Preparing for Digital Product Passports: Where Fashion Companies Should Actually Start

A version of this article was first published in Fashion Business Journal, pages 55–56. This is an expanded edition.

Ask a room of fashion professionals about the Digital Product Passport and the conversation jumps, almost immediately, to technology. Which platform? Which QR provider? Blockchain or not? It is an understandable reflex: the technology is the visible part, and the vendors selling it are persuasive.

But in our work with brands preparing for the DPP, the projects that succeed are rarely the ones that chose the cleverest platform. They are the ones that did three less visible things first: mapped the data they already held, decided who inside the company actually owns the subject, and tested their assumptions on a small, real slice of their range before signing anything. This article is about that groundwork.

Start with the data you already have

Every fashion company already holds a surprising amount of what a DPP is expected to require. Fibre compositions sit in tech packs and PLM systems. Supplier names and addresses sit in purchasing records. Certificates — OEKO-TEX, GOTS, recycled-content claims — sit in inboxes, shared drives, and audit folders. Care instructions, countries of origin, customs codes: most of it exists somewhere.

The problem is the word somewhere. The data is scattered across systems that were never designed to talk to each other, held in formats that range from structured database fields to a PDF someone scanned in 2022. And crucially, much of it is asserted rather than verified: the composition on the label is what the supplier declared, not necessarily what was tested.

So the first piece of groundwork is an honest inventory. For each category of information the DPP is expected to cover — identification, composition, origin, durability and circularity data, compliance documentation — ask three questions: do we hold this at all, where does it live, and is it verified or merely declared? The output is not a report for the shelf; it is a gap map. It tells you which data you can already stand behind, which exists but needs consolidating, and which you will have to start collecting from suppliers — the slowest part of any DPP project, and the reason to start early.

Decide who owns it — before the meetings multiply

The DPP has an organisational peculiarity: it belongs to everyone and therefore to no one. Sustainability teams feel responsible for the content. IT feels responsible for the systems. Product development holds the data. Sourcing holds the supplier relationships. Legal worries about what gets published. Marketing wants a say in what the consumer sees.

In practice, this is where DPP projects stall — not on technology, but on governance. Six functions each own a piece, meetings multiply, and a year later the company has opinions instead of decisions.

The fix does not require a reorganisation. It requires three explicit decisions, made once and written down. Who is accountable for DPP readiness as a whole — one name, with a mandate that crosses functions. Who decides on data: when the declared composition and the test result disagree, whose call is it? Who engages suppliers: data requests landing on suppliers from three different departments, in three different formats, is how goodwill gets burned before the real work starts.

Companies that settle ownership early move faster on everything that follows, because every later question — which data to prioritise, which systems to connect, which vendor to pilot — has somewhere to land.

Pilot on one product line, not on a slide deck

The third piece of groundwork is the one most often skipped: test your assumptions on something real before committing to tools.

Choose one product line — not your simplest, ideally one that is representative of how you actually source — and attempt to assemble, end to end, the information a DPP for it would plausibly carry. Real fibre data, real supplier confirmations, real certificates, real photos of the physical labels. Not in a vendor’s sandbox: in a spreadsheet if necessary.

A focused pilot like this does three things no demo can. It reveals where your data actually breaks down — typically at the second and third supply-chain tier, where your direct relationships end. It produces a realistic estimate of effort: collecting verified data for thirty styles teaches you what three thousand will cost. And it converts your tool requirements from generic (“we need a DPP platform”) to specific (“we need supplier onboarding in three languages, component-level composition, and an export path if we ever switch”). That specificity is what makes vendor conversations short and useful instead of long and theatrical.

Only then does the technology question become answerable — because by that point you know what you need the technology to do.

Less visible, but decisive

None of this groundwork shows up in a press release. There is no launch moment for “we clarified internal ownership”. But the brands that will publish credible passports on the regulatory timeline are doing exactly this now, while the delegated acts are still being finalised — so that when the requirements land, what remains is execution, not archaeology.

For the official EU sources on what data the textile DPP is expected to require — three certainty layers across the ESPR Regulation, the JRC Preparatory Study and the JRC Methodology — see our free editorial The DPP Data Map for Textiles. And when you want a structured, external view of where you stand across all of this — data, suppliers, systems, governance — the DPP Readiness Assessment turns the gap map into a personalised ~20-page report with a prioritised 90-day action plan.