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

 Status:  ✅ Approved EU law

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 and textiles as a top-priority product group for DPP, with the delegated act planned for adoption in 2027. This digital record 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.

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 vs Physical Label

Before looking closer at the proposed ecodesign requirements, it is important to understand the distinction between DPP and the physical garment label:

• DPP – a digital record accessed via a data carrier (QR code, NFC) that holds detailed product information: composition, supply chain, repair, recyclability, environmental footprint, and more. The QR code will be placed on the physical label of the garment.
• Physical label – a label providing a standardized way to communicate key environmental and sustainability metrics to consumers. A physical extension of the DPP.

The two are designed to work together. The physical label gives consumers a quick visual grade; the QR code on the label opens the DPP for the full data. The physical label is the consumer-facing summary, the DPP is the deep dive. For textiles, both the DPP and what should appear on the physical ESPR label will be addressed through the textile delegated act, scheduled for adoption in 2027.

DPP for Fashion: Which Brands Will Be Affected?

Under current ESPR legislation, the Digital Product Passport is designed to apply to all apparel and footwear 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.

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 only contains 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 final delegated act for the DPP for textiles is expected to be shared in 2027; fashion brands will then have at least 18 months to implement it (exact timing to be determined in the act itself).

Although footwear is not among the first-priority product groups, the Commission has acknowledged the environmental relevance of footwear and its potential link to eco-modulated extended producer responsibility (EPR) fees under the Waste Framework Directive. As a result, a dedicated study on footwear is expected by the end of 2027 to assess how ecodesign and information requirements, including the DPP, could apply to this category.

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

While apparel and footwear products 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 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 can entail.

What Data Could Be Included in the Textiles DPP?

The Joint Research Centre (JRC) – the European Commission's in-house science service – is preparing the evidence base for the textile delegated act. The detailed proposal for what the textile DPP will actually contain has been put forward by the JRC in a draft study on DPP content for textile apparel products.

This is a draft document – the final requirements in the Textile Delegated Act may differ from what is proposed here; however, it offers an overview of the considered data points. This JRC study proposes around 50 data points organized into four categories: product identification, producer identification, product information, and compliance documentation.

The two tables below show the JRC's proposed data points for product information and compliance documentation:

For the full list of data points – including product identification, producer identification, and the JRC's industry readiness assessment for each requirement – see Tables 5–8 of the draft study (pages 41–56).

How Are Apparel and Footwear Brands Preparing for DPP Requirements?

As final DPP requirements are still unknown, 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 here.

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.

The JRC’s 3rd Milestone for Apparel – Proposed Ecodesign Requirements

Alongside the draft DPP content study, the JRC has also been finalizing its preparatory study on textiles – a separate document that defines the actual ecodesign requirements brands will need to meet. The DPP is the vehicle through which these requirements will be disclosed; the preparatory study defines what those requirements are.

The study covers apparel containing at least 80% textile fibers, including workwear and sportswear. Footwear is out of scope – a separate study is expected by the end of 2027.

What the JRC’s Life Cycle Assessment Found

The JRC ran a full Life Cycle Assessment on three representative product categories – knitted, denim, and other woven. The analysis shows where a garment's environmental impact comes from:

• Raw material production: 60–63% (biggest impact)
• Manufacturing: 21–29%
• Distribution: 4–6%
• Use: 5–15% (highest for denim, due to laundering)
• End of life: <0.5%
  

Raw materials are by far the largest driver of a garment's environmental footprint. Across current 16 Product Environmental Footprint impact categories (currently 16, expected to expand under the EF method revision), the three largest contributors are water use, climate change, and fossil resource use.

Proposed Ecodesign Requirements

Based on these findings, the JRC has put forward four candidate ecodesign requirements for the delegated act – three as information requirements and one as a mandatory performance threshold. Where exactly the information requirements would be displayed – on the DPP, a separate label, or both – is still open and will be decided in the 4th milestone study.

1. Robustness score (0–10): an information requirement scoring how well a garment holds up after five standardized wash cycles. The score is based on technical, measurable parameters, including visual inspection, spirality, and dimensional changes after multiple cleaning cycles. The JRC is clear that it measures resistance to laundering stress, not actual product lifetime – current tests cannot reliably predict how long a garment will last in real use (e.g. after how many wears people throw garments away).

