Digital Product Passport for Fashion
The Digital Product Passport turns a garment into a data record. Under the EU Ecodesign for Sustainable Products Regulation, products placed on the EU market will have to carry a data carrier, in practice a QR code on the label, that opens a structured record of what the product is made of, where it came from and what can be done with it at the end of its life.
Textiles and footwear are in the first wave. The detailed rules arrive through a delegated act expected in 2027, followed by a transition period of around eighteen months, which puts the first obligations around 2028. That sounds far off. It is not, because the data a passport asks for is created while a collection is being developed, not when it is sold.
What the passport has to carry
The final list comes with the delegated act. Working drafts run to roughly fifty data points, and they group like this.
- Product and producer identification, including a unique identifier per item or batch.
- Material composition: fibre type and share by weight, components, trims.
- Substances of concern and chemical compliance.
- Durability and repairability, expressed as scores rather than claims.
- Recycled content and recyclability, which depends on how many fibres are blended.
- Care and repair instructions, and what to do with the product at end of life.
- Certifications, where you hold them.
Where each piece of data actually lives
This is what decides whether the passport is a data entry job or a two year project.
| Data point | Where it sits today |
|---|---|
| Fibre composition by weight | Tech pack, mill specification |
| Country of each production stage | Supplier list, often final factory only |
| Substances of concern | Chemical file held at the dyehouse |
| Durability and repairability | Physical test reports, if anyone ordered them |
| Recycled content | Supplier declaration and the certificate behind it |
| Care and repair | Written for the label, rarely kept as data |
Most brands hold all of this somewhere. Very few hold it in one place, per style, in a form a machine can read. That gap is the work.
What to do before the rules land
- Take one collection and try to fill the list above for every style in it. What you cannot fill is your real gap, and it is usually not the part you expected.
- Fix the intake, not the archive. Add the missing fields to your tech pack and to what you ask a supplier for before the order is placed. Chasing the data afterwards costs several times more and often fails.
- Decide who owns the record. In most studios nobody does, which is exactly why the data scatters across email, spreadsheets and the heads of two people.
It is the same data as EPR
The passport, the Extended Producer Responsibility fees you pay per item and the ecodesign requirements on the product itself all draw on one set of facts: fibre composition, supplier identity, traceability, documentation. Build that once and it serves all three. Treat them as three separate compliance projects and you pay for it three times.
EU Textile EPR: what it means for your brand covers the registration and fee side.
Start here
We wrote the practical guide to the EPR half of this: The Fashion Guide to EU Textile EPR: A Practical Compliance Playbook.
If you would rather walk your own range through the data list above, the first 30 minutes are free. A Sustainability Consultation goes deeper: 60, 90 or 120 minutes, from 150 EUR.
This page explains publicly available EU regulation and is not legal advice. The textile delegated act is not final, so the data list above reflects working drafts and will be updated when the official requirements are published.
