Digital Product Passport for Textiles: What Fashion Brands Need to Know About the DPP

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. In its 2025–2030 Work Plan, the Commission identified apparel as a top-priority product group for DPP, with the delegated act planned for adoption in 2027. This digital record for footwear and textile products will provide a thorough overview of an individual product’s impact throughout its lifecycle.  

However, focusing only on compliance risks overlooks a bigger DPP opportunity – improving customer relationships through environmental data accessibility. Even though EU-wide implementation is still pending, some fashion brands have already started implementing Digital Product Passports because climate responsibility is part of their DNA, and DPP provides a way to communicate that. For example, Carbonfact’s workwear customer Coverguard is using DPP as a competitive advantage to win over customers through data transparency.

In this article, we’re taking a deep dive into the EU’s Digital Product Passport and what it means for fashion brands. To gain a general understanding of all EU sustainability regulations and their impact on your brand, we recommend reading our EU textile regulations overview.

TL;DR

• What: The Digital Product Passport (DPP) will create product-level digital records showing a garment’s environmental performance, accessed via a QR code or similar data carrier. While final requirements are still being defined, EU studies indicate early DPPs will focus on material composition, manufacturing processes, core environmental indicators, chemical compliance, traceability, and durability.
• Who: The DPP will apply to apparel and textile brands selling in the EU, regardless of where they are based; the exact scope (including footwear) will be confirmed through delegated acts.
• When: The DPP is already part of EU law, with textile-specific delegated acts expected to be adopted in 2026, followed by a minimum 18-month transition period, meaning implementation is expected to start from 2027 onward. Many fashion brands are already preparing by building LCA-based data foundations.

Overview: Digital Product Passport for Textiles

In June 2024, the Digital Product Passport 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 selling 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, which serves as a comprehensive digital record for important, product-related information.Think of the Digital Product Passport for textiles 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 Ecodesign for Sustainable Products Regulation for apparel and footwear here.

DPP for Fashion: Which Brands Will Be Affected?

Under current ESPR legislation, the Digital Product Passport is designed to apply to all apparel products sold on the EU market, regardless of where the brand is based or its size. The exact scope and timing will be determined when the delegated acts are finalized. 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.

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

What is the Timeline for the Digital Product Passport for Textiles?

The ESPR framework that makes the Digital Product Passport 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.

Final delegated act for the DPP for textiles is expected to be shared in 2027, which will detail the information to be included on a passport, the type of data carriers to be used, and other specifications. After the delegated act for textiles has been published, fashion brands will have at least 18 months to implement it.

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.

What are the Data Requirements for the Digital Product Passport Fashion?

While apparel and footwear products currently already have a physical label that includes information such as material composition or country of origin, the new Digital Product Passport for textiles will require more extensive reporting. A key element of Digital Product Passport reporting will likely be based on the EU's Product Environmental Footprint Category Rules (PEFCR) for the apparel and footwear sector, ensuring consistency across the European Union regulations. 

Specific information requirements will be detailed for each product category in delegated acts. Although the final list of requirements for the DPP has not been released, we know broadly what it will entail.

What data could be included 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.

Many brands are beginning their Digital Product Passport journey by publishing an initial version now, 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. See example.

Which DPP data fashion brands should prepare first?

A Commission-mandated Textile Preparatory Study published in December 2025, complements the EPRS analysis by assessing which types of data points are technically feasible to collect and scalable at product level. Rather than defining DPP requirements, the study evaluates real-world data availability across brands and suppliers.

The study indicates that early DPP implementations are most likely to focus on:

• Material composition and weights
• Key manufacturing processes
• Core environmental indicators (notably climate, energy, and water)
• Chemical compliance references
• Basic traceability information (e.g. production stages and locations)
• Durability, repairability, and recyclability attributes
  
  

This feasibility analysis supports a phased DPP rollout, where essential environmental and product data is implemented first, with more advanced lifecycle and circularity data added over time. We analyse how DPP phased roll-out could look like at the end of this article.

