the product falls within legislation requiring a DPP.
Material information will matter
For fashion products, materials sit right at the centre of the product story.
A garment may contain a main fabric, lining, thread, labels, buttons, zips, coatings, prints and other components — each potentially involving different suppliers and different data.
Depending on the final requirements, DPP information for textiles may include product identification, fibre composition, origin, information relating to use and maintenance, and information supporting repair, reuse, recycling and end-of-life processes. Traceability and identification of relevant economic operators are also part of the developing framework.
For brands working with new bio-based materials and alternative materials, this makes material documentation particularly important.
Knowing the name of a material is not necessarily enough.
You may also need to understand its composition, origin, relevant certifications, processing, performance characteristics and other information needed to substantiate the claims made about it.
In other words, material selection and material documentation are becoming increasingly connected.
Start with the information you already have
Before thinking about technology platforms, QR codes or beautiful digital interfaces, it is worth looking at the less glamorous foundation:
your product data.
Where does it live?
Who owns it?
How complete is it?
How consistent is it?
And can you actually trace the information back to its source?
A useful starting point is to map the information you already collect for a product:
Product identification
Material and fibre composition
Material suppliers
Manufacturing locations
Country or region of origin
Certifications
Relevant environmental information
Care and maintenance
Repair information
End-of-life considerations
Supply-chain information
The precise data requirements will depend on the applicable legislation and the final textile-specific rules, so this is not a definitive DPP checklist. The European Commission is still developing the detailed framework and supporting technical specifications.
Think of it instead as a reality check.
How much do you actually know about your product?
The material supplier is part of the data chain
This is particularly relevant when introducing innovative materials.
A brand may know that a material is “bio-based,” “recycled,” “biodegradable” or “plastic-free.”
But what exactly does that claim mean?
What is the percentage?
How is it verified?
Which component does it refer to?
Is there a certification?
What testing supports the claim?
Does the supplier's technical documentation match the information being communicated by the brand?
These questions are becoming increasingly important as sustainability information moves from marketing language towards documented product information.
For brands working with emerging materials, this means that good material documentation is not simply useful for product development.
It can become part of the wider product data infrastructure.
You don't have to solve the whole DPP today
The textile DPP framework is still evolving, and the final requirements will determine exactly what information brands need to provide.
So no, you don't need to build the perfect DPP tomorrow morning.
But you can start asking better questions today.
What information do we have?
What information are we missing?
Where does our material data come from?
Can we substantiate the sustainability claims we make?
Can we trace our products and their components far enough through the supply chain?
And perhaps most importantly:
Who inside the company is responsible for putting all of this together?
Because the DPP might eventually appear as a very simple QR code.
The work behind that little square is considerably less simple.
Need help preparing?
Substanz supports brands working with new materials, material data and sustainability requirements, helping connect material knowledge with the wider product development process.
DPP preparation starts long before the passport is published. Understanding your materials, identifying information gaps and establishing the right data foundation can make the transition considerably easier.
You don't need to have every answer before you start.
But knowing what you have, what you don't have, and what you need to find out is a very good place to begin.