DPP and EPR Expose Fashion’s Data Infrastructure Gap

A Vogue Business article by Jessica Binns examines how digital product passports (DPP) and extended producer responsibility (EPR) are moving fashion compliance from policy debate to execution. For brands selling in the EU, the challenge is now product data, supplier readiness and end-of-life capacity.

Compliance moves toward execution

Digital product passports, or DPPs, are digital data records linked to physical products. They can contain information on material composition, origin, supply chain, lifecycle data, repairability, recyclability and environmental impact. In practice, this information can be accessed through a machine-readable identifier such as a QR code, NFC tag or RFID tag.

Extended producer responsibility, or EPR, means that producers remain responsible for their products beyond the point of sale. For fashion brands, this includes financial and operational responsibility for collection, sorting, reuse, recycling or disposal at the end of a product’s life.

Both requirements are becoming operational obligations for fashion companies selling in the European Union. They apply regardless of where a brand is headquartered, as long as its products are sold in the EU market.

According to the source article, a simplified DPP with mandatory product information and basic lifecycle data is targeted for late 2027. EPR is expected to become mandatory at scale across the EU by April 2028. The two timelines arrive close together, leaving limited time to build the required data and process infrastructure.

Product data becomes the bottleneck

Even the first DPP phase requires granular product-level information. This can include material composition, recycled content, chemical substances, chain of custody, supplier mapping and lifecycle assessment data.

The article cites Philipp Mayer, co-founder of Retraced, who says that even basic data points such as product weight are often not systematically available. Where data exists, it is frequently spread across PLM, ERP, traceability platforms, lifecycle tools, laboratory reports, spreadsheets and supplier documents.

For system integrators and solution providers, the task is therefore not only to create a passport interface. Brands need a centralized product data layer that can collect, normalize, validate and exchange information across internal systems and supplier networks.

Supplier readiness remains uneven

Supplier-level data is one of the weakest points. Larger brands may already use digital systems, but many upstream suppliers still rely on PDFs, spreadsheets and email.

Ashley Gill of Textile Exchange notes that the readiness gap is especially visible beyond Tier 1, including textile mills, dyeing and finishing facilities, and raw material suppliers. These actors often hold the data that DPPs will require, but lack digital traceability infrastructure.

This makes DPP implementation a change management issue as much as a technology project. Brands need alignment between sourcing, sustainability, production, quality and IT teams. They also need more reliable information flows with suppliers.

DPP and EPR share one data foundation

DPP and EPR are often discussed separately, but both depend on accurate product-level data. DPP focuses on disclosure and transparency. EPR depends on product information for reporting, sorting, reuse, recycling and end-of-life cost allocation.

Liza Amlani of Retail Strategy Group warns that inconsistent data across spreadsheets, PLM, ERP, warehouse management and point-of-sale systems can create problems when products are returned, sorted or allocated to circular processes.

For technology providers, this points to the need for interoperable infrastructure that supports compliance, logistics, resale, recycling and reporting.

Physical infrastructure is lagging

The article also highlights a gap between digital regulation and physical end-of-life capacity. Liz Alessi, founder of the Crisis of Stuff and a sustainability consultant with Bank & Vogue, argues that DPPs are being developed as a data layer, while sorting, resale and recycling systems are not yet equipped to use that data at scale.

The economics remain difficult. In many cases, the cost of collecting, sorting and processing garments exceeds the recoverable value. Recyclers also operate with material thresholds that many current products do not meet.

This has consequences for product design. Brands may need to simplify material choices, reduce complex blends and trims, and align specifications with what recycling systems can process.

Flexible systems needed

The article mentions Eon, Retraced and TrusTrace as companies offering digital product identity, supply chain transparency or compliance-related platforms. However, Mayer emphasizes that no solution can currently claim to support EU DPP requirements end-to-end, because the final rules are not yet fully defined.

The immediate priority is flexible data infrastructure. Brands need systems that can evolve as requirements become more precise. Suppliers need support to digitize and verify compliance-relevant data.

For fashion companies, DPP and EPR are not only regulatory obligations. They expose weaknesses in data governance, supplier relationships and end-of-life systems. For solution providers, they create demand for integration, traceability, identification and lifecycle data architectures that connect products, enterprise systems and physical processes.

Read more in the original Vogue Business article by Jessica Binns:
https://www.vogue.com/article/fashion-is-lurching-toward-a-compliance-reckoning