The textile sector is preparing for a digital turning point. With the publication of the Study on DPP content for textile apparel products under ESPR, the process launched by the Ecodesign Regulation takes a decisive step toward defining the data, responsibilities, levels of granularity, and access conditions that may shape the Digital Product Passport (DPP) for textile apparel. These indications are intended to feed into the future delegated act, currently expected around 2027 according to the 2025–2030 Working Plan.
The document substantially updates the issues left unresolved by the 3rd Milestone Report, which had defined many design options as information requirements intended to be conveyed precisely through the DPP, without yet clarifying the data architecture, the level of detail, or the access rules through which this would happen. The newly published document addresses this missing step: it does not introduce definitive legal obligations, because it remains part of the preparatory study and may still be amended following stakeholder consultation and the subsequent impact assessment. However, it already shifts the center of the discussion from “which environmental requirements might be imposed” to “which data need to circulate, with what structure, at what level of detail, under which responsibilities, and with which access rights.”
What is the Digital Product Passport?
The Digital Product Passport is the digital infrastructure through which the information requirements of the Ecodesign for Sustainable Products Regulation (ESPR) become accessible, verifiable, and updatable. It is a multi-actor digital infrastructure in which the consumer is only one of the users, but not the only one and perhaps not even the most decisive from a regulatory perspective: for example, customs authorities may use product identifiers and data carriers to verify the correspondence between imported goods and the DPP registry; market surveillance authorities may access data and compliance documentation; public bodies may aggregate data to monitor imports, production, and market patterns; and end-of-life operators may retrieve information on composition and substances of concern.
The economic operator directly responsible for the DPP will be the one that places the finished product on the Union market. Fibres, yarns, and fabrics — that is, intermediate textile products — therefore do not, as such, fall within the mandatory scope of the passport. The document thus clarifies an important limitation: the textile DPP will not, at least at this stage, be a mandatory tool for tracing the entire upstream supply chain, nor will it automatically impose the legally binding transmission of data between intermediate textile products and the finished product. Any DPPs for intermediate textile products could be introduced by future separate acts or developed voluntarily by industry.
How does the Digital Product Passport work?
The DPP builds a regulatory taxonomy of the product, organizing information into four blocks:
- The first concerns the identification and classification of the garment;
- The second concerns the identification of the responsible operators, including the manufacturer, the importer when the manufacturer is outside the EU, and other actors identifiable through a Global Location Number (GLN);
- The third gathers the technical, material, mechanical, chemical, environmental, and performance characteristics: fibre composition, already required under the Textile Labelling Regulation; a mechanical robustness score based on ISO tests; a recyclability index; recycled content, specifying whether the waste origin is pre- or post-consumer; biobased content; carbon and environmental footprint expressed through performance classes according to the Product Environmental Footprint Category Rules (PEFCR); care and repair instructions; and information on substances of concern (SoC), in line with ESPR and REACH.
- The fourth block concerns documentation and compliance: the DPP will have to include declarations of conformity or third-party certifications for each of the parameters mentioned above, including raw mechanical test results in cases of self-declaration.
The most relevant issue for companies is granularity. The document moves beyond the idea of a uniform DPP for all types of content and proposes a multi-level structure, in which some information can be managed at model level, some at batch level, and some, prospectively, at item level, as identified by the Global Trade Item Number (GTIN). The minimum level proposed as mandatory is the batch, while the single item is initially suggested as voluntary, with a phased approach designed to reduce the burden on manufacturers: each item receives a unique identifier, but the associated data are inherited either from the batch (for example, substances of concern, actual recycled content, certifications, quality test results, or process data) or from the model (for example, product name, category, fibre composition, or care instructions), with the possibility of adding item-specific information at later stages of the life cycle, such as after a repair.
Who is the Digital Product Passport for?
Consumers, market surveillance authorities, customs authorities, repairers, recyclers, economic operators, and other actors will be able to see different data depending on their role and legitimate interest. The document therefore introduces a role-based access model, distinguishing three levels:
- Public information – accessible to anyone without authentication – includes fibre composition, identifiers, robustness and recyclability scores, care instructions, and recycled content expressed as a percentage.
- Information reserved for authorities (MSAs, customs, the Commission) includes conformity documentation, third-party certifications, and the calculation parameters for environmental footprint assessments.
