EU Regulation 2025

Digital Product Passport: Your Complete Guide

How PLM systems help fashion brands organize and structure the data required for EU compliance. Everything you need to know about the DPP and how to prepare.

What is the Digital Product Passport?

The Digital Product Passport (DPP) is a digital record accessible via QR codes on product labels that provides comprehensive information about a product's lifecycle. It's part of the EU's Ecodesign for Sustainable Products Regulation (ESPR), which became law in June 2024.

For fashion and textile brands selling in the EU, the DPP will be mandatory starting in 2027. It requires brands to collect, structure, and share detailed information about materials, environmental impact, supply chain, and more.

The goal: enable consumers, recyclers, and regulators to make informed decisions and support the circular economy. The challenge: collecting and organizing 16+ categories of product data across your entire supply chain.

2027
Textiles deadline
for basic DPP
16+
Data categories
required per product
18 months
Implementation time
after delegated act
QR Code
Required on every
product label

Why start now? The data you collect from the start of 2025 is the data you'll report on in 2027. Waiting until late 2025 leaves limited time to gather and clean upstream data—a process that typically takes at least 12 months.

Key Dates & Timeline

The ESPR Working Plan prioritizes textiles and apparel for early implementation. Here's what brands need to know:

DateMilestoneWhat It Means
June 2024ESPR Framework ApprovedEcodesign for Sustainable Products Regulation becomes EU law
Late 2025DPP Registry RegulationsRules for service providers, product identifiers, and data carriers finalized
2026Textiles Delegated ActIndustry-specific requirements for fashion and apparel published
2027Textiles DPP RequiredMinimal DPP with mandatory product info and environmental impact
2030Advanced DPP RequiredComprehensive lifecycle information across all stakeholders

Note: After the delegated act for textiles is published (expected 2026), fashion brands have at least 18 months to implement. However, this is not the time to start—it's the deadline to finish.

Required Data Categories

The DPP requires comprehensive information across 16+ categories. This data must be transparent for regulators and accessible to consumers via scannable QR codes.

CategoryWhat's RequiredStatus
Product IdentificationName, model, batch number, manufacturing date, warranty detailsRequired
Material CompositionRaw material origins, percentages, treatment detailsRequired
Carbon FootprintEmissions across production and use phases (Scope 1, 2, 3)Required
Supply Chain TraceabilitySupplier information through all production stagesRequired
Durability InformationExpected lifespan, care instructions, quality gradesRequired
Repairability DataRepair events, replacement components, service availabilityRequired
Recycled ContentPercentage of recycled materials used in productionRequired
RecyclabilityEnd-of-life recycling instructions and material separationRequired
Chemical ComplianceREACH compliance, hazardous substance declarationsRequired
Water ConsumptionWater usage across manufacturing processesRequired
Social & Labor ConditionsWorking conditions, certifications, audit resultsRequired
Animal WelfareCertifications for leather, wool, down (where applicable)Conditional
CertificationsOEKO-TEX, GOTS, GRS, and other relevant certificationsRequired
Life Cycle AssessmentFull environmental impact assessment resultsRequired
Transportation DataShipping methods, distances, and related emissionsRequired
Ownership RecordsTransfer history for resale and second-hand marketsRequired

The challenge: Most of this data lives in spreadsheets, emails, and supplier folders—not in a structured format that can be shared digitally. This is where PLM becomes essential.

How PLM Systems Enable DPP Compliance

Product Lifecycle Management (PLM) software is the operational foundation for DPP compliance. It centralizes the engineering, materials, and supply chain information needed to create verified, shareable product records.

Without a PLM system, brands face manual data collection across dozens of spreadsheets, inconsistent supplier information, and no clear audit trail. With PLM, you have a single source of truth that maps directly to DPP requirements.

Key PLM Capabilities for DPP

Centralized Data Repository

Single source of truth for all product information, eliminating scattered spreadsheets and siloed data.

Material & Supplier Traceability

Track every component from raw material to finished product with full supplier visibility.

BOM Management

Detailed Bills of Materials with composition percentages, origins, and certifications.

Sustainability Integration

Connect to carbon calculators, LCA tools, and ESG reporting platforms.

Automated Data Collection

Workflows that gather required information from suppliers without manual chasing.

Data Carrier Generation

Create QR codes and NFC tags linked to your digital product records.

Supplier Portal

Give suppliers access to submit certifications, test results, and compliance data.

Audit Trail

Complete history of changes for regulatory verification and transparency.

Integration is key: Your PLM should connect to ERP systems for production data, sustainability platforms for carbon calculations, and PIM systems for consumer-facing information. The DPP requires data from across your business—not just product development.

8-Step Preparation Checklist

Use 2025 to build your data infrastructure. Here's how to prepare:

  • Step 1: Centralize all product information in your PLM system
  • Step 2: Align suppliers on data requirements and collection processes
  • Step 3: Run structured data audits to identify information gaps
  • Step 4: Upgrade data carriers (QR codes, NFC chips, RFID tags)
  • Step 5: Define repair and ownership record processes
  • Step 6: Prepare sustainability datasets for carbon and emissions
  • Step 7: Pilot the workflow with one product line before scaling
  • Step 8: Monitor delegated acts for sector-specific requirement updates

Pro tip: Start with your most complex product category. If you can collect complete data for that line, simpler products will follow the same process.

Common Challenges & Solutions

Preparing for DPP compliance isn't without obstacles. Here's how to address the most common challenges:

Incomplete Supplier Data

Start supplier onboarding now. Use your PLM's supplier portal to standardize data collection with clear templates and deadlines.

System Integration

Choose a PLM that integrates with your existing ERP, sustainability tools, and e-commerce platforms via APIs.

Implementation Cost

Modern cloud PLM solutions start at affordable monthly rates. The cost of non-compliance (fines, market exclusion) far exceeds investment.

Timeline Pressure

Begin data collection in 2025. The data you gather now is what you'll report on in 2027. Don't wait for the delegated act.

The Bottom Line

Start Preparing Now If:

  • You sell textiles or apparel in the EU market
  • Your supplier data is scattered across spreadsheets
  • You don't have a centralized product data system
  • You want to avoid rushing implementation in 2026
  • You see sustainability as a competitive advantage

Key Takeaways

  • 2027 deadline: Textiles DPP becomes mandatory
  • 16+ data categories: From materials to carbon to labor
  • PLM is essential: No way to comply with spreadsheets
  • Start now: Data collection takes 12+ months
  • Penalties for non-compliance: Fines and market exclusion

Prepare Your Brand for DPP Compliance

Kobo PLM helps fashion brands centralize product data, track materials and suppliers, and build the data infrastructure needed for Digital Product Passport compliance.

One workspace to
Design, Develop & Deliver

Design collections, coordinate sampling & production, manage suppliers, process sales, and fulfill orders in one connected platform.