A Race Against Time: Companies Need to Set House in Order before DPPs Kick in

Since March 2022, when it appeared that DPPs would sooner or later be here, at least in Europe, there has been much activity at the interface between fashion and tech companies. But how much of such "activities" are indeed work towards a DPP-driven future in right earnest, and how much has it been hogwash, as the textiles-fashion industry is infamous for?

Mónica Rodríguez, Co-Founder and CEO of Spanish startup Recovo, certainly has noticed “a significant surge in activities among textile, apparel, and brands towards embracing the concept of DPPs since its proposal. The industry has recognised the potential benefits of increased transparency, traceability, and sustainability offered by digital passports. Fashion brands are actively exploring technologies such as blockchain, RFID, and digital platforms to create and manage these passports.” Recovo is a B2B platform located in Spain which specialises in selling deadstock fabric which would otherwise be classified as textile waste.

It is, however, not an open and shut scenario. Rodríguez points out that “it is important to note that the adoption of DPPs is a complex process requiring significant investments in technology infrastructure, data management systems, and employee training. While some fashion companies have been quick to embrace this transformation, others may still be in the early stages of understanding and implementing digital passports. Nonetheless, the fashion industry as a whole has demonstrated a growing commitment to the DPP-driven future.”

Holly Berger, Marketing Director of Switzerland-based traceability platform Haelixa, has a similar understanding, but cautions about a brand-manufacturer disconnect. As far as brands are concerned, “there is a lot more activity and interest in understanding their supply chains. Most of it is driven by the DPP and other potential legislation requiring evidence of ingredient labels and product claims. From manufacturers, the feedback is that they want to start implementing traceability to comply with DPP needs, but find that the brands are reluctant to commit. Manufacturers are looking at all options within the traceability community—both digital and physical.”

Cooperation is going to be crucial. Tobias Herzog, Managing Director of Tailorlux GmbH - integrity solutions, takes a measured approach: “We all do not know how this will unfold in 2026, and we see a lot of cooperation projects between solution providers for the DPP and the textiles industry. The DPP is the new buzzword to label all activities to have data about a product (that is) digitally available. What we do know is that the DPP will look beyond the product, and this is where materials matter.”

Even Luca Boniolo, Senior Consultant with Ohana Public Affairs which specialises in sustainability strategies for the EU, feels “it is difficult to say (about the state of activities) without having the full picture. My impression is that it has attracted less attention than ecodesign requirements. However, there is clear interest from the industry to be able to digitise product information and provide that information digitally. Not only in the EU, but in the US too.”

But already working on the issue is CIRPASS, a collaborative initiative to prepare the ground for the gradual piloting and deployment of a standards-based DPP aligned with the requirements of the ESPR. The project,funded by the European Commission under the Digital Europe Programme, has 31 consortium partners including global nonprofit Textile Exchange which among other things develops, manages, and promotes a suite of leading industry standards.

Evonne Tan, Senior Director of Data and Technology at Textile Exchange, chips in: “(The) DPP (concept) comes up often in discussions around digital solutions for the textiles sector. Most pilots do take into consideration ESPR requirements, but it remains unclear what the requirements are and how DPP will be implemented and what the sector needs to have in place.”

The fashion industry, historically, has been laggard in adopting technology. Many proponents would beg: yes, but that was in the past; it (the industry) is now fast catching up.

So, giving them the benefit of the doubt in the DPP context, it would be interesting to see what people in the thick and thin of things have so far noticed.

Says Rodriguez, “From what we have observed the fashion industry has indeed been historically slow in adopting technology. However, there has been a notable shift in recent times, and companies are becoming more prepared to embrace Digital Product Passports. To ensure a smooth transition without upsetting the entire applecart, companies in Europe need to focus on several key aspects.”

And, in this she makes two points: “First, they should invest in robust technology infrastructure and data management systems to support the implementation of DPPs. Second, they need to provide adequate training and resources to their employees to facilitate the adoption of new processes and practices. Additionally, collaboration and standardisation efforts within the industry should be encouraged to establish common frameworks and protocols for digital passports, reducing disruption and ensuring a more harmonised approach. By addressing these areas, companies can navigate the challenges associated with change and enhance their readiness to adopt Digital Product Passports in a way that minimizes disruption to their existing operations.”

A lot of spadework will certainly need to be done before companies can get into the groove, and people will need to look beyond their noses. Herzog explains why and how: “The DDP is related to a more holistic view on products where the industry will be forced to look beyond first tier suppliers and the shelf life of a product. This means that new supply chain partners will be needed, and existing relationships might need a new basis for collaboration and a new level of trust because materials and upstream data must be valid.” That itself will take some time and effort.

The DPP might only be a tool, but what it also means is that for it to achieve the objective, it cannot be business as usual for companies. Berger underscores this contention when she points out: “Adopting a change in practices is often a struggle in fashion. In our experience, brands are interested in piloting new solutions and technologies. There needs to be more understanding of what the new legislation requires and how they may be held accountable.”

The key to how DPPs will eventually work will hinge on when/how the ESPR becomes a reality. The European Parliament has only so far voted on the committee report. It might be a while before this trickles out through the member states, and as the EP research briefing says: “The regulation would enter into force 20 days after its adoption and would be applicable immediately. However, since this would be a framework regulation, new ecodesign requirements would be applicable to specific groups of products only after the adoption of product-specific delegated acts.”.

So, isn't working on DPPs— in a way—even before the ESPR becomes effective kind of jumping the gun? Or, is it that companies should start work on DPPs now itself because it is an eventuality?

Boniolo is clear: “For textile products, the DPP will be a reality because we know that the EU will set ecodesign requirements for textile products. Following the development of the CIRPASS project, operators will have a sense of what information they might be asked to provide, allowing them to assess any information gaps they might have. Obtaining and organising data could be more challenging than anticipated. Furthermore, operators could already assess the feasibility of attaching data carriers to the products. Finally, being able to communicate to consumers voluntary information could also be a business opportunity for companies.”

In fact, it could be a race against time. Herzog believes that the work needs to start now. “By simply trying to map out procurement risks and existing knowledge on recyclability of materials or their provenance is a big chunk of work. If you realise that a material you are using now in your product will not meet ESPR requirements like durability and circularity, the time to act is relatively short. The adjustments in software and protocols in exchanging data are something that can be achieved faster when the task becomes apparent. My message would be to all companies to just start and try things without looking at the 100%-one-stop-shop solution.”

From Recovo's perspective, Rodriguez says, while the effectiveness of DPPs does rely on the implementation of the ESPR, it is not premature for companies to start working on DPPs beforehand. Considering that the adoption and implementation of DPPs can be a complex process, starting early allows companies to gain valuable insights, develop necessary infrastructure, and establish internal systems to align with the future requirements of the ESPR.”

And why will it all need to work? Says Berger: “DPPs will help companies understand what they need to share and what they will be accountable for sharing. ESPR will need some traceability to help ensure that companies follow the legislation. DPP will be a warmup for the time when more detailed ingredient information will need to be transparent.”