Digital Product Passports for Apparel

Ana Carneiro

Principal Consultant, Green Design Lead

UK

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Ana Carneiro

Ana specialises in sustainability strategies for consumer goods and circular economy. With experience in eco-conscious product development, Ana helps organisations embed regenerative design and climate resilience.

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Holly Browne

Associate Director

UK

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Holly Browne

Holly draws on over a decade in fashion and sustainability, guiding ethical compliance and strategy development for brands seeking responsible production and sourcing.

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Honor Cowen

Retail Sector Lead

North America

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Honor Cowen

Honor leads sustainability initiatives for North American retail and consumer brands, addressing challenges from plastic reduction to food waste and supply chain innovation.

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Table of contents

• What is a Digital Product Passport?
• Critical considerations for enabling circularity
• Making DPPs a reality
• How Anthesis can help

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The fashion industry is preparing for a data-driven transformation, one that rethinks how clothing and apparel are made, sold, valued, and recirculated. At the heart of this transformation is the introduction of Digital Product Passports (DPPs), a central feature of the EU’s Ecodesign for Sustainable Products Regulation (ESPR). While the regulation is still in development, the direction of travel suggests that transparency mechanisms, delivered through the Digital Product Passport, are solidifying as the primary instrument of change. DPPs are therefore poised to become a fundamental enabler of circularity, influencing everything from design processes to resale dynamics.

What is a Digital Product Passport and why does it matter?

At its simplest, a DPP is a digital record that travels with a product throughout its life – but that rather undersells its ambition! In fashion, a DPP could hold everything from fibre composition and sourcing data (such as where the cotton was grown, if it was organic or recycled etc.), to lifecycle impact metrics, repair history, and even ownership records.

This information will be scannable (likely through QR codes or RFID tags) and designed to outlive a single purchase. A DPP isn’t just a high-tech tag; it’s a live connection between a garment and the system it moves through, connecting brands, consumers, resellers, repairers, and recyclers.

If that sounds like a lot, it is. But it’s also what circularity demands: durable data to match durable design, right through the entire life of a product.

If implemented appropriately, DPPs can benefit the apparel industry by:

• Revealing new opportunities for brands to engage customer loyalty
• Unlocking circularity through more complete product data
• Strengthening the resale ecosystem by providing trust in products

Unlocking circularity through product data

Today, a lack of product-level data is one of the key blockers to scaling circular fashion; DPPs could finally bridge that gap. By embedding accurate, accessible information into each item, brands can begin to see value not just at the point of sale, but across a product’s entire journey. A product that is more durable and recyclable holds more long-term value, both environmentally and commercially.  Information can also support much needed emotional durability – a reason for customers to invest in and hold onto apparel items.

With this shift, new business models can thrive: resale, rental, leasing, product-as-a-service, and beyond. These once-fringe activities are fast becoming central to how fashion will operate in a regulated, resource-constrained world. 

However, if minimum performance thresholds remain limited (as the JRC’s latest study suggests), the effectiveness of the system will depend on how retailers, platforms, investors, and consumers respond to the disclosed data. In this sense, the ESPR could be shifting circularity from a baseline for market access to a matter of accountability, presumably through DPPs.

Strengthening the resale ecosystem

Resale platforms like Depop and Vinted have shown that second-hand fashion is here to stay, and the ThredUp annual reports have been raising expectations for the growth of the secondary apparel market. Still, trust remains a challenge; consumers need to know that an item is genuine and in good condition.

DPPs can offer the infrastructure to scale that trust. DPPs are expected to carry incorruptible data and could therefore be used to verify a product’s origin, composition, care history, and even previous ownership. This will help buyers make informed decisions, and could increase resale value while also reducing fraud and counterfeiting.

A new role for brands: ownership, loyalty, and lifetime value

DPPs also offer something quiet but powerful to brands: insight into what happens next. With data-linked garments, brands could launch their own in-house resale channels with embedded authentication, reward consumers for take-back and repair behaviour, monitor how long their clothes stay in use, and gather empirical data on the durability of their products.

In the future, we can imagine data grounded in the success of products in the secondary market feeding back into demand in the primary market. Brands that prioritise product quality will be supported in building a reputation around longevity and circular value, and in rewarding customers for purchasing ‘real’ products with that lifelong purchase.

Critical considerations for enabling circularity

While DPPs promise major benefits, realising their potential will require thoughtful implementation and a holistic view of the system.

Recent communications from the JRC’s 3rd milestone preparatory study for apparel suggest a subtle but important shift in regulatory architecture: rather than introducing strict minimum durability or recyclability thresholds, the emerging design options lean heavily on scoring systems and information requirements, including robustness scores, recyclability scores, and environmental footprint disclosures.

While this structured transparency may improve comparability across products, it does not itself create a clear barrier to low-performing products entering the market. In this context, the Digital Product Passport becomes not simply a compliance tool, but the primary instrument through which circularity is expected to operate – shifting the burden from prohibition to disclosure, and from design mandates to data visibility.

