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This summer, Europe’s landmark Ecodesign for Sustainable Products Regulation (ESPR) became law, kicking off the next phase in a years-long journey toward introducing digital product passports (DPPs) — a digital record that will be required to accompany any goods sold in the European Union by 2030.
It’s hard to overstate the significance for fashion: DPPs will require unprecedented transparency in global supply chains and should foster more robust resale and recycling capabilities for brands and their consumers.
“There’s a stake in the ground — now the clock starts clicking,” says Andrew Xeni, founder and chairman of UK-based fashion brand Nobody’s Child — an early adopter of DPPs — and founder and CEO of tech company Fabacus.
The ESPR replaces Europe’s 2009 Ecodesign Directive, which aimed to reduce the environmental impact of energy-using products like lightbulbs and TVs. The new regulation expands that to 12 “in-scope” consumer goods categories, including textile-based products such as clothing and footwear. The regulation is one in a cluster under the EU’s Strategy for Sustainable Textiles, developed in 2022, to overhaul the linear ‘take, make, waste’ textile sector into a circular one. The strategy’s multiple laws and guidelines govern how products sold on the European market must be designed, made, marketed and disposed of to fit within Europe’s circular economy ambitions.
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ESPR and DPPs have global implications for fashion and beauty brands, as products in any of the 12 in-scope categories sold within the EU will need to be compliant — even if the parent company and its manufacturing facilities are based elsewhere.
For companies to comply, and to produce evidence that they are complying, they will need to collect — and then be able to share externally — data on product-level technical performance, materials and their origins, repair activities, recycling capabilities and lifecycle environmental impacts.
A product’s DPP, where the data will be stored, is key to making it happen.
How DPPs will work
DPPs require three things: a digital data carrier (like a QR code) connected to the product; the data itself; and a decentralised and interoperable IT system that permits access to, and the retrieval of, relevant data.
“Ultimately, consumers are front and centre. [DPP is about] brands sharing data authoritatively with those consumers, but you need the data to be consistent and accurate,” says Robert Beideman, chief product officer at global standards organisation GS1, which sets the foundation for the use of QR codes used to access DPPs.
Fashion brands and retailers that are obliged to maintain DPPs will be liable for ensuring the product data is gathered, stored and available. (For many brands, and smaller ones especially, this data storage and service will probably be provided by third parties.)
In the pilots carried out across fashion to date, each garment has been given a unique identification number, which is attributed to a QR code. The QR code, which contains links to the product on the brand’s website, has been printed on the garment label and sewn in at the Tier 1 garment factory. The QR code is scannable by mobile phone, and the website ‘pulls in’ the permitted data from the source (which will be held in the decentralised and interoperable IT systems once the DPP network is ‘live’).
What the fashion pilots have told us so far
Although the exact requirements are not yet finalised for DPPs, several pilot studies have aimed to establish what is both necessary and possible. The studies have tested the various digital data carriers, how the IT architecture should be structured to facilitate data sharing and which DPP data might be most relevant for consumers.
One such pilot was carried out as part of the Trace4Value project, which brings together stakeholders from various industries to find ways to shift to circular production models. From this pilot, supply chain traceability solution TrusTrace created fashion’s playbook for DPPs.
The pilot coordinated the creation of unique digital IDs and QR codes printed on the labels of over 3,000 products from fashion brands Marimekko and Kappahl. In addition, TrusTrace and the brands established a DPP data template of likely information required in the final DPP stipulations, as well as a proxy IT system to mimic how DPP data could be gathered and shared between stakeholders and with consumers.
“Being part of this project and doing a DPP ‘for real’ was very tempting. It was something we could [see] and scan with a mobile phone — a tangible example,” explains Sandra Roos, VP of sustainability at Kappahl, of the decision to take part.
The pilot found that many brands already held much of the required data across their product lifecycle management (PLM), enterprise relationship management (ERP) and other systems and turned to suppliers or traceability partners to obtain the remaining data. But data gaps exist when it comes to ‘environmental footprint’, repair and recycling — areas that brands have not historically had to track. (The brands taking part in the pilots were forced to leave these as gaps for now.)
