Digital Product Passports in Fashion: How to Prepare Your Data for EU ESPR

Digital Product Passports (DPPs) will be mandatory for EU fashion brands under the Ecodesign for Sustainable Products Regulation (ESPR). While most can build a pilot, scaling across an entire portfolio is where the real challenges emerge.

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Digital Product Passports (DPPs) will be mandatory for EU fashion brands under the Ecodesign for Sustainable Products Regulation (ESPR). While most can build a pilot, scaling across an entire portfolio is where the real challenges emerge.

• What a DPP is: A unique digital record, accessed via QR code or NFC, containing verified data about a product’s materials, origin, environmental impact, and end-of-life guidance
• The regulatory deadline: The EU DPP registry goes live July 2026. The Textiles Delegated Act (DA),which sets specific data requirements for apparel, is expected late 2027, with at least 18 months to comply after that
• Who it affects: Fashion brands with EU market exposure, particularly those with complex, multi-tier supply chains
• Three things that trip brands up: Data that’s inconsistent or held across disconnected systems, suppliers who aren’t ready to provide structured environmental data, and no clear internal owner for the programme
• What good preparation looks like: Auditing your current data against likely ESPR requirements, deciding who leads cross-functionally, and starting supplier conversations now, before the DA forces the issue
• The data privacy question: Not all DPP data needs to be public. ESPR frameworks allow for selective disclosure, but understanding how access tiers work needs to happen before you design your data architecture

Fashion brands across the world are working on their first Digital Product Passport right now. They’ve picked a hero product, chosen a QR code provider, assembled some supplier data, and produced something that technically works. It’s a reasonable starting point.

The problem tends to emerge when someone asks, ‘How do we do this for the rest of our products?’.

That question, scaling from one product to an entire portfolio, is where DPPs stop being a technology project and start revealing something more uncomfortable: gaps in data quality, unclear ownership, suppliers who aren’t ready, and internal teams that have never had to collaborate in this way before. The passport itself is often the easy part. What it exposes underneath is harder to reconcile.

This isn’t a technical guide to building a DPP. It’s about what brands with EU market exposure need to think through now, before mandatory requirements land, because the groundwork will take longer than most people expect.

The regulatory framework is the EU’s Ecodesign for Sustainable Products Regulation (ESPR), which entered into force in July 2024. Under ESPR, every product sold in the EU will eventually need a digital record – a unique identifier, typically accessed via QR code or NFC tag, containing verified information about its materials, origin, manufacturing processes, environmental impact, and end-of-life guidance.

According to the European Commission, up to 80% of a product’s environmental impact is determined at the design stage. For an industry built on high-volume, resource-intensive global production, that makes textiles an obvious priority.

For fashion and textiles, the timeline looks like this: the EU’s DPP registry goes live in July 2026 – a centralised index of unique product identifiers, though it won’t store passport data itself. The delegated act for textiles, which will set the specific data requirements for the category, is now anticipated for late 2027, following confirmation from the European Commission’s DPP team. Enforcement comes separately, brands will have at least 18 months to comply once the DAis finalised, with longer transition periods under consideration for more complex industries.

That might sound like plenty of time. But the DA will require verified data across multiple tiers of the supply chain, at SKU level, consistently maintained and machine-readable. Building the systems and relationships to deliver that reliably across a complex product portfolio is not a simple 18-month task.

The DAs will be finalised in 2027, with enforcement expected 12-18 months later. That’s just six fashion seasons for brands to embed passport data into every SKU.

Early DPP implementations are expected to focus on material composition, key manufacturing processes, core environmental indicators (climate, energy, water), chemical compliance, and basic traceability information. More advanced lifecycle and circularity data will be phased in over time. But even the baseline requires a level of data discipline that most brands haven’t yet had to apply at scale.

Getting a DPP built for one product is a project. Getting DPPs built for 500 products, across multiple seasons, with data flowing reliably from tier one and tier two suppliers, updated as products change – that’s a fundamentally different challenge.

