Explainer: How Fashion Brands Should Prepare for Mandatory Digital Product Passports

Fashion brands would be forgiven for not knowing exactly when the EU will begin mandating that all new items sold in the region come with digital product passports — unique digital identities containing traceability details and other information.

Since the European Commission first started talking about requiring DPPs in its Ecodesign for Sustainable Products Regulation in 2024, the final text for its rules on textiles has experienced multiple delays. Even searching the EU website does not offer exact dates for when draft rules, which could at least be used as guidance, can be expected — let alone when the DPP requirements will come into effect.

The situation has left many companies, and even experts, confused about when businesses need to be in compliance.

Although a number of brands, particularly in luxury, are already charging ahead and creating DPPs for millions of products, the regulatory uncertainty has led many others to “put the pen down” and wait for clarity, said Pierre-Nicholas Hurstel, chief executive and co-founder of DPP platform Arianee, which works with labels like Mugler and luxury watch companies.

H&M, for example, said in a statement that while it fully supports DPPs as a “key enabler of product circularity and transparency” and considers them a strategic priority, “a broad rollout of DPP across all products is not imminent.”

Brands won’t be able to wait indefinitely, however. Implementing DPPs will require an operational transformation for many companies.

“This is one of the most cross-functional internal operational projects you can have,” said Iris Skrami, founder of DPP provider Renoon, noting it touches “production, technology, marketing, design — everything.”

The most time-consuming work is not building a passport interface but organising and verifying data across tiers of supply chains, especially upstream.

The clock is ticking, this year but brands still have time to get things in order.

What’s the deadline for implementing DPPs?

The final text for textiles is now planned to be finalised in late 2027, with an 18-month timeline to comply and longer transition periods possibly under consideration, according to the European Commission’s DPP team.

In an email, the team clarified that textiles and apparel are among the priority categories listed in the Commission’s ESPR Working Plan for 2025–2030, and “the Commission anticipates adopting the delegated act for textiles in late 2027, pending standard scrutiny procedures.”

Crucially, the team emphasised that “late 2027” is not the start of enforcement. That will be decided closer to date. It also noted that draft rules are expected to be published months earlier via the EU’s “Have Your Say” platform, creating a window for brands to anticipate requirements before they become binding.

A forthcoming EU DPP registry set for June 2026 will act as a central registry of unique product identifiers — essentially a digital serial number — designed to support tracking and enforcement, but it will not store full passport data. Instead, brands and their DPP providers will be responsible for managing their data.

Could there be any other changes or delays?

Part of the murkiness around DPPs comes from significant changes in the EU’s political environment, including a more “pro-business” stance in policymaking that has led several sustainability-linked reporting regulations like CSRD, CSDDD and EUDR to be delayed or weakened.

The abrupt shifts have raised the question of whether DPP requirements might similarly soften.

“The Commission did a lot of self-inflicted harm to itself by changing green laws which were just fresh out of the press,” said Baptiste Carriere Pradal, co-founder of ESG policy advisory firm 2B Policy, which helps companies with upcoming EU regulations. “It’s now creating a lot of confusion.”

Pradal said the reversals have undermined trust from the fashion industry, making many companies hesitant to act.

As of now, there’s no indication that the deadlines will change, although the rules are still being finalised. But the uncertain environment means brands need to keep an eye on the situation.

What should brands do this year?

For most companies, the coming 12 months will not be about achieving full regulatory compliance, but about laying the digital foundations that will make compliance possible when enforcement begins.

Many brands are also thinking about what value they can get from their investment in DPPs beyond treating them as a narrow compliance tool. Companies are experimenting with using them for greater storytelling or enabling easier resale for shoppers who buy them.

1. Treat DPPs as systems architecture

Across providers, policy advisors and early brand adopters, one message is consistent: The biggest risk now is not choosing the “wrong” technology standard or data to include, but delaying the operational transformation required to organise product-level information across fragmented supply chains.

“What brands underestimate is the work required before they even get to a provider,” said Aura’s head of membership and growth, Costanza Nicolosi. “You need to understand where the information is, collect it and structure it. You can’t just put it in a bucket.”

Renoon’s Skrami echoed the point, saying the EU isn’t asking for separate ingredients but a “baked pie” made of structured, product-level data across systems.

For brands with complex outsourcing models, the task can quickly escalate from manageable to overwhelming without early preparation, Nicolosi added. Many brands still hold critical information, from data on durability testing to supplier documentation, in disconnected systems and files. Without a unified data backbone, even the most sophisticated DPP interface risks becoming an empty shell. Brands need to work on standardising how they gather and organise data, including upstream with suppliers.

“One of the key bottlenecks… is actually factory-level training, because most fashion companies don’t own their supply chains [so] it means engaging with a lot of third parties,” said Vanessa Hallik, founder and co-CEO of Another Tomorrow, a sustainable luxury label which recently joined the Aura Blockchain Consortium. “I’d say brands should pick a SKU range that has a shared set of materials and manufacturing partners, and apply the DPP there. It almost becomes like an internal mini pilot. Then you can go through the entire process of traceability, certifications.”

2. Find the right partner and start early

Even if brands feel like they have time, they should start speaking to DPP providers sooner than later.

Not all brands and their providers are suited to each other, and providers say it’s crucial for brands to approach multiple partners to find one that works for their products. The Aura Blockchain Consortium — an alliance of luxury brands using blockchain for traceability — and Arianee, for example, work with only luxury clients, while others like Eon and Renoon have a broader slate of companies they can work with.

“In next year, it’s paramount for the brand to get a sense of what the solutions are, and finding a partner will be key,” said 2B’s Baptiste.

“Once the requirement comes, you will be busy meeting the requirements of the law. You will not have time to play around comfortably for one or two years with different service providers, to understand which one meets your requirements, you can plug in easily and make work most effectively. ”

3. Start with the physical–digital link — then enrich data over time

Several providers emphasised that brands do not need perfect data to begin. Worry first about figuring out how to create the product’s physical link to the DPP, whether through QR codes or NFC tags, a process that may involve changes in manufacturing. That foundation allows companies to create a persistent product identity that can be enriched as requirements become clearer.

Both Arianee and Eon emphasised that DPPs are designed to be dynamic rather than static, allowing brands to add certifications, impact data and services over time rather than delivering everything at once.

4. Pilot for consumer value

While regulations are the immediate force driving brands to adopt DPPs, providers say long-term differentiation will depend on how useful DPPs become to customers.

Aura’s pilots, for example, focus on usability and understanding what makes consumers return to scan a product more than once. Repair, tailoring, authentication and resale services consistently emerge as the most compelling use cases.

The Cirpass-2 Consortium, an EU-backed initiative designed to trial the technical backbone of DPPs through multiple pilots, suggests brands provide individual items with their own DPP — rather than assigning one DPP to all products of the same design — for this reason. It enables features such as repair records, resale and authentication and even though individually tagging items means marginally higher costs per garment, it offers greater functionality to achieve circularity and update traceability data over time.

Ultimately, however, the bottom line is brands must stop framing DPPs as another reporting obligation.

“This isn’t like publishing another sustainability report,” said Carolyn Bernier, lead for the Cirpass-2 pilot. “Under ESPR, DPP is tied to the right to sell. If you can’t comply, you can’t access the market.”

Brands that want to sell to European consumers will need to get ready, and while uncertainty remains around technical standards, brands already have enough information to begin laying the foundations.

“Brands have time to act,” said Pradal. “They don’t have time to lose.”

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