Digital Product Passport: How new EU rules will affect fashion companies

Digital product passports will soon be a legal requirement for fashion brands in Europe. 

While they demand new systems, data, and investment, they also open the door to stronger consumer loyalty and a reputation for genuine sustainability. 53% of luxury consumers have already heard of Digital Product Passports, and 25% are familiar with some of its functions. This awareness will grow as the regulations come into force. With this in mind, early adopters could gain a premium edge, using eco-credentials in their brand positioning to outpace slower competitors

What is the Digital Product Passport (DPP)?

The DPP is a digital record that’s linked to each product. It’s designed to make the product more transparent in terms of:

• origin, 
• materials, 
• repair and recycle options, 
• and other environmental performance details. 

As a recent European Parliament study stated, “A European digital product passport (DPP) could enhance textile industry traceability, circularity, and transparency.” The concept of a DPP came about after the introduction of the Ecodesign for Sustainable Products Regulation (ESPR), which was enacted in 2024. The goal is that each product must carry a QR code or NFC tag that links to its digital product passport. People should be able to scan with a smartphone and see all the relevant product details. 

Overall, the DPP will help to show the environmental impact of every item, encouraging brands to make products more durable and reusable. This level of transparency should also help to build consumer trust and loyalty.

Why pay attention to DPP now?

The EU’s 2025–2030 plan prioritises textiles and apparel for early adoption of DPP. It’s believed that the guidelines will be published in late 2025, with the actual rules taking effect in 2027. After that, a compliance window of around 18 months is expected to kick in for apparel, with footwear following later. The introduction of DPP marks a sharper focus on supply chain documentation. This means brands should start improving data quality and traceability now in preparation.

What will be in the DPP?

Although the final delegated acts aren’t published yet, we already have a clear idea of what fashion passports will include. Each product will carry the following information.

• Core product data – origin, fibre content, sustainability credentials
• Unique identifier – usually a GS1-serialised code kept for the item’s lifecycle
• Data carrier – most likely a QR code linking to the passport
• Interoperable IT systems – to ensure data can be shared across the supply chain

The passport is expected to cover around 125 key data points. Over time, it will support circular models by allowing repairers, recyclers, and resale platforms to add updates on a product’s condition and history.

It’s best to think of the DPP as a “living record” that follows an item from factory to consumer, through resale, repair, and recycling. It’s a big step forward in product transparency and brands that prepare for this change early can turn compliance into a competitive advantage.

Digital product passport – What’s inside?

Impact on fashion companies

The consequences of non-compliance are expected to be severe. Without a compliant DPP, products may not be allowed on the EU market. The Commission is likely to monitor compliance through market checks, with warnings issued first and products blocked from sale if problems remain. Imported goods are also covered, as ESPR applies equally to EU and non-EU companies. The business placing the product on the market is responsible for creating and maintaining the DPP.

“Fashion brands should be prepared well in advance to avoid shipment delays or even sales bans. Having an EU entity is increasingly preferred to stay in control.”

Henri Smets
Manager customs, trade & compliance at Modexpress

Non-EU brands should appoint an EU-based operator, either an importer or authorised representative, to take responsibility for the DPP and technical file access. Preparation should start now, particularly for non-EU brands facing additional logistics hurdles. As an indicator of the importance of preparation, a recent Times report warned of the commercial risk of lost EU sales if UK companies delay readiness.

DPP timelines

It’s a good idea to start preparing for the introduction of DPP now, as it means you can hit the ground running when the rules eventually come in.

• 2025: ESPR is already law. Standardisation bodies CEN/CENELEC JTC 24 are developing the DPP system/standards to underpin implementation.
  
• Late 2025 to early 2026: The standards will be outlined and horizontal DPP rules will be developed. Industry pilots will continue apace.
  
• Indicative 2027: The textiles delegated act will become mandatory for adoption, with an 18-month transition period anticipated before full enforcement. (This compliance window is only indicative and not confirmed at the time of writing).

Digital product passport – Timeline

What “good” preparation looks like for fashion brands 

In order to prepare for digital product passports, brands must focus on data quality across the supply chain and product lifecycle.

Step one – map your data

Align your data with the likely DPP schema (materials, fibre content, chemicals, facility IDs, repairability/recyclability). Involve supply chain partners to ensure accuracy.

Step two – select your tech

Choose IDs & carriers early (serialised GTIN + QR) and ensure systems can carry the ID across the product lifecycle and channel handovers. Start testing systems and formats for product data as early as possible, so there are no glitches when it’s finally rolled out.

Step three – connect your systems

Make sure your IT and supply chain systems can “talk” to each other and share data smoothly. Keep an eye on the official EU standards being developed (CEN/CENELEC JTC 24), as these will define how systems should link up and exchange DPP information. Partnering with a third party can make this process easier, especially for non-EU brands.

How Modexpress supports clients during this transition

While Modexpress can’t take on full legal responsibility for your compliance, we do provide practical support to help fashion brands get ready for DPP and manage the change.

• Guidance from the start – advice and feedback during onboarding to flag risks early.
  
• Ongoing checks – regular sample reviews of documentation to keep everything on track.
  
• Tools & know-how – templates and best practices built from decades of fashion logistics experience.

What makes Modexpress different is our dedicated customs department. Beyond paperwork, the team acts as a sparring partner to navigate EU entry rules and DPP requirements.

“DPP brings new expectations for brands, and we want to make that transition as smooth as possible. Our customs experts guide clients through what’s needed and provide the tools to organise compliant documentation.”

Niek Fransen
CEO at Modexpress

With compliance expertise and logistics support combined, Modexpress makes the DPP journey far less daunting. To discuss how you can prepare for DPP in more detail, reach out to Henri or our customs department today.

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