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One of the first industries for which Digital Product Passports (DPP) will be required by the end of 2027 is textiles.
What is the Digital Product Passport (DPP)?
Digital Product Passports is an EU initiative within the ambitious EU Green Deal initiative, aiming at net zero by 2050. DPP is part of the sub-initiative Ecodesign for Sustainable Products Regulation (ESPR), which has the purpose of changing the way industry designs products and production methods to minimize long run environmental impact.
The introduction of DPP could be seen as a means to mobilise consumer purchasing power to drive such change instead of using the traditional regulatory approach, to make the process more dynamic, less focused on details and more proactive.
Objectives of Digital Product Passports in Textiles and Fashion
The objectives for introducing DPP in the textile and fashion industry are no different in general from the objectives of introducing DPP.
All industries have their special characteristics, though. For textiles and fashion, some of the main issues that the DPP regulation aims to address are:
Fast fashion leading to over consumption and mountains of wasted clothes
Water consumption by growing and treating cotton, often in arid areas
Environmental impact of cleaning, treating and colouring textile fibres
Consumption of oil to produce synthetic fibres
Frequent abysmal labour practices in production and treatment of textiles as well as in production of garments.
Dropshippers flooding the EU market with products breaking health and safety standards
Textiles and Fashion being among the first industries where it’s introduced is an indication of the scope of environmental impact of the industry, though, as well as a sign of its environmental impact.
How DPP Differs from Ordinary Tracking Systems
Digital Product Passports could easily be mistaken for “just another tracking system” but is much more. For DPP, tracking goods is secondary to the purpose of compounding and conveying information to consumers.
Let’s look at what sets Digital Product Passports apart:
Mandatory and uniform for goods sold in the EU – No local variations
Digital only – Scan a QR code or another identifier to obtain the data. Or enter the unique GTIN in systems for professionals
About the product itself, not about its logistics – DPP’s main purpose is to convey information about the environmental performance, recyclability, repairability and responsible sourcing. Logistics is just one contributor to the entire DPP.
To obtain a complete DPP, you need a “data supply chain” mirroring the supply chain for physical items, compiling a digital twin of products, step-by-step, as items are produced, assembled and transported.
How Digital Product Passports Will Impact the Textile Sector
The introduction of DPP will be a fundamental shift in all industries on sourcing, manufacture and logistics. It will affect practically all roles and departments; all aspects of product data will become as important as the physical product itself as no products will be possible to sell without the accompanying data. Providing it, updating it and communicating it correctly.
Greenwashing will be a thing of the past, as all pertinent data will become public and easy to compare.
1. Becoming Able to Provide the Data at All
Much of the data required for Digital Product Passports will be data that you do not readily have already. If you’re lucky, it might be hidden somewhere in your systems, maybe even in the required formats.
For other data you will have to rely on your suppliers providing it, and they for their suppliers to provide it to them, in their turn…
2. Obtaining the Infrastructure to Manage, Maintain and Continuously Verify Data
Digital Product Passports are not a “drive-by event”, they are a fundamental change to how business is done. Therefore, it’s not sufficient just to extract and present the data once, you will need both the infrastructure and processes to continuously verify, update and change the information. Changes of suppliers, changes of logistics, changes made by suppliers somewhere up the supply chain and changes to recycling possibilities will all impact DPP data. You will need a supply chain for data, parallel to the one for physical products.
3. Digital Product Passports Will Impact Design of Products and Production
The stated purpose from the EU is to change the way products are designed and produced to become more eco friendly. Once you’ve managed to provide the DPP, it will be compared with those of competing products. Maybe, consumers won’t worry too much if DPP data vary just a little between products, but if yours are way worse than your competitors, or you might not be able to supply a valid certificate of the absence of child labour, you will need to make substantial changes to design, production, logistics or choice of sub suppliers.
4. Changes to Supply Chain Management from Digital Product Passports
Not only will you need to establish a supply chain for data as we just mentioned, but you will also need to weigh environmental factors into your choice of suppliers and logistical alternatives in ways you never had to before. Think of it as expanding the concept of performance or quality of components and other inputs to include also environmental performance.
Over time, your shortlists of suppliers are likely to change depending on not only their environmental performance, but their ability to supply DPP data in a reliable way.
