With digital product passports (DPPs) and extended producer responsibility (EPR) moving toward enforcement, compliance is shifting from a strategic consideration to an operational one for fashion.
Both EPR and DPP requirements will apply to any brand — regardless of where it is headquartered — that sells products within the European Union market, requiring companies to finance end-of-life waste management systems while collecting and disclosing granular data on product composition, supply chain, and environmental impact.
A simplified DPP covering mandatory product information and basic lifecycle data is targeted for late 2027. EPR becomes mandatory at scale across the EU by April 2028. The two deadlines arrive in close succession — and as brands move from planning to execution, a more difficult reality is coming into focus: the infrastructure required to meet them, from machine-readable supplier data to domestic sorting and recycling facilities, does not yet exist at the scale being demanded.
“DPPs are being developed as a data layer,” says Liz Alessi, founder of the Crisis of Stuff and a sustainability consultant with Bank & Vogue, which works across the resale and end-of-life side of the fashion value chain. “But the systems they’re meant to support — sorting, resale, recycling — are not yet equipped to fully use that data. Without investment in physical infrastructure, the impact of DPPs remains limited.”
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But the compliance framing may itself be the problem. DPP is better understood as a forcing function for a broader transformation already underway, says Natasha Franck, founder and CEO of Eon, which builds digital product identity infrastructure for brands including PVH and Mulberry. “Digital product passports may be the ‘why now’, but in AI-driven commerce, structured product data is the price of entry — and digital product identities will become the primary interface through which products are discovered, recommended, transacted, and sold. Without them, brands risk becoming invisible.” Treating DPP as a narrow compliance or labeling exercise carries real long-term risk of limited visibility and irrelevance in systems where catching up becomes extraordinarily difficult.
EPR, meanwhile, shifts financial and operational responsibility for a product’s end of life back onto the brand. In theory, that creates an incentive for brands to design for recyclability and invest in the systems that handle returns, sorting, and processing. In practice, those systems are not ready for the volumes EPR will generate.
“EPR is forcing the industry to confront end-of-life capabilities that have historically been overlooked,” Alessi says. Domestic infrastructure for large-scale sorting, assessment, and processing remains underdeveloped. Existing systems depend heavily on export markets and resale channels to remain financially viable — a dependency that will not scale.
That gap — between the data ambition of DPP and EPR, and the physical reality of what happens to a garment at the end-of-life stage — is a glaring tension in fashion’s compliance conversation. And it is far from the only one.
The data problem starts at the supplier
The first phase of DPP — described in EU guidance as a minimal and simplified passport focused on mandatory product information and lifecycle data — is targeted for late 2027, with the delegated acts defining precise requirements still being written. Full circular passport requirements, encompassing complete lifecycle data, follow on a longer horizon. Even that first, simplified phase requires brands to track and disclose granular product-level information: material composition, recycled content, chemical substances, chain of custody, supply chain mapping, or lifecycle assessment data. In principle, much of this already exists somewhere in the value chain. In practice, it is scattered, inconsistently formatted, and largely inaccessible.
“Not all of this data exists today,” says Philipp Mayer, co-founder of Retraced, a supply chain transparency platform. “Even basic data points like product weight are often not systematically available and need to be collected from suppliers.” Where data does exist, he adds, it is spread across product lifecycle management (PLM) and ERP systems, traceability platforms, lifecycle assessment tools, and laboratory reports — rarely digitized, standardized, or consolidated.
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