- Finally, information accessible only to actors with a legitimate interest – such as recyclers – includes the location of substances of concern within the product and the absolute values of the environmental footprint.
This architecture works only if the data speak the same language. The document therefore insists on common vocabularies, public dictionaries, ontologies, and open standards, referring to tools such as CEON, UNECE, circularity.ID, TRICK/eBIZ, GS1, and CPDP in order to assess to what extent the DPP information elements can already be represented through existing semantic languages and models. Without shared semantics, two companies may declare the same data using different meanings, different units, different methodologies, or incompatible levels of aggregation. In that case, the DPP would lose its comparability function and become merely a constellation of non-interoperable digital pages. Supply chain preparedness must therefore include not only digitalization, but also data standardization.
How is the Digital Product Passport verified?
The document states that the reliability of the DPP will depend on the truthfulness of the information coming from long and opaque global supply chains, and it highlights the need for robust Chain of Custody models and verifiable links between the physical product and the digital data. This approach is crucial because it distinguishes formal completeness from substantive truthfulness: a DPP could contain all the mandatory fields, be correctly formatted, and pass automatic validation, yet still contain inaccurate, outdated, or non-verifiable data.
What remains outside the scope of the JRC document?
The document is ambitious in envisioning the DPP as a tool for the market, surveillance, and circularity, but it remains cautious on some enabling elements. It declares key aspects to be out of scope, such as technical architecture, data carriers, access protocols, cybersecurity, hosting models, integration with company systems, and implementation costs. This choice is understandable, since the report concerns the content of the DPP rather than the entire technical system. However, for companies, these very aspects will determine the difference between a manageable compliance effort and a costly infrastructural leap. The ambition of the document will therefore need to be complemented by clear technical standards, tools for SMEs, public dictionaries, proportionate verification models, and procedures capable of preventing the burden from falling primarily on upstream actors, who are often less digitalized but closer to the generation of the data.
Substances of concern in the Digital Product Passport
The ESPR provides that information on the identification, presence, location, and management of substances of concern may be required in the DPP when proportionate and relevant, especially where needed for safe use, repair, refurbishment, or end-of-life treatment. The 3rd Milestone had already shown how difficult this issue is: the textile supply chain uses many chemical substances, often across long, global, and opaque chains, and the study itself acknowledged that it had not been possible to produce a detailed inventory for a representative product, leaving it to operators – and ultimately to those placing the garment on the EU market – to make reasonable efforts to identify and communicate the relevant substances through the DPP.
The novelty, therefore, does not lie in the existence of chemical obligations, which are already present under several regulatory regimes, but in their integration into an information system oriented around the product life cycle. For the textile supply chain, this implies costly steps and a revision of information flows between chemicals, materials, production, and compliance. Substance-related data will no longer be able to remain confined to Restricted Substances List (RSL) specifications or to certificates exchanged between supplier and brand. They will need to be linkable to the product, updatable, protected when they contain commercially sensitive information, and accessible when needed by recyclers or authorities. The document in fact proposes a differentiated access model, under which fibre composition and other data directly connected to ESPR requirements should be publicly accessible, while sensitive data such as detailed chemical concentrations or verification documentation should be reserved for market surveillance authorities or actors with a legitimate interest, such as recyclers.
Does the Digital Product Passport risk enabling greenwashing?
A final new element concerns anti-greenwashing. The document explicitly restricts voluntary sustainability or environmental information not defined in the preparatory study. The aim is to prevent the DPP from becoming a container for claims, storytelling, private labels, and non-comparable declarations. The strict exclusion of non-harmonized voluntary environmental indicators is intended to prevent greenwashing and to ensure that only methodologically sound and harmonized indicators are displayed; voluntary information should therefore remain limited to non-environmental data, for example data useful for commercial or logistical transactions.
For a sector accustomed to the proliferation of certifications, sustainability claims, “responsible” capsule collections, private labels, and imaginative brand narratives, this is a cultural shift. Clear criteria will be needed to distinguish a voluntary technical datum from an implicit environmental claim, along with surveillance rules, controls over DPP platforms, and consistency with the European framework on green claims. Otherwise, the risk is that promotional communication will simply move outside the DPP while continuing to use the DPP as indirect proof of sustainability, perhaps through selective summaries or consumer-facing interfaces designed by brands. The ambition of the document will therefore need to be defended not only in the data structure itself, but also in the communication ecosystem that will form around the passport.
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