Key considerations for enabling circularity through DPPs include:

1. Data carriers: QR codes vs RFID tags

As we await the final Delegated Act for apparel, one major point of industry speculation is whether a particular data carrier will be mandated for DPPs?

• QR codes are low-cost and consumer friendly. They are familiar, scannable by smartphones, and visually understood.
• RFID tags are more expensive, but provide seamless industrial scanning without line-of-sight. This is especially useful in sorting and logistics environments. However, it remains unclear if consumers would be able to easily access this data, and whether all smartphones can support RFID reading.

Both options will also have their challenges for some product types (e.g., socks), though it’s possible different apparel categories will be treated distinctly in the legislation.

2. Avoiding information loss

For circular systems to function, product information must stay with the product. However, lots of tags are cut off by consumers or brands (especially in second-hand or outlet markets), which removes valuable composition and care data. Low-quality labels can also fade, tear, or lose legibility after repeated washing, especially affecting QR codes, as these require high contrast for readability.

To avoid this:

• QR codes may need to be printed directly onto garments, using high-contrast and durable printing, placed in accessible but hard-to-remove areas. This could also have a positive impact for those with sensory needs. 
• RFID chips could be embedded into garments, but placement must balance durability with wearer comfort

These changes would require new production steps and potentially significant cost uplifts for manufacturers.

3. Preparing waste handlers and PROs

For the DPP system to support recycling, waste sorters and recyclers must have the tools to read and access DPP data. If multiple data carrier technologies are used (QR, RFID, or other), it could lead to confusion or interoperability challenges.

There is already concern in the sector about:

• Whether scanning will require manual labour (which is unscalable)
• How technology investments will be funded in what is still a fragile textile recycling industry
• Whether regulation will create clarity early enough for infrastructure development to keep up (and funding initiatives for adaptation).

4. Implications for global markets

Despite the DPP and ESPR focusing on the European market, their impacts are likely to be felt globally. Any product destined for Europe will need to comply, causing the associated supply chain companies to adjust.

There is also potential for impact downstream:

• With the ban on destruction of unsold goods and new EPR obligations under ESPR, more textiles will likely remain within Europe for sorting and reuse. This could have positive consequences by boosting local secondary markets and incentivising investment in textile recycling infrastructure. However, alignment with other regulations such as the Waste Framework Directive (WFD) and the Waste Shipment Regulation (WSR) will be critical. If these aren’t harmonised effectively, we could see regulatory friction, such as restrictions on shipping used textiles out of Europe under WSR, which conflicts with the market reality that Europe currently lacks sufficient infrastructure to process all collected textiles domestically.
• If recycling infrastructure isn’t scaled quickly, and with a significant amount of low-quality apparel in circulation, more clothing could be exported to the Global South (potentially in an unregulated way), worsening existing issues related to waste dumping and informal resale economies.
• On the other hand, if brands take charge of the opportunity to mostly “own” the pre-loved goods they originally launched into the market, DPP-enabled circularity will lead to tighter control of second-hand goods by brands or retailers, leading charities and community organisations to potentially lose access to higher quality donations, undermining their social missions and the affordability of second-hand fashion.

Making Digital Product Passports a reality

If done correctly, Digital Product Passports could fundamentally disrupt how fashion currently functions. By embedding transparency and traceability into every product, DPPs promise to support new circular models, unlock secondary market value, and build long-term brand loyalty. 

Clothes sold will no longer be out of sight and out of mind. Instead, they will remain digitally traceable through structured product data systems, and brands will be consistently reminded of less sustainable design decisions and overconsumption. This will lead to more sensible and mindful decision-making from buying and merchandising teams. 

This digitisation of the apparel industry could also bring clarity to the consumer, helping them identify who made their clothes and how they perform. If this information is properly understood and valued, it could support the design of better-performing products. The carrot lies with both the consumer and the brand: increasing the value of clothing, and the capacity for repair and resale.  Without that, it risks becoming yet another stick with which to beat beleaguered supply chains, adding costs and additional requirements without the ability to increase prices to make better garments. 

Less established and more informal parts of the industry also worry that the final regulation may reflect the capabilities of large players more than the realities of SMEs and non-profits, potentially shifting some from leaders in circular practice to laggards in compliance and communications.

Luckily, nothing is yet set in stone. Now is the time for the industry to engage seriously with the decisions being shaped – decisions that will have far-reaching consequences across supply chains, business models, and markets, both within and beyond the European Economic Area.

Despite the challenges ahead, ESPR and DPPs represent a genuine opportunity to accelerate circularity. The question is whether this moment is leveraged to transform how clothing is designed, valued and kept in use – making throwaway fashion as culturally unacceptable as the plastic straw.

How Anthesis can help

Anthesis can support you and your business as you consider the implications of ESPR and the DPP regulation on your business.  We can help you unpack the regulation, perform a readiness assessment on your business, processes, and systems, and help you to understand the far-reaching consequences this could have on your operations and supply chain.  We can help answer questions around data collection and analysis, and can also help implement other elements of ESPR, including the ban on destruction at End of Life and the requirements for recyclability.