Will You be Impacted by Digital Product Passports Although You Don’t Sell Your Products in the EU?
The answer is: “it’s very likely, unless you only produce for your local market”. Remember that, for the DPP to be complete, the DPP will rely on input data from the entire upstream supply chain, all the way back to the cotton fields or sheep herd. The earlier you are in the supply chain, the greater the probability that at least some of what you produce will finally end up as an input to something being sold to EU consumers. Therefore, you will need to be able to supply DPP data with your product.
Benefits from DPP for Consumers, Manufacturers and Others
The main benefactors intended from the introduction of Digital Product Passports are future generations and our environment. But there are benefits or opportunities for us also in our roles in the commercial arena.
Consumers are enabled to make better and more informed choices, not to be fooled by greenwashing. They can choose products that are safer and that last longer.
As one of the dimensions of Digital Product Passports is repairability, there’s hope that they will bring a renaissance for craftsmen and -women who repair and recycle all kinds of products.
Hopefully, DPP may also help in improving the handling of recycled textiles and second hand garments.
Manufacturers can, if they go about DPP in the right way, reap benefits in a range of ways:
Better control of products and production – DPP will widen the scope of quality and production control to include new parameters. We foresee a closer relationship with reliable suppliers and more “levers” to pull to watch over quality
A new way to handle product data – Product data has traditionally been replicated from system to system, from supplier to supplier, creating lag and errors. The DPP infrastructure is intended to be distributed, where data remains, and is maintained, at the sources and only fetched when someone scans a DPP QR code. That new paradigm has already led to companies being able to reduce the number of databases used and maintained. It can also open doors to new and efficient ways to handle the presentation of product data on websites, e-commerce. manuals and in print.
Business development – That “data supply chain” will be able to handle other data than DPP data only. You will be able to supplement your products with added value that could be monetized. Data that might currently lie idle somewhere in your systems.
Why DPP for the Textile and Fashion Industry?
The environmental and social responsibility of the textile and fashion industry has been a frequent theme in the news cycle for quite some time.
Fast fashion boosting clothing consumption to ever higher levels
Bogus “recycling” operations polluting poor countries with mountains of discarded clothing, bloating shipping by relaying used clothes like in a global pinball game gone mad
Water consumption of cotton growing and treatment contributing to desertification
Environmental impact of pesticides and colouring operations
Use of forced, child or underpaid labour in production of textiles or in clothing manufacture
Horrendous fires and fatalities in substandard textile manufacturing in South Asia
Dropshippers flooding the EU with products breaking EU standards for health and safety
Let’s look at the statistics for France (2022 - CNN/Refashion) to get an idea of the scope we’re talking about:
3.3 billion items of clothing, shoes and home linen put on the French market
700,000 tonnes of clothes thrown away*
…whereof 2/3 ended up in landfills
This with a population of 68 million of the Global almost 8 billion (=0.85%)
* The corresponding number for EU in total is 5 million tonnes, around 12 kg of clothing discarded per person per year.
Most of these challenges are addressed through the introduction of DPP while the mountains of discarded clothes are addressed by another part of the ESPR, at least partially. ESPR introduces a ban on destruction of unsold textiles and footwear to deal with the portion of clothing that, today, is discarded without even having been used by consumers. The rest might be dealt with like individual countries have done, like Sweden where it’s forbidden, from 1 January 2025, to throw used clothes in general waste. It should be recycled, either through second hand or charity, or recycled as fibres.
Challenges in the Textile Supply Chain
Like many other industries, the supply chains in textiles are long and complex. They often originate either from oil (for synthetic fibres) or in poor countries with weak administrations, for cotton or wool.
Complex Global Production Networks, with Doubtful Transparency
Textiles is one of those industries where commodities are produced, refined and traded internationally later to be processed into final products.
The garments might look the same, but the raw material may well originate from different countries just as manufacturing may be done in different places, all with differing environmental impact. So, two items that look identical may have very different history and environmental impact.
In Textiles, There’s Also the Issue of Recycling
Much of the DPP challenges of the textile industry lie in the early stages as described above, the gigantic market volume and wasteful consumption of clothes aggravate the problems.
With the speed, volume of consumption and recyclability comes another issue, which differs from most other industries; the environmental impact of recycling, and – too often – make-believe recycling.
