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      The Digital Product Passport (DPP) regulation is approaching. More than a compliance task for textile companies, the DPP can boost brand trust, enhance supply chain transparency, and support resilience in a market where traceability is key. Early insights from our European survey will show how first-movers are preparing.

      Globally, many companies have already begun implementation, recognizing both the risk of noncompliance and potential supply chain disruptions. Acting now is about more than readiness - noncompliance can damage business reputation and reliability in the eyes of partners and stakeholders.

      DPP requirements are being finalized, and implementation is near. Textile products will need a DPP: a digital record accessed via QR code on the label, detailing materials, origin, performance, repair history, recyclability, and environmental impact. Companies should start preparing now to shape implementation, avoid last-minute issues, and build trust. Early adopters will be better positioned for future models focused on circularity and traceability.

      Riikka Leppanen
      Riikka Leppanen

      Senior Manager, Audit

      KPMG in Denmark

      Nicolai Hoffmann
      Nicolai Hoffmann

      Manager, Audit

      KPMG in Denmark

      Key takeaways

      • Early action is a competitive advantage

        Textile companies that begin implementing the Digital Product Passport (DPP) now will gain an advantage in compliance readiness, market differentiation, and customer trust while avoiding last-minute operational disruptions.

      • The DPP goes beyond compliance

        More than a regulatory requirement, the DPP supports strategic goals such as supply chain resilience, circular economy acceleration, and improved transparency for consumers and stakeholders.

      • Implementation requires cross-company preparation

        Successful DPP integration involves readiness assessments, staff training, system and software upgrades, supplier onboarding, and strong data governance to ensure reliable and high-quality information.

      • Product level scope makes it universal

        Unlike some regulations, DPP obligations apply at the product level, regardless of company size or revenue making preparation relevant for all textile brands.

      • Future proofing through transparency and traceability

        By embedding the DPP into product design and operations, companies not only meet upcoming EU requirements but also strengthen their ability to track, communicate, and improve sustainability performance across the value chain.

      Starting early with the DPP gives your company the time to build internal capabilities, benefit from learning curves, and ensure compliance in a market where sustainability is already a business driver.

      A value-creating implementation that supports key strategic and operational objectives requires several steps. These include training and readiness assessments to equip key personnel with the necessary knowledge and skills, and system and software integration to ensure that digital infrastructure can support DPP data flows and storage. It also involves supplier onboarding, which is critical for consistent data exchange across the value chain, and data collection and governance to ensure reliable, high-quality information that meets regulatory and business needs. Finally, alignment between performance metrics, policies and strategy is crucial to ensure that DPP efforts are embedded into broader sustainability and operational goals.

      Some of the operational and strategic benefits beyond compliance include:
      • Resilient supply chains
      • Acceleration of the circular economy through product lifecycle data, reuse, and recycling
      •  Competitive differentiation through an early-mover advantage
      • Greater transparency for consumers
      • Reduced environmental impact

      Introduced through the Ecodesign for Sustainable Products Regulation (ESPR) - in force since 18 July 2024 - the DPP will be required for several product categories, including textiles. Unlike other legislation that applies only to large companies, the DPP requirements are product-based, meaning they apply regardless of company size or revenue.

      The DPP will serve as a digital record that provides standardized, accessible information about a product’s sustainability profile. While the exact criteria and requirements remain unknown until the adoption of delegated acts (expectedly in 2027 with 18 months until application), we already have qualified assumptions of potential demands. Data will be required from different stages of the product’s lifecycle, and the following provides examples of possible criteria and requirements¹:

      • Inflow and Production Data
        Examples of relevant data at this stage include the environmental footprint as well as water use and efficiency.

      • Lifetime Performance Information Data
        For the use phase, possible examples include disclosure of data on reusability and durability.

      • End of Life Data
        At the end of the product’s lifecycle, examples may include data on the possibility of recycling, recovery, and remanufacturing, as well as the potential for material recovery.

      1) Regulation (EU) 2024/1781 article 5.

      By making this data available on EU’s digital registry - likely accessible via a QR code on the product label - the DPP empowers consumers, investors, and other stakeholders to benchmark and make informed, responsible choices. It also supports due diligence by improving traceability of raw materials and production processes, helping companies align with both regulatory and market expectations.

      In addition to product-specific requirements, companies will also needto disclose horizontal requirements - rules that apply across all product categories within scope. These include aspects such as the repairability of their products and the share of recycled content². These obligations are expected to be issued in 2027 and 2029 andto apply approximately 18 months thereafter. The horizontal requirements will cover not only the textile and apparel sector, but also industries in scope of the DPP, such as furniture, chemicals, tires, aluminum, iron, and steel.

      2) Ecodesign for Sustainable Products and Energy Labelling Working Plan 2025-2030 page 6.

      Given that textile product design cycles often span 12 to 24 months, starting now is essential to ensure a smooth process that allows you to leverage learning curves and improve sustainability metrics before products reach consumers, investors, and other stakeholders.

      Our suggested approach outlines best-practice phases thatcan be tailored to fit each company’s specific processes and product development pace: (1) beginning with a readiness assessment to prepare a roadmap, and (2) followed by software and supplier onboarding to ensure technical integration.

      Acting early not only creates timely compliance but also provides a competitive advantage by enabling companies to build traceability into product development, strengthen supplier collaboration, and enhance transparency and resilience across the value chain. 

      While the Environmental Product Declaration (EPD) quantifies a product’s environmental impact based on a life cycle assessment, the Digital Product Passport (DPP) provides broader digital information to support circularity, resilience, and traceability in product designs.

      Primary focus
      Scope of use
      Environmental Product Declaration (EPD)

      Enviromental performance and impact data (LCA-based)

      Mainly used for external communication of enviromental footprint

      Digital Product Passport (DPP)

      Comprenhensive product lifecycle data (materials, repairability, enviromental footprint etc.)

      External communication of broader circular economy performance

      Starting early with DPP implementation is crucial, especially in Denmark, where sustainability can be a key competitive factor for textile companies. DPP’s scope applies at a product level - regardless of company size - and early movers will expectedly be better positioned to meet expectations and lead the market.

      Nicolai Hoffmann, Manager, ESG Advisory Services

      Need support building on ESG work and navigating DPP?

      By acting early, companies can gain a competitive edge by turning regulatory requirements into opportunities for transparency, efficiency, and differentiation.

      We help companies unlock business value by enabling better product data management and traceability, supporting more circular business models, strengthening customer trust, and enhancing brand positioning. 

      If you would like to learn more or have questions about our upcoming Nordic Survey, feel free to reach out to our ESG team.

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