Nobody’s Child has conducted multiple DPP pilots led by sister tech company Fabacus. (Xeni, a former garment factory owner and supplier to high street brands, founded Fabacus to offer retailers supply chain and licensing data-management solutions.) The womenswear brand introduced DPPs into 27 garment styles in 2024, integrating data from as far back as Tier 4 — or the raw materials stage — in the supply chain. The brand then collated data throughout the value chain, including the materials, suppliers, compliance, circularity and sustainability.
“Integrating DPPs early on allows us to enhance transparency and traceability, which provides our customers with greater detail of the life of each garment, from the factory to their door,” says Nobody’s Child CEO Jody Plows. “This aligns with our core values of ethical production and sustainability.” She continues: “The launch of our DPP pilot, through the Happy Place by Fearne Cotton collection and our most recent denim collection, delivered key learnings to ensure we can roll out DPPs across all collections by the end of 2024.” Fabacus is also supporting UK supermarket giant Tesco’s F&F fashion brand to trial DPPs.
Elsewhere, the Aura Blockchain Consortium, whose members include luxury leaders LVMH, Prada Group, OTB Group and more, has presented a DPP solution positioned alongside its existing NFT-based ‘digital product twin’ proposition. Although the DPP data requirements for all fashion products will be universal, irrespective of market segmentation, luxury brands have already engaged consumers with digital product IDs via RFID-based product authentication and creative Web3 content.
Benefits beyond governmental compliance
One of the most anticipated applications and benefits that DPPs are expected to deliver is to better equip the industry to meet some of its sustainability targets.
During the lead-up to the ESPR, the European Commission evaluated the circular economy potential of European industries. Textiles stood out as almost entirely untapped. The union’s net-zero target was deemed impossible if the current ‘take, make, waste’ consumption endures — and fashion, which falls under the “textiles” categorisation and whose products often end up in landfills or exported to nations in the Global South, is especially in the spotlight.
A circular model — which hinges on the existence and accessibility of repair, reuse and recycling services — is only achievable if certain design criteria are met, with brands and consumers requiring reliable sources of information to determine whether those are fulfilled, which is where the DPPs come in. They enable people and companies to better identify the materials a garment is made of, for example. Practically speaking, that could mean that people can list garments on a resale website more easily or obtain details of how to best care for or repair a garment by scanning the DPP’s QR code. Similarly, recyclers need information about the components of a product to be able to recycle materials effectively and efficiently, and the QR code should be able to provide that as well.
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Brands taking part in the pilot programmes observed a number of other potential benefits of DPPs. “Integrating DPPs has unlocked new ways for us to engage with customers beyond our direct channels,” says Plows. “For example, when customers purchase our products through multi-brand retailers like Marks Spencer, they may not always have a direct connection to the brand. The DPP’s QR code serves as a bridge, allowing these customers to access product information, sustainability credentials, and the story behind each piece, regardless of where they made their purchase.”
She adds: “This digital touchpoint has allowed us to engage with third-party shoppers, helping them to see our commitment to responsible fashion and build brand loyalty, even when the initial interaction hasn’t happened through our own platforms. This has proven invaluable in creating a more cohesive and consistent brand experience across all retail touchpoints.”
DPPs are “a powerful tool” for consumer engagement, agrees Anja Sadock, SVP of marketing at TrusTrace. The TrusTrace pilot found that DPPs have the potential to create customer value as a part of product storytelling.
“While our favourite garments and shoes and bags hold a lot of value on their own, with the ability to share more data with consumers, you can build richer experiences, more elaborate stories and communities,” Sadock adds. “I don’t think we’ve even scratched the surface of what this will mean [yet], which is understandable as everyone is still in the weeds of how to even get all the data and the infrastructure in place to deliver this.”
“When we prepared the pilot, the full extent of what DPP would offer wasn’t clear yet,” says Masaki Kato, project manager of Marimekko’s cross-function innovation team. “When we were able to share the concrete consumer interface with other teams, it sparked interest and the marketing potential for DPPs was seen.” Sustainability manager Marjut Lovio adds that the team sees potential for the integration of DPP data into its loyalty scheme, which offers discounts and special event access, among other member benefits. Marimekko concludes that DPPs can be seen as a business opportunity for increased customer loyalty and services, and the pilot led to DPP preparation becoming a multi-departmental initiative rather than residing within sustainability.