2. Recyclability score (0–10): an information requirement scoring how easy it is to recycle the garment. The cleaner and more homogeneous the fiber composition, the higher the score. Products with more than 15% elastane (or 20% in nylon-rich blends) score 0. Products below these thresholds can gain points for mono-material construction, matching inner and outer composition, and the absence of recycling disruptors such as prints, coatings, sequins, or dyes. Additional points are linked to compatible recycling pathways. For example:

• Pure cotton → compatible with chemical recycling into man-made cellulosic fibers (+2 points)
• Polyester- or acrylic-rich blends above 80% → compatible with thermo-mechanical recycling (+2 points)

3. Recycled content: the JRC proposes potential minimum recycled-content thresholds as part of future performance requirements, though these are still under assessment and optimization. The levels currently explored include:

• 20% recycled cotton in denim
• 15% recycled polyester in knitted and other woven products
• 10% recycled wool in knitted and other woven products
• 5% recycled nylon in knitted and other woven products

4. Manufacturing footprint: information requirement that would indicate whether a product's environmental performance is better than the average (and to what extent, in %). The JRC suggests the European Commission pick between two versions:

• Environmental footprint: a single score summarizing current 16 PEF impact categories.

• Carbon footprint: only the climate change category (the biggest impact one).

How would the footprint be calculated?

In either scenario, the footprint would be calculated using the PEFCR methodology, but limited to the manufacturing stage – raw materials are suggested to be excluded. The JRC justifies excluding raw materials by arguing that the datasets available for different fiber types use inconsistent system boundaries, which prevents their fair comparison. The JRC argues the raw materials hotspot is addressed elsewhere via the robustness, recyclability, and recycled content requirements.

The proposal suggests distinguishing products calculated using primary data from those relying mainly on secondary data to incentivize the use of primary supply-chain data.

Which brands would display the manufacturing footprint indicator?

The proposed approach would allow the voluntary reporting of the footprint indicator. Brands could choose not to calculate the manufacturing footprint at all. Those that do calculate it would only be able to display the indicator if their product beats the PEFCR category benchmark – showing by how much they outperform the EU average (as a %). The field would be "excellence-only."

Carbonfact’s Feedback for JRC 3rd Milestone

Carbonfact has submitted a joint position to the JRC consultation on the Digital Product Passport, together with three other LCA vendors and 2B Policy. This is the first time these platforms have formally united on a policy position.

Here's what we argued:

1. Include raw materials

It's the biggest driver of impact: The JRC's own preparatory study acknowledges that raw material production accounts for 60–63% of a textile product's environmental footprint. Excluding raw materials means the regulation cannot distinguish between the most and least impactful products on the market. It also removes the market incentive for brands to invest in lower-impact fibers, which often come at a higher cost.

2. Make it mandatory, not voluntary

A voluntary disclosure framework creates selection bias: only better-performing products would report, leaving the majority of the market invisible to consumers. Mandatory requirements, as demonstrated by EU energy labeling, are what actually shift markets – nearly 80% of EU citizens consult the energy label at the point of purchase. The garment’s environmental footprint indicator should work the same way.

3. The technology is ready, and the costs are manageable

The JRC estimated a per-SKU calculation cost of €2,550, based on figures from the Battery Regulation. Aggregated data from product LCA tool providers tells a different story: the actual cost ranges from €1 to €10 per SKU. Collectively, our four platforms have calculated environmental footprints for over 3 million unique SKUs in the last 12 months alone. 20-40% of users of these tools are already SMEs.

4. Use the A&F PEFCR as the methodology

A multi-indicator Environmental Footprint based on the Apparel & Footwear PEFCR ensures comparability across the industry and consistency with other EU legislation – including the EU Battery Regulation, which already mandates PEF-based declarations. A carbon-only metric would miss critical textile-specific impacts like water consumption and land use.

What's next?

The next key milestone is the JRC 4th milestone publication in June, which may update its previous policy recommendations and will shape the next phase of advocacy. 

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.

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 gray-market measures.

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

Carbonfact is the environmental data platform built specifically for apparel and footwear brands. It enables brands to measure product-level environmental impact accurately and at scale using LCAs tailored to apparel and footwear supply chains, consolidating data from existing systems and suppliers into a consistent product model and improving accuracy over time through transparent heuristics.

By focusing exclusively on environmental data – the hardest part of DPP and product sustainability – Carbonfact allows brands to start with a complete solution today while remaining flexible as requirements evolve, reusing the same underlying data across compliance, reporting, and product-level decision-making instead of rebuilding it for each new use case.

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.