Many fabrics can be recycled to make new clothes, but not all. Clothes intended for recycling need to be sorted and treated before fibres can be used to make new clothes – a low-paying job. The infrastructure for textile recycling is insufficient and immature, at least at the scale needed at our current levels of consumption.
This has led to long, complex and seemingly erratic transports across the entire globe, too often ending in mountains of unusable clothes in developing countries.
The issue is compounded by widespread chemical treatment of fabrics in some countries, chemicals that are often banned in the developed world – flame retardants (PFAS) – meaning that if such clothes get into the mix, the clothes produced from those recycled fibres will have limited sales markets.
With the drastic increase of dropshipping, this is a fast-growing issue.
The Role of DPP to Drive Sustainability and Social Responsibility
Digital Product Passports will hopefully lead to tightening practices and improving traceability in the production and processing of raw materials for textiles as well as more responsible production practices.
As the EU is such an important market and DPP’s are a compound of the environmental impact of products throughout the entire journey, requirements will ripple back through the supply chain. Producers will have to abandon today’s questionable methods or be prepared to lose sales that used to reach the EU later in the supply chain.
EU Regulations for Digital Product Passport in Textiles
The DPP regulations are essentially the same for all industries concerned. What will differ are the standards for products based on their characteristics. Obviously, the relevant data categories and units used cannot be the same for a chair, a sweater or a smartphone.
But nor can they be the same for a hat, a pair of trousers and a dress although all of them are textile.
Overview of the EU Requirements and Directives for Digital Product Passports
All details are not yet in place, but the DPP regulation stipulates:
Over time, ALL products sold in the European Union shall be accompanied by DPP’s, except for a few industries deemed sufficiently regulated already, like food and pharmaceuticals.
The requirement will be introduced gradually, by industry
The DPP should be unique for each product
The information should be provided in digital formats, through a mechanism (QR code, typically) to access that information
The information should be up-to-date and follow a standardised protocol for the kind of product
Data according to open standards, in interoperable format and machine readable, structured, and searchable
Lock-in effects to DPP service providers are not allowed.
Mandatory Data Categories for DPP Compliance
The details for each product category are still in the making, but the in general: the DPP should provide information on:
Product characteristics
Environmental impact of the item, from cradle to grave
Information on repairability
Information on how to reuse or recycle the product or components thereof
Verified certificates on responsible production (no deforestation, no child or forced labour….)
Timeline and Deadlines for Implementation
Textiles and Footwear are among the first industries where DPP will be required.
ESPR came into force mid 2024
The delegated acts, detailing the data, formats and units required for each product category are being worked on in the EU standardisation network. They are due late this year, 2025
DPP’s will be required by the end of 2027
How to Implement Digital Product Passports in Textiles
The main point about preparing for Digital Product Passports, if you’re in textiles or fashion or any of the other industries where it will be required from the end of 2027, is to get started. Here’s a short extract from this, our more elaborate post on the topic:
Step 1 – Inform Yourself, Get Engaged and Create Your Vision for DPP
Obviously, the very first step is to inform yourself what all this is about. Congratulations! You're already there, as you've found this site and read this.
Step 2 – Check Your Data Gaps – and Start Filling Them
As you learn about the details of the upcoming regulation, you will gain a better understanding of which data will be required for you to provide.
Start by identifying key data points that are likely to be required for DPP in your industry, the required formats and standards.
Map available data within your organisation against # 1
...and data from your sub-suppliers and the entire supply chain
Now you know which gaps you need to fill and can start planning to take what action is required.
Step 3 - Inform and prepare your organisation
By now, your picture of where you want to go and what you need to do to get there is clearer. Now, it's time (at the latest) to start to inform all and involve relevant internal teams.
Step 4 – Take stock of your available technology's ability to support DPP
Identifying the data to be supplied is one thing. Being able to supply it easily, continuously and securely, verified and up to date is another. Therefore, you need to check your available systems and possibly modify, supplement or replace some.
Challenges in Adopting Digital Product Passports in Textiles
Obviously, implementing Digital Product Passports will require considerable effort and changes, most of which are similar across industries.
Will Costs and Skills Required Be Prohibitive for Small Manufacturers?
