The Tamesis
Compliance in the fashion industry is shifting from a strategic to an operational consideration as Digital Product Passport (DPP) and Extended Producer Responsibility (EPR) move towards enforcement.
The EPR and DPP requirements will apply to any brand selling products on the EU market (regardless of where they are headquartered), requiring companies to fund end-of-life waste management systems while collecting and disclosing detailed data on product ingredients, supply chains and environmental impacts.
A simplified DPP covering mandatory product information and basic lifecycle data is scheduled to be launched by the end of 2027. By April 2028, EPR will be fully enforced across the EU. The two deadlines came in quick succession, and as brands moved from planning to execution, a more difficult reality came into focus: the infrastructure required to meet these requirements, from machine-readable supplier data to domestic sorting and recycling facilities, was not yet at the scale required.
“DPP is being developed as a data layer,” said Liz Alessi, founder of Crisis of Stuff and sustainability advisor to Bank & Vogue, which works on the resale and end-of-life aspects of the fashion value chain. “But the systems they are supposed to support – sorting, resale, recycling – are not yet equipped to fully exploit this data. Without investment in physical infrastructure, the impact of DPPs will remain limited.”
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But the compliance framework itself may be the problem. DPP is better understood as a mandatory function of the wider transformation already underway, said Natasha Franck, founder and CEO of Eon, which builds digital product identity infrastructure for brands such as PVH and Mulberry. “Digital Product Passports may be the ‘why now’, but in AI-driven commerce, structured product data is the price of entry – digital product identities will become the primary interface for discovering, recommending, transacting and selling products. Without them, brands risk becoming invisible.” Treating DPP as a narrow compliance or labeling exercise carries a real long-term risk of limited and irrelevant visibility in a system where catching up becomes incredibly difficult.
At the same time, EPR shifts financial and operational responsibility at the end of a product’s lifecycle back to the brand. In theory, this would incentivize brands to design for recyclability and invest in systems to handle returns, sorting and disposal. In reality, these systems are not ready to handle the volumes that EPR will generate.
“EPR is forcing the industry to confront historically neglected end-of-life capabilities,” Alessi said. Domestic infrastructure for large-scale sorting, evaluation and processing remains underdeveloped. The existing system relies heavily on export markets and resale channels to remain financially viable – a reliance that cannot be scaled.
This gap between the data ambitions of DPP and EPR and the physical reality of what happens to garments during their end-of-life phase is a clear tension in compliance conversations within the fashion industry. And it’s far from the only one.
Data problems start with suppliers
The first phase of the DPP – described in EU guidance as a minimized and simplified passport focusing on mandatory product information and lifecycle data – is scheduled to be implemented by the end of 2027, with an enabling act defining the precise requirements still being written. Full cycle passport requirements, containing full lifecycle data, will be followed in the longer term. Even the first simplification phase requires brands to track and disclose detailed product-level information: material composition, recycled content, chemicals, chain of custody, supply chain mapping or life cycle assessment data. In principle, much of this already exists somewhere along the value chain. In practice, it is fragmented, inconsistently formatted, and largely inaccessible.
“Not all of this data currently exists,” says Philipp Mayer, co-founder of supply chain transparency platform Retraced. “Even basic data points such as product weight are often not systematically available and need to be collected from suppliers.” The data does exist, he adds, but it is spread across product lifecycle management (PLM) and ERP systems, traceability platforms, lifecycle assessment tools and lab reports, and is rarely digitized, standardized or integrated.