Most brands discover this gap when they try to move from pilot to programme. Three things tend to surface.

The data isn’t where you think it is

Material composition data, the basic starting point for any DPP, is often held across multiple systems, collected inconsistently, and not subject to any formal verification process. Fabric content on a tech pack doesn’t always match what’s on the care label. Country of origin data can be incomplete or out of date. Chemical compliance certifications exist somewhere, but not in a format that can be pulled into a digital record at speed.

“The real opportunity with Digital Product Passports isn’t the passport itself. It’s the discipline of building reliable product and supply chain data. Brands that invest in that now will not only be ready for ESPR, they’ll be better positioned to make smarter sourcing, design and circularity decisions.” – Millie Baldwin, Senior Consultant, Seismic

This isn’t criticism, it’s just how most fashion businesses have operated until now, because there was no regulatory reason to hold this data differently. DPPs are changing this; the data needs to be structured, verified, and accessible at the product level, across the full range, on an ongoing basis.

Suppliers aren’t ready either

The data requirements for a DPP don’t stop at tier one. Verified information about fibre origin, dyeing and finishing processes, and environmental certifications requires engagement with suppliers who may never have been asked for this kind of information before, in a structured format, with evidence attached.

For brands with supply chains spanning dozens of factories across multiple countries, this is a significant supplier engagement challenge. It requires investment in relationships and communication, clear expectations, and in many cases practical support for suppliers who lack the systems to provide what’s being asked of them. Some brands are already building this capacity such as Nobody’s Child who recently published their DPP playbook.

Nobody owns it

This is probably the most common, and most underestimated, obstacle. DPPs sit uncomfortably across functions. Sustainability teams understand the regulatory context but often lack access to product data systems. Product and innovation teams understand the data but don’t own the compliance agenda. Supply chain teams manage supplier relationships but haven’t traditionally been responsible for data collection at this level of granularity.

The result is that DPP projects stall not because the technology is difficult, but because there’s no single function that can credibly own the full picture. Someone does need to lead this work, ideally with the authority to coordinate across product, sustainability and supply chain teams. For many brands this is new territory, so establishing clear ownership early can make a significant difference to how quickly DPP programmes move from discussion to implementation.

The brands navigating this well tend not to be the ones with the most advanced DPP programme. They’re the ones doing the less visible work first: getting their data in order, agreeing who’s responsible, and building supplier relationships that can actually deliver what’s needed.

A few things worth doing now, regardless of where you are on the DPP journey:

• Run a data audit against what ESPR will require. Material composition, country of origin, manufacturing stages, environmental certifications – map what you actually have against what a compliant DPP will need. The gaps are usually clarifying and often surprising.
• Decide who owns this. Not in a nominal sense, but genuinely, who has the authority and cross-functional access to drive data collection, supplier engagement, and system changes? If the answer is unclear, that’s the first thing to fix.
• Start the supplier conversation early. Suppliers who’ve never been asked for structured environmental data need time and support to provide it. Beginning that engagement now, even informally, builds the relationship and surfaces problems before they become compliance issues.
• Pilot with intent. If you’re running a pilot product, treat it as a test of the full process, not just the technology. What does it take to collect this data? Who needs to be involved? What breaks when you try to do it at speed?

Track the DA. The specific data requirements for textiles will be defined in the DA expected in late 2026/early 2027. The direction is already clear enough to prepare against but the detail matters, and brands should be tracking it closely as it develops. The European Commission is regularly sharing updates here.

At Seismic, we work with fashion brands that are trying to make DPPs workable in practice, as well as compliant on paper. That tends to mean helping teams figure out the organisational and data challenges before they get to the technology, because in our experience, that’s where most of the real work is.

Our upcoming webinar on Digital Product Passports will dive deeper into this topic, register here. 

If you’re a Head of Sustainability, Product, or Supply Chain working through what DPP implementation actually looks like for your brand, let’s talk.