What is the Digital Product Passport (DPP)?

What does a DPP for a fashion product contain?

The exact data set for textile DPPs will be fixed only when the textile delegated act is adopted, but ESPR Article 9 already lists the master categories from which any product DPP must draw. For textiles, apparel, and footwear, the working consensus from the JRC's Preparatory Study and the Commission's published methodology points to the following.

Identification

Unique product identifier, unique operator identifier, unique facility identifier where relevant — all in machine-readable form (UPI, UOI, UFI standards).

Composition

Fibre content by mass; presence of substances of concern above declaration thresholds; recycled content percentage, split between pre-consumer and post-consumer, with chain-of-custody verification.

Origin

Country and facility for the key supply-chain stages: spinning, weaving or knitting, dyeing and finishing, cut-make-trim. The French AGEC Law has required a subset of this since 2023.

Environmental footprint

PEF-based indicators per the Apparel and Footwear category rules — likely climate change, water scarcity, and a microfibre release indicator.

Durability and repairability

A durability score under the JRC Preparatory Study's DO1 framework (ISO test-based) and information enabling repair or component replacement.

Recyclability

A recyclability score under the JRC's DO2 framework, with particular attention to elastane content (15% or more elastane currently scores 0 for recyclability).

End-of-life instructions

Sorting and recycling guidance for waste operators downstream.

Compliance documents

References to the EU Declaration of Conformity and applicable test reports.

The DPP must also support tiered access: a consumer scanning a QR sees one view; an authority sees more; a recycler sees only what they need to know to dismantle the article. These categories are stable; the exact format and thresholds will be set by the delegated act.

For the source-by-source breakdown of where each data point comes from, see our editorial The DPP Data Map for Textiles.

Who is responsible for the DPP?

The Responsible Economic Operator (REO) is the entity that legally owns the DPP for a product placed on the EU market. Depending on the business model, the REO may be the manufacturer, the importer, the brand owner, or a fulfilment service provider acting in that role. Where multiple operators are involved — for example, an EU brand sourcing from a non-EU manufacturer through a 3PL — the chain typically resolves to whichever operator places the product on the market under its own name.

A few practical consequences for fashion brands:

• Legal accountability does not transfer to vendors. Many DPP solution providers, data platforms, and traceability vendors will offer to "manage" a brand's DPP. Their software may be involved at every step, but the regulatory obligation — and the penalties for non-compliance — remain with the REO. A vendor SLA is not a substitute for legal responsibility.
• The REO is the one that signs the EU Declaration of Conformity. Whoever puts their name on that document is, by that act, the REO for the article.
• Outsourcing the work does not outsource the duty. Brands relying on a manufacturer or distributor to "handle compliance" need a clear written agreement on who is the declared REO, and what audit trail the REO holds.

For fashion brands selling under their own name in the EU, the REO is, in almost all cases, the brand itself. Working out who is responsible internally — sustainability, sourcing, product, legal, IT — is then a question of governance rather than of regulation.

How fashion brands should prepare today

You do not need to wait for the textile delegated act to begin. The data the DPP will require already exists, scattered across your suppliers; the task is to consolidate it.

1. Map your value chain to Tier 3. At minimum, identify your spinners, weavers or knitters, dyers, and cut-make-trim factories. If you cannot name the Tier 2 facility that dyed a given fabric, you cannot meet the origin attributes the DPP will likely require.
2. Get a clean Bill of Materials per SKU. Fibre composition by mass, components (zips, buttons, linings, prints, finishes), origin per component. The fibre composition on the care label is the starting point — but the DPP will demand verifiable evidence behind those percentages.
3. Audit your substances list against REACH Annex XVII and the SVHC list. Substances of concern above declaration thresholds must be flagged. Existing OEKO-TEX STANDARD 100 certifications are useful but do not, by themselves, satisfy the DPP requirement.
4. Pick a data infrastructure intentionally. A DPP is, in technical terms, a set of accessible records linked to a data carrier. You can build this on a database you already have (PLM, PIM, ERP), on a dedicated DPP platform, on a traceability platform that adds DPP features, or on a combination. There is no single right answer — the question is which fits your team, suppliers, and budget. The free Provider Map is built exactly to help you see who does what across that landscape without any vendor pitching at you.
5. Train the team that will own it. DPP-readiness is multi-function: product, sourcing, sustainability, legal, IT. Whoever ends up owning it needs to speak the regulatory language fluently. The DPP Masterclass covers the full ground — legal foundations, data architecture, supplier engagement, technology selection — in a vendor-neutral format.