As per the EU’s Ecodesign for Sustainable Products Regulation, Digital Product Passports will become mandatory for fashion and textile products sold in the EU by 2027. If you're an international apparel or footwear brand distributing into European markets, this compliance requirement applies to you regardless of where your headquarters are located. But are you ready? Get the PDF version of this.
Three Swedish fashion brands—Kappahl Group, ETON, and Gina Tricot—participated in the pilot under The Swedish School of Textiles to test what DPP implementation requires. Together with these brands pioneering the way, TrusTrace provided the data structuring infrastructure and technological platform, the DPP Data Protocol, that enabled all the participating brands to launch pilots despite vastly different data maturity levels.
Their learnings matter for any brand preparing for ESPR and other EU compliance. Watch the panel discussion.
You don't need perfect data to start, nor do you need all 126 datapoints right away as detailed in the DPP Data Protocol from Trace4Value. However the same infrastructure from this protocol worked for brands with extensive supply chain data, brands building processes with suppliers from scratch, and brands beginning with just internal product information. What you need is the right structure to work with what you have, and the willingness to start testing now.
As Pauline God from TrusTrace notes, "When you scan the QR code and you see it on your phone or on your laptop it's about 25 to 30 data points that we've selected that is visible to the end consumer. So in the end, the list of 126 data points, some might be visible for the brand only or for the suppliers or a circularity player which is going to resell it or recycle it etc., but just to clarify, we started small. We did not collect 126. It's a suggestion."
"We have had to work on how we should set this up when we have it at scale. Then there was a need for a gap analysis [on DPP datapoints]. What data do we have in our current systems vs what are we missing? So to close those gaps we needed to add a system which was TrusTrace." — Lina Ödeen, Global Head of Sustainability @ ETON
Supplier Education Takes Time Especially for Global Supply Chains
The brands discovered that when they requested detailed data from suppliers, the response was often "why?" Not because suppliers were resistant, but because they were the first brand asking for it. As pioneers, they had to educate suppliers on what data was needed, how it would be used, and why upcoming regulations made it necessary.
For international brands: If your suppliers aren't already serving EU-based brands, factor in additional time for education and relationship-building. This cannot be treated like a checkbox exercise; it's change management across your supply chain.
"We are relying on our good relationships with our suppliers. It has been in our strategy for a long time to work with long term suppliers, so we are entering this DPP journey quite positive." —Julia Persson, Sustainability Coordinator @ Gina Tricot
Serialization Mistakes are Expensive at Scale
One of the brands initially created QR codes at batch level instead of per-item serialization. Discovering this error during testing rather than at full scale was critical. True circularity requires item-level tracking because each item needs its own unique identifier to enable resale, repair, and recycling programs.
The cost of learning this late: Reworking serialization systems after production integration is significantly more expensive than getting it right during pilots.
Physical Implementation has Real Constraints
The brands also tested QR code placement and discovered that care tags become inaccessible when garments are folded on shelves. Hangtags solve in-store usability for employees but get removed by consumers. Durability testing with label suppliers revealed that persistent carriers need to survive multiple wash cycles.
What this means: DPP implementation isn't just a digital infrastructure project. You need to work through physical product design constraints, cost implications, and consumer accessibility challenges.
Even when you have strong supplier relationships and existing data, translating that into DPP-ready infrastructure requires internal buy-in across departments—not just executive approval. Leadership support is the starting point, but cross-functional understanding and nurturing internal DPP ambassadors creates the momentum needed to move forward.
"To have our coworkers as ambassadors in this work has been really good. Also when we are going into phase two, with an actual garment with the [DPP] QR code in place, it's easier to get the change management and understanding, in all levels. " —Viktoria Arndt, Global Sales and Business Developer @ Kappahl Group
ESPR applies to all products sold in the EU, regardless of where your brand is based. Starting early gives you three critical advantages:
Time to build supplier relationships
Global supply chains require more coordination than regional ones. Supplier onboarding and data collection take longer when you're working across different regulatory contexts and time zones. On top of that, other markets are developing their own digital product passport protocols.
Room to test technical solutions
Small-scale pilots let you identify problems when they're still cheap to fix. Serialization errors, data structure gaps, and physical implementation challenges are all easier to solve before full-scale production.
Competitive advantage in European markets
Brands that treat DPP compliance as strategic infrastructure rather than last-minute market access requirements will be positioned for success when 2027 arrives.
"Get started with the DPP, make it easy and collect the data. Make sure that you have the support you need. Systems, partners or whoever."—Isabell Svensson, Buyer and DPP Project Manager @ ETON
This blog only scratches the surface. The complete case study and recorded panel includes:
Download the full case study to access the complete pilot learnings and prepare your brand for 2027 EU compliance. Link to the DPP Use Case Panel Recording.
Ready to improve your data backbone for DPP and beyond? Connect with TrusTrace to explore how supply chain traceability infrastructure can enable your EU market compliance strategy. Contact us.