How are apparel and footwear brands preparing for these requirements?

Based on our conversations with apparel and footwear brands preparing for the Digital Product Passport, five requirements consistently surface:

1. Seamless integration with LCA and reporting tools: A DPP solution that draws data directly from LCA systems eliminates duplication and allows teams to “measure once, report everywhere.”
2. Customizable branding: Strong branding makes the DPP feel like part of the product experience, not an external requirement.
3. Traceability details: Brands expect DPPs to include supplier-level information, verified origins, and certifications.
4. Automation: Companies prioritize DPP solutions that can auto-generate passports with a low-lift, largely automated implementation process that allows implementation at scale.
5. Multiple impact indicators: Brands want DPPs that go beyond CO₂ to display additional environmental metrics such as water use, energy, and eco-scores.

Which Apparel Product Categories Will Be Affected by DPP?

Textiles and apparel are explicitly listed as a priority product group in the European Commission’s 2025–2030 Work Plan. This indicates that garments and other textile-based products are the primary focus of the initial DPP rollout.

Footwear, however, remains less clearly defined. Footwear is not explicitly included in the Commission’s priority product list, nor is it covered in the Textile Preparatory Study. This suggests that footwear may be addressed separately or at a later stage, potentially through a dedicated delegated act.

How Will the Digital Product Passport Be Displayed on Fashion Products?

A data carrier (such as a QR code) linking to a unique identifier should 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. In practice, the Digital Product Passport is expected to be created at the SKU level, rather than for each individual item or as a single average across multiple products. The information should also be easy to access for consumers, retailers, and other stakeholders.

Carbonfact’s Approach Is Built Around Apparel and Footwear Needs

1. Automated LCA Integration – DPPs are generated automatically from your existing Carbonfact product LCA data, requiring no additional data collection or complex integrations
2. 16 PEF Environmental Indicators – Displays comprehensive environmental impact metrics aligned with the EU Product Environmental Footprint framework, covering carbon, water, energy, and 13 other indicators
3. QR Code & Link Generation – Each product gets a unique URL and downloadable QR code that can be generated with a few clicks.
4. Granular Impact Breakdown – Shows environmental footprint broken down by process step, component, and material, helping consumers understand where most emissions occur in the product lifecycle
5. Customizable Brand Content – Includes sections for brand description, sustainability values, care guides, and certifications, allowing you to tell your sustainability story alongside the data.
6. Certification – Our DPP solution includes a section showing all relevant certifications for the product, such as GOTS and others.
7. Eco-Score Display –  Selling in France? Carbonfact’s Digital Product Passport can display the French Eco-Score as part of the DPP output.

Digital Product Passport displayed on Carbonfact’s platform

Why Should Fashion Brands Start Preparing for the Digital Product Passport Now?

Brands like Nobody's Child, Chinti & Parke, and Panerai have already led the way in the industry by implementing the Digital Product Passport.

Working with Carbonfact, Fusion Sportswear co-developed a Digital Product Passport that enables the brand to share product-level environmental information directly with customers, embedding transparency into the product experience. Coverguard, a B2B workwear brand, uses Carbonfact’s Digital Product Passport feature to demonstrate a strong data strategy to its clients, supporting its CSR approach and helping to secure contracts and increase sales.

Although the introduction of the Digital Product Passport has faced delays, this should not be interpreted as a signal to pause. In practice, these delays give brands the necessary time to build the data foundations required for compliance. Had the original timeline remained in place, most brands would have struggled to meet the requirements without significant last-minute costs.

Avoid rushed implementation 

Building the data infrastructure needed for the DPP typically takes a year or more. Supplier data can be incomplete, inconsistent, or spread across multiple systems, such as PLM. Beginning too late increases the risk of data gaps, rushed integrations, and expensive last-minute scrambles.