Companies including Balenciaga, Coach, OTB Group and Prada Group have begun adding digital identities to physical goods to enable digital storytelling and enhanced customer services like instant resale. In another example, UK-based eponymous designer Priya Ahluwalia connected web-based video content to her physical garments via a QR code on the garment label. Although not a use case for DPPs, it’s not a stretch to imagine how that digital ID could be linked to DPP data, as well as exclusive content.
What we still don’t know
While the ESPR is already in force, the final stipulations for DPPs — which will specify the exact data points required — will be stated in the ‘Delegated Acts’, which are currently being written. The acts are expected to be finalised by 2028, the same year they will enter into force for all in-scope products, including clothing. The ultimate level of granularity might be less intensive for apparel in comparison to other categories, such as electronics, says GS1’s Beideman. Apparel, for example, might only require details on the product batch level, while a mobile phone might require details at the individual product level.
“In general, we are in favour of harmonised and consistent regulation that helps customers to make more informed choices while raising the bar for the industry,” says Lynne Walker, director of Primark’s sustainability and circularity strategy Primark Cares. “It is therefore essential that DPPs are based on sound scientific criteria and are practical for retailers to adopt.”
Unknown DPP data points include those without a universal standard — for example, how to measure a product’s carbon footprint in circular, instead of linear, terms. The European Commission has devised two environmental footprint methods to inform the regulations: the Product Environmental Footprint (PEF) and the Organisation Environmental Footprint (OEF), which are designed to measure and communicate the lifecycle environmental performance of products and organisations, respectively. The PEF method expands on typical product impact assessments by incorporating the consumer use phase and eventual ‘end of life’. However, it has been marred by criticism over its “broad brush” approach.
Some brands and industry experts predict a watering down of the DPP requirements, as was the case with the Corporate Sustainability Due Diligence Directive (CSDDD) earlier this year. “I think there will be thresholds [introduced]; there is a lot of lobbying [happening] on the retail side,” Xeni says of the introduction of DPPs into a tough retail landscape.
Other DPP unknowns include how implementation will be enforced, the consequences of non-compliance and specific thresholds that will determine which companies are required to adopt these measures.
The ESPR states that each EU and EEA (European Economic Area) member must conduct national market surveillance (including monitoring, verification and enforcement of national and EU legislation), then report on key information, like the nature and number of checks and types of non-compliance and penalties. By way of comparison, 2009’s Ecodesign Directive typically consisted of warning letters, fines, prosecutions and judicial sentences. To date, market surveillance suggests that 10 to 25 per cent of products are non-compliant. Comparable or higher levels of non-compliance with the more robust ESPR are expected, given its broader scope.
Despite the shortcomings and the unknowns, brands are beginning to act. “We have seen significant downloads of the DPP protocol in Europe, the US and other countries,” explains Sadock. She believes DPPs represent a consolidation of several regulations, galvanising and rallying brands around a helpful, single focal point. “Brands want to ensure they are on the same path other brands are on, and DPP is a visible and tangible requirement that brands can more readily get on board with compared to the less tangible compliance and reporting requirements.”
Soon, Sadock believes, not having DPPs “might prompt the question why, leading to the assumption that there is something to hide”.
Key takeaways: DPPs underpin Europe-wide efforts to establish a new circular economy that builds on economic growth while designing out waste and limiting new resource use. All textile products, including clothing and homewares are in scope for DPPs, which will demand that product data be held and shared with consumers, EU regulators and other value chain stakeholders. Most of the required DPP data has already been established through pilots, however gaps include how environmental footprints should be calculated, since there are currently no universal industry standards. The final DPP requirements are expected in 2028 when implementation will begin. For now, brands are advised to begin gathering and harmonising data identified in the DPP pilots to ensure they’re ready to comply, as well as capitalise on the consumer engagement potential.
Brooke Roberts-Islam wrote ‘Unlocking DPP: The Why, What and How of Digital Product Passports’.
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