DPP in the apparel and footwear industry: What you need to know

"Fashion Rules" is a LinkedIn publication by Carbonfact aimed at providing clarity on regulatory matters to brands within the apparel, luxury, and footwear industries.

Carbonfact a sustainability platform, helps apparel and footwear brands measure, report, and reduce emissions with a team of data experts.

This article was originally published on the Carbonfact blog, find the full version here

Status:? ? Approved EU law, from June 2024, Implementation pending

For apparel and footwear brands operating in the EU market, the Digital Product Passport (DPP) will be one of the most visible indicators of a company’s environmental performance. This digital record for footwear and textile products will provide a thorough overview of an individual product’s impact throughout its lifecycle.

This will have a big impact on sustainability teams at all fashion brands, affecting everything from product labeling to implementing new tools. In this blog post, we’re taking a deep dive into the EU’s Digital Product Passport and what it means for fashion and textile brands.

To gain a general understanding of all EU sustainability regulations and their impact on your brand, we recommend reading this article as well as exploring our Textile Regulations Hub .

Overview - Digital Product Passport for textiles

In June 2024, the DPP was officially approved by the EU as part of the Ecodesign for Sustainable Products Regulation (ESPR), a framework regulation that applies to any apparel and footwear company that sells in the EU, no matter where they are based.?

In short, the ESPR law introduced certain performance requirements for products placed in the European market, as well as information requirements to enhance transparency and sustainability in product design and manufacturing. One significant aspect of this framework is the introduction of the Digital Product Passport (DPP), which serves as a comprehensive digital record for important, product-related information and must be made accessible on the website and on the garment.

Think of the DPP as a "digital fingerprint" for your products. Leveraging a data carrier like a QR code, the DPP will include essential information about a product's supply chain, as well as environmental footprint, details about materials used, chemical compliance data, recyclability, and repairability.?

You can read our complete deep dive on the ESPR for fashion and textiles here .

Which textile and footwear brands will need to publish a DPP?

The Digital product passport will be required for all apparel and footwear products (products comprising majority textile materials (including leather) sold on the EU market, regardless of where your brand is headquartered or the size of the company.?

That means Small and Medium Enterprises (SMEs) are included – but they can expect financial help to comply. According to the EU, SMEs are defined by meeting at least two of the following criteria:

• Less than or equal to 250 employees
• Less than or equal to €50M turnover
• Less than or equal to €25M in total assets

Which data is required for the DPP?

While garments and footwear products currently already have a physical label that includes information such as material composition or country of origin—the new textile DPP will require more extensive reporting.?

Although the final list of requirements for the DPP has not been released, we know broadly what it will entail. Specific information requirements will be detailed for each product category in Delegated Acts. These are technical explanatory documents for specific industries that specify the details for textile companies, a concrete timeline, and what specific data should be collected and displayed in the DPP.

This study conducted by the EPRS (European Parliamentary Research Service), published in June 2024, lists 16 categories of information that could be contained in the DPP:?

1. Product Description: General characteristics of the product, such as size, color, performance, and marketing details. It can also include after-sales information like product condition for resale or repairs.
2. Composition: Mandatory data on material percentages (e.g., cotton, polyester) as well as optional details about material origin, treatment, and other qualities like dyeing processes and fiber lengths.
3. Supply Chain: Information on the manufacturing process, identifying all involved stages from raw material sourcing to garment production.
4. Transport: Details about the transportation process, including distances and types of transport used for each stage of production, providing insights into the environmental impact.
5. Documentation: Certificates, audit reports, and quality control documents that verify the claims made by the brand regarding the product.
6. Environmental Impact: Data on the environmental footprint of the product, which helps in eco-design and allows consumers to make more informed decisions.
7. Social Impact: Information regarding the social aspects of production, such as worker rights, labor conditions, and human rights compliance.
8. Impact on Animals: For products involving animal-derived materials (e.g., wool, leather), details on the treatment and welfare of the animals involved in the production.
9. Circularity: Information on how circular the product is, including aspects such as recycled content, availability of repair services, and take-back programs.
10. Health Impact: Information related to the presence of hazardous substances and compliance with health and safety regulations (e.g., REACH).
11. Information on the Brand: Brand-specific information, including its commitments to sustainability, contact details, and corporate social responsibility reports.
12. Communication/Identification Media: Methods for linking the product to its data (e.g., QR codes, NFC chips) for consumers and authorities to access the DPP information.
13. Quantity: Information on production quantities, which helps assess product value and manufacturing scale.
14. Costs: While sensitive, some brands may disclose manufacturing costs to emphasize transparency. This information is often not mandatory.
15. Usage and Customer Feedback: Optional data related to product usage and consumer reviews, providing brands with feedback for improving product design.
16. Tracking and Tracing After Sales: Data on product lifecycle beyond initial sale, such as resale, modifications, or repair activities, facilitating circularity and extended product life.