As in some other industries, the textile industry is full of small and artisanal businesses. Craftsmen and -women who are skilled at designing and making garments, but not at advanced data management. Based on the way the EU has handled similar situations before, we’re confident that there will be some kind of exception or “light” version applied for artisanal and small businesses.
Data Locked in Legacy Systems
Maybe you already have an ERP system, a production control system or a supply chain system and are confident you can leverage it to provide you DPP’s. Double-check that assumption as soon as possible, is our advice. It isn’t guaranteed that the providers of those services are willing to let go of your data. Not without a charge anyway. And remember, a one-time export will not do the trick. It needs to be a continuous, automatic flow of updated data.
As mentioned earlier, the DPP regulation explicitly states that lock-in of DPP data is not permitted. It is supposed to be a distributed, transparent system.
Security and Access Permissions to Various Levels of DPP Data
Although most companies don’t go to the extent of some food and beverage manufacturers to lock their “original recipe” into a secure vault, the composition of products may very well be considered as “company confidential”. Therefore, there have been worries about the integrity of DPP data. Not everything should be accessible for everyone, obviously. You will need layers of access, of course. Some examples.
Consumers and retailers
Business partners
Customs and similar authorities
DPP oversight authorities
Internal
This creates several needs:
A Secure log-in system for all but the public
A system that differentiates between the various levels and only presents the applicable data
A classification system and process to ensure all data gets classified
A system to check and maintain integrity
Authenticity – Is the Garment (or Fabric) Really Authentic?
EUIPO, The EU Intellectual Properties Office, has stated that 5% – at least – of all products sold in the EU are imported counterfeits. Add to that any counterfeits produced within the EU.
As counterfeiting is rampant among prestige brands in clothing and apparel, we suspect that number to be even higher in textiles and footwear.
What good is the DPP data if the item in front of you is counterfeit? Expect counterfeiters to copy also the QR codes of the genuine items so you will get the DPP data of the real thing but hold a counterfeit that is nothing like it in inputs or quality.
Therefore, we hope that the DPP process will comprise a product authentication feature to ensure that both items and data are genuine and apply to the actual item.
Challenges Particular for the Textile Industry
Still, there are some challenges which are special for the textile industry (albeit maybe not unique).
Integrity of labels – The QR code or other “key” to the DPP data is supposed to be securely joined with the item. Usually, garments are labelled either with a sowed-in label or a label hanging in a string made of fibre or plastic. Neither is fake-proof. One could imagine sowing in an RFID transmitter, but would that be much more difficult than exchanging a sowed-in label? Probably more expensive too.
Longevity of labels – For the benefit of the second-hand market and recycling, the QR code or “DPP key” should live as long as the garment, which means not being easy to cut off, wash safe and resistant to wear and tear.
For fabric, the question arises where to put it? At the centre of the roll of fabric or at the outside end? Or elsewhere? If only at the outside, how do you find the DPP data later, once you’ve cut the first piece from the roll?
How do deal with DPP data when recycling fibres?
We’re sure there are others. If you see another challenge specific to textiles, please let us know in a comment. We’ll be happy to update this text with your contribution.
The Future of Digital Product Passports in Textiles
Implementing Digital Product Passports in the textile industry will bring some unique challenges in addition to those experienced in other industries. But do we have a choice? Not really.
Not if we want to be able to sell our products, as final products or inputs to others, in the European Union after 2027.
Not if we want to leave a habitable planet for our grandchildren and future generations to inherit and inhabit.
So, instead of seeing the introduction of the DPP regulation as “another case of meddling by the authorities”, let’s try to take a positive approach instead. How about thinking of it as:
A way to promote quality (including environmental quality) over quantity
A way to improve circularity and re-use of our clothes
A way to improve labour conditions among those producing textiles and garments as well as living conditions for people living where textiles and clothes are produced or processed, or where the mountains of “recycled” textiles end up.
A way to favour serious businesses over rogue actors and counterfeiters
A novel way to leverage consumer purchasing power instead of rigid and detailed regulations
We Help Businesses Implement Digital Product Passports and Leverage the Technology for New Business Opportunities
We provide the “parallel data supply chain” to compose, handle and present your Digital Product Passport data. We do it in an efficient and transparent way that is easy to maintain.
And we advise you to get a good start on your way to DPP.
Image by stevecoleimages on iStock
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