The European Union’s approach toward Ecodesign for Sustainable Products Regulation (ESPR) may be helping to keep the adoption of digital product passports (DPPs), once a widely hyped technology for supply chain transparency, afloat.
Several years ago, DPPs—which help brands share information about a product’s material makeup, origin, carbon footprint and instructions for end of life—consistently surfaced as a point of discussion. Companies considered their value, conducted pilots and began consolidating data to be used for the consumer-facing portion of the technology. As cost pressures amassed and priorities shifted, some companies halted their adoption or exploration of DPPs—but new movement on the ESPR could be ushering in a resurgence for the traceability tech.
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Despite the bloc’s watering down of other sustainability-related regulations—take the reduced scope of the EU’s Omnibus package designed for streamlining corporate due diligence, as an example—ESPR has already been adopted. Regulators have commenced a process that will soon set forth sector-specific expectations they will enforce under the law.
In April, EU regulators approved the Ecodesign and Energy Labeling Working Plan 2025-2030, which indicated how they view industry prioritization and laid the groundwork for future expectations under the ESPR, including those for textiles and apparel.
According to the plan, EU regulators believe implementing DPPs into the textiles and apparel sectors has “high potential to improve product lifetime extension, material efficiency and to reduce impacts on water, waste generation, climate change and energy consumption.”
Moving forward, EU regulators will propose a delegated act—which helps those impacted by the incoming regulations to better understand the exact requirements they must meet—to be adopted by 2027. The idea, then, is that companies will be in compliance with the requirements in 2027, and the mandates will be enforced in 2028. The act that will clarify the industry’s requirements is likely to be proposed by the end of the year or early 2026.
Megan Brewster, vice president of advanced technology at Impinj, said those acts will dictate the continued movement of DPP integration inside companies—both technology providers and those required to adopt the systems they build.
“DPP is still definitely moving forward. There’s a lot of work going on in the standardization of, ‘What are these digital product passports, and how are they implemented?’” Brewster said. “We are still looking forward to those delegated acts, where we’ll get a better understanding of what the implementation will really look like for these different product categories.”
For all the bureaucracy that remains to be worked out, that the ESPR pervades at all is a win for transparency technology providers. The EU’s legislation looms large and in charge over the heads of some fashion and apparel brands.
Interview-based data from consulting firm Bain & Company and secondhand marketplace eBay research shows that roughly nine in 10 companies deem DPP integration a “regulatory burden;” in other words, a checkbox they must tick off to keep their business compliant in a key market.
Patrick Willemsen, director technical community EMEA at product lifecycle management (PLM) company Aras, said regulation and material provenance are the key reasons companies have started investing resources into DPP integration—but not all companies have started the journey of working toward DPPs.
“We do see some reluctance [toward] spending money on the DPP, especially because the collection of that data takes a lot of time and a lot of effort,” he said. “I think the bigger [companies], they see that they have to be proactive. The smaller ones are reluctant, because it’s not clear to them what is actually needed for the DPP, so they are more in the waiting position.”
Data continues to be a problem for many brands working to integrate technology—mandatory or voluntary—particularly in the fashion industry. That’s because fashion and apparel brands often have siloed data spread across their organizations, which can make consolidating even simple factors for a DPP on a clothing tag a daunting task without the right governance systems and supplier relationships in place.
That’s especially true as companies seem to face stronger-than-ever mandates from the C-suite related to creating value and churning profits. Matteo Capellini, partner at Bain & Company, said that though both EU and the U.S. regulators have backed down from respective legislation in their nations related to sustainability, companies continue to quietly advance their efforts, even if the goalposts have shifted.
“What we’re seeing with this watering down of regulation in Europe is actually a change of paradigm. We summarize this change…with the expression, ‘from morality to materiality.’ Basically, companies are focusing much more on value creation in sustainability, but they’re not slowing the effort,” he said. “Companies, [because of] the politicization of certain issues are speaking less, but they’re not slowing the efforts. This is what we’re seeing with our clients on a daily basis now, and it’s across geographies.”
Each of the three experts noted that, while regulation might be a primary driver for implementing DPPs, brands and retailers are likely to find other value in the technology along the way. Authentication to reduce the spread of counterfeit items is but one benefit experts said DPPs could have; they could also help companies model the environmental impact their products could have before production ever begins.
Part of the allure for companies could be delighting and connecting with the consumer. Bain and eBay’s data shows that, at present, consumers actually reap about two-thirds of the value DPPs offer today. That’s, in large part, because it helps them resell the product with greater ease—and to prove it’s authentic during the process of selling the item.
Capellini said brands and retailers have the opportunity to grab a greater share of that profit back if they enable branded resale programs at scale, rather than forcing consumers to rely primarily on peer-to-peer resale players like eBay, Poshmark, Depop and others.
“Today, secondhand is not a top priority for brands, although everyone, in one way or another, is looking into it or working on it,” he said. “In the next three to five years, we [expect] to start seeing brands seeing the potential increasing year after year of secondhand, coming from this enabler of DPP, and investing in owning the [resale] channel, rather than relying on peer-to-peer platforms like it’s happening today.”
Brewster said sustainability, despite today’s regulatory environment, remains top of mind for consumers and brands alike. She expects to see the secondhand market and other consumer-led sustainability plays continue to expand the market for DPPs. She further noted that other priorities, like traceability and product fidelity, will influence companies’ prioritization of DPPs and other digital identifier technologies, like RFID.
“What we’re seeing from companies is that sustainability remains a priority. It may be in a different place on that list of priorities, but it remains a priority. Other priorities that may be coming further up the list still point them toward the use of digital identifiers,” Brewster said. “‘Sustainability’ may not be the word for today, this year, next year, but it’s for sure coming back.”
Experts said they believe consumers’ interest in sustainability remains. But despite that, consumers’ interest in the digital fingerprints on the day to day is a little more difficult to quantify.
Whether or not EU consumers are on board, DPPs on fashion and apparel items are headed their way within a few short years. But Willemsen said U.S. consumers may not see such stronghanded adoption from their favorite fashion brands—mostly because it’s not fully required.
Instead, he posited, companies will likely begin by implementing DPPs on their EU-based products, both to save money and to make the processes behind integration more streamlined before scaling DPPs into all their markets simultaneously.
“I have the impression that the American companies are waiting a little bit [to see] what the European companies are doing. That makes sense—the Europeans are closer to the fire,” he said. “Global companies will have an advantage of being able to trial and error in Europe and see if [their approach] works.”