What is the timeline for the implementation of the textile DPP?

The ESPR framework regulation that makes the DPP mandatory was approved in June 2024. However, it does only contain high-level information regarding the DPP; there is no textile-industry specific information just yet. These technical details are currently being worked on and will become law in the form of the above-mentioned delegated acts.

The first draft of the delegated act for DPP for textiles is expected to be shared in 2025, which should detail the information to include on a passport, the type of data carriers to be used, and other specifications.?

After the delegated act for textiles has been published, which most estimate will happen in 2026, fashion brands have at least 18 months to implement it. Next to this, the latest reports indicate that the DPP will be rolled out per industry between 2027-2030.

A June 2024 study by the European Parliamentary Research Service (EPRS) outlines recommendations for implementing the Digital Product Passport (DPP) in the textile industry. The study proposes a phased approach, suggesting that the DPP for textiles be rolled out in three phases - find the list of details for each phase here.

Subscribe to our Textile Regulations Hub to stay up-to-date on any news regarding the DPP and how it will impact your apparel and footwear brand.?

How should the DPP be presented on the products?

A data carrier (such as a QR code) linking to a unique identifier must be physically present on the product (e.g. on the label) at the time of sale.

The goal is to communicate essential information in a standardized and accessible digital format. Each product should have a unique product identifier that links to a digital record in a database or website. Imagine a QR code or RFID tag. The information should also be easy to access for consumers, retailers, and other stakeholders.

Which tools do I need for the DPP

To gather and publish data for the Digital Product Passport (DPP), fashion companies need a variety of tools for data collection, management, and reporting. Key tools include:

1. Product Lifecycle Management (PLM): Manages product data from design to disposal.
2. Sustainability Data Platforms: Measures environmental impact metrics (e.g., Carbonfact).
3. Supply Chain Management (SCM): Tracks sourcing, production, and supplier compliance.
4. Enterprise Resource Planning (ERP): Centralizes production, material, and compliance data.
5. Traceability Tools: Verifies material origin and certifications.
6. Data Integration Platforms: Consolidates data across systems.
7. Product Information Management (PIM): Centralizes and prepares product data for public release.
8. Reporting and Publishing Tools: Generates DPP-compliant reports.
9. QR Code & RFID Systems: Links physical products to digital sustainability data.

All tools will need to connect smartly, and, ideally, no manual work should be involved.

Why you should act on DPP in 2025 and not later

The Digital Product Passport (DPP) has emerged as a vital tool, pushing brands to build robust data infrastructure and gain actionable insights. At the same time, the delays in the introduction of the DPP have caused some brands to take a lackadaisical approach. In reality, these delays could have been introduced so brands have the time to act now – would the original timeline remain unchanged, almost every brand would miss compliance deadlines, or incur significant extra cost to meet them. The move makes it realistic for brands to implement data-gathering and DPP-tooling solutions, but that does mean they need to act now. Here’s why:

Now is the Time to Act, Not the End of 2025

– While you technically have until the end of 2025 to decide on a solution, waiting that long significantly increases your risk of rushing implementation. Starting now gives you the lead time needed to properly set up your systems and address the complexities of data collection and compliance.?

