DPP: The who, what, where and when, and how to prepare
The Digital Product Passport (DPP) is coming. All products on the European market will have to be provided with a product passport, also known as a “digital twin”, in the (near) future: a digital file that provides comprehensive information about the environmental impact of a product throughout its entire life cycle. This is expected for textile products by the beginning of 2026.
The concept of the Digital Product Passport (DPP) was introduced in the EU strategy for sustainable and circular textiles and refined in the Ecodesign for Sustainable Products Regulation (ESPR).
The Ecodesign for Sustainable Products Regulation (ESPR) came into effect on 18 July 2024, says lawyer Judith Bussé. “This is framework legislation, which means that it provides a framework for further implementation and concretisation per product category and sector. By the end of December 2025, standardisation organisations must provide harmonised standards for the DPP system. In January 2026, a first delegated act (or “delegated act“) for textiles is expected.”
“Specifically for textiles, it is expected that the first standards will be published in January 2026, which companies will have to comply with 18 months later,” says Bussé.
The bigger picture
The DPP is one of the measures that will be introduced to make the EU more sustainable and to be a circular economy in 2050. There are still many laws and directives in the pipeline that are part of the European Green Deal. Think for example of the Dutch Extended Product Responsibility (also known as the UPV in the Netherlands), the Right to Repair, the Corporate Sustainabilty Reporting Directive(CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).
NB: If companies become more sustainable to comply with new regulations such as the DPP, they will also automatically be better prepared for other sustainability legislation and directives.
The European Commission will set up a special web portal where DPPs will be registered. This central database will act as a register containing all specifications and will be accessible not only to companies, but also to consumers.
“By creating this easily accessible and verifiable digital file, the DPP aims to improve transparency, traceability and trust throughout the supply chain, from manufacturers to consumers and recyclers, so that consumers can make more sustainable and informed choices,” said Jake Hanover, director of digital products and apparel solutions at Avery Dennison, about the introduction of the DPP in a previous conversation with FashionUnited.
The exact form of the “digital twin” data carrier, such as a QR code, barcode, RFID label or an NFC chip linked to blockchain, has not yet been determined and will be determined later by the European Commission.
The DPP of products will have to contain information about the sustainability of the product and the entire life cycle, such as the materials used, recycled materials, energy consumption, CO2 footprint and the degree of circularity of a product (think about ease of repair and reusability), as well as how to dispose of them.
Implications for the clothing industry
The introduction of the DPP will have significant consequences for the fashion sector, as this information is currently not provided or not (always) completely available due to a lack of transparency in the value chain (which is complex and extensive, with many links, ed.).
The upcoming DPP will therefore have a major impact on clothing companies. How will they collect data for each part of the supply chain, and later manage and present it?
Moreover, the majority of fashion companies are not so keen on sharing (business-sensitive) information for strategic and financial reasons, such as possible competitive advantage. So it will also be a challenge for them to find a balance between transparency and protecting business interests.
How can you as a fashion company prepare (now) already?
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What are the next steps? How to proceed with DPP?
Before the DPP comes fully into effect, it still needs to be definitively approved by both the European Parliament and the Council of the EU. After approval, the legislation will be further implemented and enforced. The regulation will therefore be crystallised in the coming period and it is possible that some things will be changed.
Who will control the implementation of the DPP will depend on the EU’s chosen approach. In broad terms, a number of things have already been laid down in the regulation, says Bussé. “Customs will check whether products entering the EU have a DPP. Specific bodies in each EU country will also ensure that products on the market comply with these rules. Member states will have to ensure that these checks are well organised and monitored so that everything runs according to the new legislation.”
This DPP article will be updated regularly by FashionUnited. Current information about the DPP can be found on the website of the European Commission and the official policy documents.
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Sources:
– Input Judith Bussé, founder of law firm Pivot Law, 29 July 2024.
– European Commission, The Regulation for the introduction of the Digital Product Passport, 13 July 2024.
– European Commission, Ecodesign for Sustainable Products Regulation (ESPR), in force since 18 July 2024.
– European Commission, Communication from the commission to the european parliament, the council, the european economic and social committee and the committee of the regions ‘On making sustainable products the norm’, 30 April 2022.
– Dopper.com ‘Recipe for transparency: Trace your impact with our Digital Product Passport’, 7 April 2024.
– CIRPASS ‘A study on DPP costs and benefits for SMEs, February 2024.
– Carbonfact article [Textile industry] DPP: Understanding the EU’s Digital Product Passport and How It Impacts Fashion Brands, by Lidia Lüttin, 9 February 2024.
– Articles from the FashionUnited archive by journalists Rachel Douglass and Simone Preuss.
– Parts of this article text were generated with an artificial intelligence (AI) tool and then edited. This article originally appeared on FashionUnited.NL. Translation by AI, edit by Rachel Douglass.
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