2027/2028: Your future collections depend on today’s data

The products being designed now will enter the market in 2027/2028, precisely when DPP obligations are expected to apply. This means the data collected today will form the basis of your future DPP disclosures. Brands need fully operational data systems well before that point to avoid compliance risks.

For luxury brands: There’s a big, overlooked advantage to launching DPPs 

DPP can serve as a powerful authentication tool. SKU-level QR codes and product-specific impact data are extremely difficult to replicate, strengthening anti-counterfeiting and grey-market measures.

Carbonfact Helps Apparel and Footwear Brands Prepare for Digital Product Passport Requirements

This level of data collection and analysis will demand a comprehensive carbon management solution specific to 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 “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 and re-use your data for other regulations like CSRD and French Eco-Score.

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.  

How Could a Potential DPP Roll-Out in the Textile Industry Look Like?

The Digital Product Passport roll-out has not yet been decided on as the details are currently being worked out. These will be published as delegated acts in 2027.

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

Phase 1. Deployment of a “minimal & simplified DPP” for textiles on a short-term horizon of 2027. 

This phase proposes a "minimal and simplified" DPP, focusing on providing essential information. The key elements of this phase include:

Mandatory Information: 

• Product composition, specifically indicating recycled materials, hazardous substances, and plastic microfibers.
• Recyclability of the product.
• Traceability of supply chain production, including information on key processes like weaving, dyeing, and finishing.
• Packaging details, including recycled content and recyclability.
• Environmental impact, particularly regarding product safety.

To support Life Cycle Assessment, the DPP would also include material weights and transport modes and distances.

Recommendations for Phase 1:

• Keep the DPP simple and easy for consumers to understand
• Enable data sharing and interoperability across the supply chain, for example by allowing material, supplier, and certification data to flow consistently between brand systems (such as PLM or LCA tools), supplier databases, and the Digital Product Passport, without requiring manual re-entry.
• Apply the DPP to all textiles sold in the EU, regardless of where they are produced.
• Adapt mandatory information in alignment with upcoming European regulations, such as the revision of the Textile Labeling Regulation.

Phase 2. Deployment of an “advanced DPP” for textiles on a mid-term horizon of 2030.  

This phase involves the expansion and enhancement of the Digital Product Passport system based on the learnings from the first phase. Key points of this phase include:

Increased information collection:

• The DPP will gather more comprehensive data throughout the product’s lifecycle.
• Supply chain information will be expanded, with mandatory and additional details included for each production stage, considering confidentiality and restricted access for certain data.
• More detailed information about the finished product will be collected, covering aspects like size, color, weight, and composition to facilitate better sorting and recycling at the end of life.
• After-sales tracking, including repair and second-hand activity, to assess durability and product lifespan

Recommendations for Phase 2:

• Ensure standardization of data across various systems, including supply chain software, product lifecycle management (PLM) tools, and second-hand platforms.
• Develop standards for data exchange between all stakeholders, from raw material suppliers to recyclers, ensuring seamless information flow.
• The DPP will be generalized across the entire apparel and footwear industry, including products from foreign countries, ensuring compliance with European rules.

Phase 3. Deployment of a “full circular DPP” for textiles on a long-term horizon of 2033. 

During this last phase, a “full circular DPP” could be fully deployed to promote circularity in the textile sector.

Complete supply chain integration:

• The DPP will document the entire supply chain, with controlled access to preserve business confidentiality.
• Information will be inherited throughout the supply chain to allow brands to automate impact calculations and provide data for certifications and labels.

Tracking Throughout Product Life Cycle:

• The DPP will track products through distribution, usage, after-sales services, and all relevant lifecycle events, promoting durability and effective collection processes for end-of-life management.
• Enhanced sorting and recycling will be enabled by accessing detailed product design and manufacturing information to improve end-of-life processing.

Increased Circularity:

• By exchanging data between recyclers and suppliers, the DPP will facilitate higher rates of closed-loop recycling, reducing reliance on virgin materials.
• The DPP will enable a significant reduction in natural resource extraction by promoting the reuse of recycled materials.