Mid-to-Late 2025: Risk of Rushed Implementation

– Waiting until (late) 2025 leaves limited time to gather and clean upstream data, a process that typically takes at least a year. Data from suppliers is often incomplete or inconsistent, and you may need to integrate systems like PLM. Rushing this work increases the chance of missing critical information and leads to last-minute fixes.

2027/2028: Collection Deadlines Loom

– The collections you’re working on now will be released in 2027/2028 – in other words, the data you collect from the start of 2025 is the data you’ll report on then. Your data collection needs to be fully operational now, and your compliance systems need to be fully ready by that time to avoid disruptions.

Avoid Last-Minute Costs and Compliance Issues

– Acting now helps prevent a costly, last-minute scramble to meet compliance requirements. It ensures you can build your processes properly, reducing long-term costs and avoiding costly, repeated corrections later on.

There’s a big, overlooked advantage to launching DPPs?

– DPPs serve as a strong marker of authenticity. Replicating the correct QR-codes on product labels is something knock-off imitations won’t be able to do, especially considering SKU-level applications – essentially recognizing that different sized products have different weight, therefore different environmental impacts that need to be recognized in DPPs.?

How to get started with DPP in 2025?

Many brands are beginning their Digital Product Passport (DPP) journey by publishing an initial version in 2025, with a focus on environmental data. This often involves performing a Life Cycle Assessment (LCA) for each product, which captures a product’s full environmental impact — from cradle to grave. Tools like Carbonfact simplify this process, enabling you to efficiently gather, analyze, and report environmental footprint data for compliance, no matter how messy your data initially might be.?

A key element of reporting will likely be based on the EU's Product Environmental Footprint Category Rules (PEFCR) , ensuring consistency across industries. While conversations around environmental footprint data are still evolving, the groundwork is already being laid, with many brands preparing to meet these requirements. We encourage you to adopt the “measure once, report everywhere” approach, where robust databases will always allow you the flexibility to react to evolving regulations.

Examples of DPPs launched by brands

Recent implementations of Digital Product Passports (DPPs) by British retailers Chinti & Parker and Nobody's Child demonstrate the growing adoption of digital supply chain transparency tools, though the majority of them for now function as marketing tools. Luxury brands have also adopted DPP solutions as a means to verify product authenticity and fight counterfeiting.?

Panerai , a famous luxury-watch maker, uses DPPs for customers to verify the technical specifications and authenticity of their watches.

Brands like Simple Chic , Tammam and Born+Berg have taken their DPP a step further in terms of information completeness, detailing crucial elements likely necessary for the final form of DPP, though none have yet disclosed the CO2 emissions per product – no doubt a crucial aspect for the “launch version” of DPP. It’s non the less an admirable initiative and a strong show of leadership.?

How Carbonfact can help you launch your first DPP in 2025

This level of data collection and analysis will demand a comprehensive carbon management solution specific for fashion and textile brands. Carbonfact enables you to perform comprehensive environmental LCAs for all of your products – and that’s your starting point.

For now, here’s what to know: the DPP will require numerous KPIs to be reported and displayed. Carbonfact can seamlessly provide a product’s environmental score and other sustainability indicators. We offer robust carbon management, encompassing all emissions categories (Scope 1, 2, and 3) and environmental data points, empowering brands to leverage their data for the creation of a Digital Product Passport. We also operate on the aforementioned “Measure once, report everywhere” philosophy, which means that we’ll help you gather all the data necessary for you to be able to respond flexibly to any changes in regulations, consumer-transparency demands or sustainability initiatives.

Carbonfact is actively involved in efforts to guide the development of the DPP. We are currently working with a consortium of climate tech startups like CommonShare, certification bodies, and brands such as AdoreMe to propose a solution to the DPP at the EU level. As such, we’re following this topic closely and will update as soon as further information is released in 2025.??.