The first step to DPP compliance isn’t actually the passport

The EU’s regulations targeting fashion and textiles have moved beyond strategy decks and firmly into many businesses’ operating models, though the step change is not without its challenges.

The Ecodesign for Sustainable Products Regulation is already in force, while the ban on destroying unsold apparel, accessories, and footwear now applies to large companies, with textile-specific DPP requirements expected through ESPR, and textile EPR schemes due to become operational across EU member states from 2028 onward.

Together, these regulations demand that product information is more accurate, accessible, and defensible than it has ever been before. While DPPs will be fundamental to meeting those requirements, creating the passport itself is only one half of the challenge.

Why Digital Product Passports are more complicated than they seem

A DPP’s primary purpose is to record material composition, origin, lifecycle data, repairability, recyclability, substances of concern, and end-of-life information. The data is made available to consumers, regulators, recyclers, and other actors depending on specific access rights.

It is one thing to mandate that companies must comply and provide DPPs, yet it is another thing entirely to figure out exactly how to source that data – particularly upstream in the supply chain.

As noted in Vogue Business, many of the systems that will be required to support DPP and EPR are far from where they need to be. All things considered, attaching QR codes to products and publishing compliant data records are the ‘easy’ parts. Securing buy in from suppliers in less developed regions is significantly more difficult. So too is consolidating data across a business.

These issues will be challenging for larger organisations, though there are admittedly more straightforward, albeit expensive, options to them. Smaller suppliers – like mills and upstream manufacturing partners – will face the brunt of the burden. Many of these businesses still rely heavily on spreadsheets, PDFs, emails, certificates, and manual record-keeping processes.

They very well may have the information on fibre composition, dyeing, finishing, production sites, chemical inputs, recycled content or chain of custody, but that does not mean they have the digital infrastructure necessary to provide it in a structured and auditable way.

For the smaller suppliers, the investment case for new systems, staff training, and data governance might not be fiscally worthwhile. Each requires considerable investment for limited return. The biggest ROI undoubtedly sits with the larger organisations selling into the EU because they will otherwise lose access to one of the biggest markets for apparel and footwear.

This is why the discourse around DPP readiness remains anything but positive. On the surface, it may seem like a ‘simple’ IT project and yet the reality is far from that. The regulations (necessary as they may be for the environment) impact buying relationships, supplier selection, onboarding, training, commercial terms, and crucially, long-term sourcing strategy.

One suggestion posited by Vogue is the option to work with fewer but ultimately compliant suppliers. Again, this is easier for larger organisations to achieve than SMBs. Another path is to invest in upskilling supplier workforces and digital infrastructures. Whether businesses choose to do either depends on the cost involved and what happens commercially if they don’t.

In truth, no one DPP provider can solve this. It depends on the brands and suppliers in question, as well as their willingness to engage in the mandates. To complicate matters more, supplier engagement is just one half of the DPP puzzle. The other is rooted in data collation.

Most data is spread across ERP, PLM, and other systems

In most cases, and especially so at enterprise level, production information does not typically live cleanly inside one system. It moves through PLM, ERP, POS, traceability tools, sustainability platforms, lab reports, supplier documents, spreadsheets, and third-party portals.

Bringing information from across all these disparate tools is no easy feat, and yet it is essential to creating accurate and auditable passports that comply with the EU’s legislation.

ERP systems have long been heralded as the “single source of truth”, but you only need to speak to a handful of enterprise fashion businesses to know that a large majority rely on additional systems beyond their core ERP. A PLM point solution may hold their product specs, while the ERP handles purchasing and inventory, and a separate commerce system stores their transactional and customer-facing data.

To muddy the waters further, many brands also create their data before a product physically exists. Materials are specified, suppliers are nominated, origins are pencilled in, transport is planned, and sustainability attributes are calculated against expected conditions.

The problem is that plans do not always follow through. It’s not uncommon for substitutes to happen, factories to change, production runs to be split, transport choices to shift, and batches to arrive under different conditions (e.g., air versus sea).

By the time goods are physically received, the product in question may no longer be the same as the one that was planned. This is something understood by most people but not by all DPPs. There are plenty of DPPs on the market that capture and record what a product was planned to be, as opposed to what is actually delivered at goods receipt.

Creating passports at goods receipt is more reliable because many of the variables brands can control (e.g., split deliveries) can be recorded as fact since the DPP is created after delivery has taken place.

Of course, this does not remove the upstream challenge. Supplier data still needs to be collected, evidence still needs to be validated, and brands still need to decide how they will support, select, and manage them as compliance expectations increase.

Nevertheless, DPPs created at receipt do still give brands a more logical foundation to begin their compliance work while solving one of the common challenges surrounding the legislation.

K3 Fashion is built to connect data for DPPs

While no technology platform can make every supplier compliant overnight, brands can take control of the product data that already exists inside their own organisation.

Our Digital Product Passport is available directly within K3 Fashion and Dynamics 365 Finance, Supply Chain Management, and Commerce. This means that not only is the DPP grounded in the data that already runs your business, but that it is also connected to Microsoft’s ERP, our fashion intelligence layer, as well as our PLM capabilities.

In other words: every bit of data used to run your business is in one place ready for the DPP. Each passport is created at goods receipt, scoped by product, variant, batch, or serial number, so that the record reflects what was received rather than what was originally planned.

Both of these points ensure that your records can be trusted, updated, audited, and connected to the commercial decisions that take place across your business.

While the wider supplier challenge will persist, the truth of the matter is that no platform can make every upstream partner compliant by default. What it can do is give enterprise brands control over the data foundation they are responsible for, reduce fragmentation inside their own organisation, and create product records that are both faithful and auditable.

To find out more about the K3 Digital Product Passport and how it can support your compliance efforts, get in touch with us today.