What Is a Digital Product Passport and Why Should Brands Care?

A new regulation is making its way through the European Union, and it will eventually touch nearly every garment exported into that market. The Digital Product Passport, or DPP, is not yet law for textiles. The detailed rules are still being drafted.

Understanding Digital Product Passport (DPP)

A Digital Product Passport is a structured digital record attached to a specific product. It is accessed by scanning a QR code or similar data carrier on the garment or its packaging. It is not a marketing page, but closer to a verified data file that follows a product through its life (from raw material to end product).

The regulatory framework behind it

The DPP is part of the EU's Ecodesign for Sustainable Products Regulation, which entered into force in July 2024.

ESPR is a framework regulation, meaning it sets the legal structure but leaves the specific requirements for each product category to separate delegated acts.

The delegated act for textiles is expected around 2027, with a transition period of roughly 18 months after adoption. Realistic estimates place mandatory compliance for apparel somewhere between 2028 and 2029, though some product categories may move sooner under pilot schemes.

What information it is expected to hold

The exact data fields are still being finalised, but the direction is consistent across draft studies.

A draft specification published by the EU's Joint Research Centre in May 2026 outlines around 49 data points across four categories: 

• Product identification
• Producer identification
• Product information
• Compliance documentation.

Expect material composition, country and facility of manufacture, environmental footprint at the manufacturing stage, substances of concern, and information relevant to repair and recyclability.

Some of this will be visible to anyone who scans the code. Other parts, such as detailed supplier identities, are likely to remain restricted to regulators and supply chain partners.

Digital Product Passport (Summary)

• DPP is a structured digital record per product, scanned via QR code
• Part of the EU's ESPR regulation, in force since July 2024
• Not yet mandatory for textiles, rules still being finalised
• Expected 2027 adoption, compliance likely 2028-2029
• Around 49 data points across 4 categories
• Covers material composition, origin, footprint, recyclability
• Some data public, supplier details restricted
• Applies to all brands selling into the EU, any size
• Shifts sustainability claims from stated to verified
• Artisan-led brands have an edge with short and traceable supply chains
• Most artisan data isn't digitised or standardised yet
• Actionable: Document materials and artisans consistently

Who the Regulation Applies To

The DPP will apply to any brand selling textile products into the EU market, regardless of where that brand or its manufacturing is based.

Size offers some flexibility on timelines for smaller enterprises, but not exemption. A small workshop exporting a handful of styles a year falls under the same eventual requirement as a large manufacturer shipping thousands of units.

A shift in how compliance gets verified

Most existing sustainability claims in fashion are self-reported. A brand states its credentials, and buyers largely take that statement at face value, sometimes backed by a certification logo.

The DPP changes that model. The data has to be structured, attached to a specific product, and accessible to anyone, including regulators, who scans the code. This is a meaningfully different standard of accountability than the industry has operated under so far, and it applies across the board, not to any one type of brand.

Set the regulatory jargon aside and the DPP is really a sustainability tool at heart. Regulators built it because brands kept making environmental claims that nobody could check. Now those claims will need data behind them, not just words. What the DPP actually requires lines up with what sustainable fashion has been pushing for all along.

• Cuts waste at the design stage by giving brands and buyers visibility into material composition and origin before a purchase is made
• Extends product life by surfacing repair and recyclability information that is currently buried or absent entirely
• Reduces greenwashing by requiring claims to be tied to structured, checkable data rather than marketing language
• Supports circularity by making end of life information, recyclability, disassembly, material recovery, part of the product record itself
• Shifts accountability from brand statements to verifiable supply chain data, changing who carries the burden of proof

The Opportunity Hidden Inside the Compliance Requirement

It is worth resisting the temptation to treat the DPP purely as a cost of doing business in Europe. Brands built around authentic, traceable, small-batch craft have a structural advantage waiting to be made visible.

Turning verified origins into a competitive asset

European buyers, both consumer-facing and wholesale, are increasingly making sourcing decisions based on documented transparency rather than general sustainability claims.

A craft brand that can show, product by product, exactly which artisan made an item and under what conditions has something far more substantive to offer than a brand relying on broad ethical sourcing language.

Once the infrastructure is set to capture and present that information digitally, it becomes a story that can be told at the point of sale, not just a regulatory requirement satisfied in the background.

Early preparation reduces long-term cost

Brands that wait until the delegated act is finalised will be racing to build data systems against a fixed deadline, with their suppliers asked to provide retrospective information under pressure.

Brands that begin now, even informally, by documenting material origins, recording artisan and workshop details consistently, and noting basic process information for each product line, will face a smaller and cheaper task later.

What This Looks Like in Practice

Preparing for the Digital Product Passport does not need to mean adopting an expensive enterprise platform immediately. It means starting to build the habits and records that any future system will need to draw on.

This starts with documentation that is already mostly available within direct artisan relationships, recorded more consistently: which artisan or workshop produced a piece, what fibres and dyes were used, where the raw material originated, and how the finished product travelled to market.

It extends to keeping records in a structured, digital format rather than informal notes, even something as simple as a consistent spreadsheet, so that the information can later be migrated into a compliant system without having to be reconstructed from memory.

It also means staying informed as the delegated act for textiles moves towards finalisation, since the scope and exact data fields will continue to be refined through 2026 and 2027.

A Regulation Worth Building Towards

Strip away the acronyms and delegated acts, and the Digital Product Passport is asking fashion to do something it has avoided for a long time: prove its sustainability claims rather than simply state them.

At TuDuGu, we see the DPP less as an external mandate to comply with and more as a regulation built around an assumption we already hold - that transparency only means something when it can be verified, and that a product's environmental and social footprint should be traceable rather than asserted.

Whether a brand works with artisans or with industrial manufacturing, the direction is the same. Fashion is moving towards a model where products are expected to carry their own evidence.

We would rather be ready for that shift than reacting to it, and we think every brand serious about sustainability should be thinking the same way.